GDPR Article 32
for engineering teams.
Article 32 is the article most aimed at engineering — and the one most cleanly mapped to cloud controls you can actually verify. This is the paragraph-by-paragraph version: requirement, evidence schema, control IDs, agent prompts.
What "security of processing" actually says.
Article 32 doesn't tell you what to build. It says implement "appropriate technical and organisational measures" with reference to four named ones — pseudonymisation, encryption, CIA, restore — and then defers to risk assessment. That phrasing is what makes it confusing for engineers.
The phrasing is also what makes Article 32 the most-cited article in supervisory action. Below is the version where every paragraph is a concrete engineering surface, with the evidence supervisors actually look for.
pseudonymisation + encryption
Implement pseudonymisation and encryption of personal data — TLS 1.2+ in transit, AES-256 at rest, KMS with key rotation ≤ 365 days.
- ·TLS termination policy
- ·at-rest encryption per data store
- ·KMS key + rotation config
- ·pseudonymisation design doc
- ·periodic review record
Cloud_Security: DP-3, DP-4, DP-5, DP-6 · NIST CSF: PR.DS-01 · OWASP: A04 cryptographic failures
CIA — confidentiality, integrity, availability
Ongoing confidentiality, integrity, availability, and resilience of processing systems and services.
- ·SLO definition
- ·incident response runbook
- ·integrity check / signing
- ·replication topology
NIST CSF: PR.DS, PR.IP · ISO 27001: A.8.16, A.8.21
restore in timely manner
Ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident.
- ·backup config
- ·restore test log (last 90 days)
- ·documented RTO/RPO
NIST CSF: RC.RP-01 · ISO 27001: A.8.13, A.8.14
periodic testing
Process for regularly testing, assessing, and evaluating the effectiveness of technical and organisational measures.
- ·pen-test report
- ·scanner cadence
- ·control-effectiveness review
NIST CSF: ID.RA, PR.IP-12 · ISO 27001: A.8.29
risk-based assessment
Risk assessment must consider risks of unauthorised access, accidental loss, alteration, or disclosure.
- ·threat model
- ·risk register
- ·assessment cadence
NIST CSF: ID.RA · ISO 27001: A.8.8
instruction-bound processing
Natural persons under controller authority process personal data only on documented instructions, with technical enforcement.
- ·IAM policy with purpose tags
- ·audit log linking access to documented purpose
- ·periodic access review record
Cloud_Security: PA-1, PA-7 · NIST CSF: PR.AC
One bundle, one loop.
The full Article 32 surface is bundled in RuleMesh as access-control-security: 19 IT requirements, 89 evidence checks, 17 high-risk items, mapped to AWS, Azure, GCP, NIST CSF, and OWASP Top 10.
~/your-repo $ claude mcp add rulemesh # in your agent: Pull the access-control-security bundle from rulemesh. For each requirement, walk the repo and infrastructure config, decide met / partial / todo, capture evidence references, and submit signals. Then print a markdown report grouped by paragraph (32(1)(a), 32(1)(b)...).
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