GDPR Art. 32 · Security of processing

What the supervisory authority
asks you to prove.

GDPR Article 32 isn't a recommendation: it sets four binding technical obligations on personal-data security. Here's what it requires — and how Securoo helps you demonstrate each one.

The context

What is the GDPR, in short.

The General Data Protection Regulation (EU 2016/679, "GDPR") is the European law protecting the personal data of EU citizens. It has been in force since 25 May 2018 and applies to anyone — public or private, inside or outside the EU — who processes data of European residents.

For a professional firm (lawyer, accountant, notary, insurance broker, doctor, property manager) it means something very concrete: you are the "data controller" of your clients' data. It is your responsibility to safeguard them with appropriate technical measures. The supervisory authority holds you accountable in case of a breach — not your software vendor.

Applies to everyone

Solo practice or multinational, online or paper-based: if you process EU citizens' data, GDPR applies. No size-based exemptions.

You are the controller

You decide the purposes and the means of processing. You are the primary responsible party before the regulator: the technical vendor is your "external processor".

Declaring isn't enough

The accountability principle (Art. 5.2) requires you to demonstrate the measures adopted, not just claim them. Audit log, DPA, processing register.

Sanctions are real

Up to € 20M or 4% of global turnover. Hundreds of penalties actively imposed by European supervisory authorities every month.

What the article says

Four technical obligations, binding.

GDPR — Article 32, paragraph 1 — requires appropriate technical and organisational measures to ensure a level of security appropriate to the risk. In particular:

"Taking into account the state of the art, [...] the controller and the processor shall implement appropriate technical and organisational measures [...] including, as appropriate: [a] the pseudonymisation and encryption of personal data; [b] the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services; [c] the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident; [d] a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing." — GDPR, Art. 32, para. 1
a)

Encryption and pseudonymisation

Encrypt personal data to ensure confidentiality by default, and apply pseudonymisation where possible.

b)

Confidentiality, integrity, availability, resilience

Ensure on a permanent basis the four properties of systems processing personal data.

c)

Timely restoration

Restore availability and access to personal data quickly in the event of a physical or technical incident.

d)

Periodic testing and review

A documented process for regularly testing, assessing and evaluating the effectiveness of the measures adopted.

Key point

Encryption is not optional.

Article 32, letter (a), explicitly cites the encryption of personal data as an example measure. It is the only technical measure named by name in the regulation. In practice: without encryption, demonstrating an "appropriate level of security to the risk" before a regulator is virtually impossible.

Every client document — contract, expert report, ID, medical record — must be encrypted. Locking it behind a cloud-drive password isn't enough: you need end-to-end encryption with keys the vendor doesn't hold.

Securoo measures

How Securoo covers the four obligations.

Point by point. No vague claims: every measure has a verifiable technical reference.

a)

Zero-knowledge end-to-end encryption

AES-256 for content, RSA 4096-bit for keys. Keys never reach our servers.

How it works: documents are encrypted on your device before being uploaded. The decryption key never reaches our servers. Even we cannot read the content — technically, not just contractually. GDPR explicitly cites encryption as an example measure for satisfying Art. 32.1.a.
b)

Four properties on a permanent basis

Confidentiality, integrity, availability, resilience — each backed by a dedicated technical mechanism.

Confidentiality: end-to-end zero-knowledge model. Integrity: SHA-256 hash + RFC 3161 timestamp verifiable by accredited CA on every file. Availability: multi-region EU geographic replication, 99.9% contractual SLA (99.99% Enterprise). Resilience: redundant infrastructure on OVH (France), zero non-EU sub-processors.
c)

Daily backups + 4-hour restoration

RPO < 1 hour · RTO < 4 hours · 30-day retention.

Daily incremental backups, retained for 30 days. Recovery Point Objective under 1 hour (max admissible data loss) and Recovery Time Objective under 4 hours (max restoration time). Disaster-recovery drills every six months, recorded and documented for regulator audits.
d)

Annual audits, external pen tests, ISO 27001

Documented periodic testing and review for every calendar year.

Annual security audits run by accredited third parties. External penetration tests with reports available under NDA for Enterprise customers. ISO 27001 alignment in consolidation. The organisational side (staff training, internal procedures, policies) remains your responsibility — we provide the templates.
What you risk

The fines a regulator can apply.

Non-compliance with Art. 32 isn't a bureaucratic formality: administrative sanctions are concrete, recent, and being applied across the EU. The European case law — including against small firms — is now well established.

€ 20M
Maximum fine for Art. 32 violations — or 4% of global annual turnover, whichever is higher.
72 h
Maximum window to notify a data breach to the supervisory authority (Art. 33). Past that window the penalty escalates.
2,000+
GDPR fines issued across Europe in 2024, more than half tied to Art. 32 obligations.

What has already happened (recent examples)

  • Law firm, Italy (2024): €20,000 fine for client documents stored on an unencrypted cloud drive accessible to unauthorised staff.
  • Accounting firm, Spain (2023): €50,000 for the loss of a corporate device containing tax data in the clear, with no full-disk encryption.
  • Notary, Germany (2024): formal warning + €12,000 fine for exchanging deeds via unprotected email, after a client complaint.
  • Medical practice, France (2024): €800,000 for unauthorised access to patient records on unencrypted servers, plus a six-month remediation order.

Sanctions are public: the supervisory authority publishes the order online with the firm's name. The reputational impact is often more costly than the fine itself.

Are you really compliant with Article 32?

Five questions, three minutes. You'll receive a quick assessment of your exposure and a downloadable checklist ready to share with your DPO or legal counsel.