GDPR Technical & Organizational Measures (TOMs) Under Article 32

TOMs under Article

32 GDPR are security measures to protect personal data. Technical measures include encryption, firewalls, and access controls. Organizational measures cover policies, staff training, defined responsibilities, and processes to ensure ongoing data security.

Article

32 specifies pseudonymization and encryption, the ability to ensure confidentiality, integrity, availability, and resilience of processing systems, the ability to restore access to data promptly after an incident, and a process for regularly testing and evaluating the effectiveness of measures.

TOMs must be documented in writing and regularly updated. Documentation includes a description of each measure, mapping to protection objectives, responsibilities, implementation status, review intervals, and evidence of effectiveness. It forms part of the records of processing activities.

Technical measures include data and communication encryption, physical access control to server rooms, logical access control through password policies and MFA, role-based authorization concepts, logging, automatic security updates, and backup systems.

Organizational measures include data protection policies, staff training programs, confidentiality agreements, four-eyes principle, clean desk policies, emergency plans, regular audits, and documented processes for data subject rights and breach notifications.

Appropriateness is assessed based on the state of the art, implementation costs, the nature and scope of processing, and the likelihood and severity of risks to individuals. A risk-based approach requires stronger measures for more sensitive data and higher risks.

Article

32 requires regular review and evaluation of effectiveness. Best practice includes annual TOM audits plus event-driven reviews after security incidents, system changes, or new processing activities. All results must be documented.