Privacy Program - Technical & Organizational Controls

Article

32 GDPR explicitly names pseudonymization and encryption of personal data. A complete privacy program also includes: access controls and authorization management, firewalls and intrusion detection systems, automated logging of all data access, secure data transmission (TLS/SSL), backup and recovery procedures, and regular vulnerability scanning. The selection depends on the state of the art, implementation costs, and the risk level of each processing activity.

Organizational measures ensure that technical safeguards work in practice. They include: data protection policies and processing instructions, authorization concepts based on the need-to-know principle, regular staff training on data protection, confidentiality agreements, incident response and breach notification procedures, data processing agreements under Article

28 GDPR, and regular effectiveness reviews. ADVISORI supports the creation and implementation of these documents and processes.

A TOM implementation plan follows four steps: First, inventory all processing activities and existing safeguards. Second, conduct a risk assessment evaluating the likelihood and severity of potential data breaches. Third, select specific measures considering the state of the art and implementation costs. Fourth, document everything in the records of processing activities under Article

30 GDPR. The plan must be regularly reviewed and updated.

TOMs under Article

32 GDPR are protective measures for existing processing activities � they secure ongoing processes. Privacy by Design under Article

25 GDPR requires that data protection is built into new systems, products, and processes from the outset. In practice, both complement each other: TOMs implement current protection, while Privacy by Design ensures new projects are designed with data protection from day one. An effective privacy program links both approaches.

Violations of Article

32 GDPR can result in fines of up to

10 million euros or

2 percent of annual global turnover. Supervisory authorities check not only whether measures exist but whether they reflect the state of the art and are regularly tested for effectiveness. Lack of documentation increases the risk. For example, the Austrian data protection authority imposed a fine in

2023 for inadequate encryption and missing access logging.

ADVISORI follows a proven approach: First, we analyze existing security measures and identify gaps against Article

32 GDPR. Then we develop an implementation plan that builds on your existing IT infrastructure and compliance frameworks � such as ISO 27001, BSI IT-Grundschutz, or industry-specific requirements. Implementation proceeds step by step, prioritized by risk. We prepare the required documentation and train your staff on new processes.

Encryption is the only technical measure explicitly named in Article

32 GDPR. It protects data at rest (on storage media), in transit (during transmission), and in use (during processing). A key benefit: when a data breach involves encrypted data, the obligation to notify affected individuals under Article

34 GDPR may not apply, as the risk to data subjects is considered low. ADVISORI recommends at least AES‑256 for data at rest and TLS 1.3 for data in transit.