GDPR Encryption and Pseudonymisation Requirements (Art 32 in Practice)

Article 32 in practice

Pair encryption standards with key management, access control, logging, and restore testing. Document why the residual risk is acceptable for each processing purpose.

Pseudonymisation patterns

• Tokenisation for identifiers in lower environments
• Separate vaults for re-link keys
• Role-based reveal workflows with audit trails

Evidence auditors and DPAs expect

Key rotation records, configuration baselines, access reviews, and incident tabletop notes. SIEM alerts on anomalous decrypt or key use strengthen the story.

How CyberSilo Helps

• Evidence mapping in CyberSilo CSA
• Detection and logging proof with ThreatHawk SIEM
• Advisory scoping — contact CyberSilo

Frequently Asked Questions

Is encryption always mandatory under GDPR?

Article 32 is risk-based; encryption is a named measure often expected for higher-risk data, not a blunt universal rule.

Is hashed email anonymous?

Often not — hashing alone may remain personal data. Assess re-identification risk.

Do we need to name algorithms in the privacy notice?

Usually describe measures at an appropriate level; keep deep crypto detail in internal security docs.

Related Resources

• GDPR hub
• Privacy PETs