What this control covers

Controllers and processors must implement risk-based technical and organizational measures, like pseudonymisation and encryption, to ensure data security, confidentiality, integrity, and availability, with regular testing and restricted access per controller instructions. This control addresses Security of Processing.

Why it matters

Risk is the language an executive team understands; this control connects technical reality to board-level decisions and budget allocation.

How to implement

AWS

Codify the policy intent as SCPs, AWS Config conformance packs, and Security Hub standards so the cloud enforces what the document says.

Azure

Codify in Azure Policy initiatives (built-in regulatory compliance for CIS, ISO 27001, SOC 2, HIPAA) and assign at management-group level.

GCP

Use Cloud KMS with customer-managed encryption keys (CMEK) for BigQuery, GCS, and Compute. Sensitive Data Protection (DLP API) inspects/de-identifies PII at scale.

Google Workspace

Enable client-side encryption for Drive/Docs and turn on Drive Labels + DLP rules to prevent external sharing of regulated data classes.

GitHub

Apply branch protection on default and release branches: require PR review, status checks, signed commits, linear history, and dismiss stale reviews on new commits. Use CODEOWNERS for required reviewers, Dependabot + CodeQL for SAST, and the Dependency graph / SBOM export for vendor disclosures.

On-premises

Maintain a policy library with a documented review cadence (annual minimum); store in your GRC tool with attestation tracking. Map each policy to controls so an audit pull cites the exact policy clause.

Evidence to collect

  • policy_document — A signed, version-controlled policy stating leadership intent and the named owner.
  • infra_scan — See the iCompaas Evidence library for the canonical source for this evidence type.

Signed policy or standard documents the safeguard. Focus: Security of processing.

Quick checklist

  • Data — Controller / Controllers
  • Processor — Controller / Controllers
  • Security — Controller / Controllers
  • Confidentiality — Controller / Controllers
  • Review — Controller / Controllers

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