implementing-gdpr-data-protection-controls

Article 32 requires pseudonymization and encryption of personal data, confidentiality and resilience of processing systems, restore capability, and regular testing. Implement AES-256 for data at rest, TLS 1.2+ in transit, RBAC with least privilege, and MFA on systems processing personal data.

A Data Protection Impact Assessment under Article 35 is required for processing likely to result in high risk to individuals, such as large-scale profiling or sensitive data processing. It documents risks and mitigations, and its recommendations like pseudonymization must actually be implemented, not just written.

Issue a real test erasure request and confirm the data subject is removed from primary databases, replicas, search indexes, and restored backup samples. Erasure workflows must cascade deletion to archives, not just the production system.

GDPR Articles 44-49 require a valid transfer mechanism such as adequacy decisions, SCCs, or BCRs for cross-border transfers. Verify the actual TLS endpoint and destination region, since signed SCCs do not help if traffic lands in a non-adequate region without a transfer impact assessment.

Consent must be granular, withdrawable, and auditable, and it fails when there is an imbalance of power or when withdrawal is impractical. Many processing activities are better grounded in legitimate interest or legal obligation rather than over-relying on consent.