Short answer: The EU does not give a single, prescriptive “tech checklist.” Under the GDPR you must implement appropriate technical and organizational measures proportional to the risks to people. Below is a practical, controller/processor-ready set of requirements and controls mapped to GDPR expectations. This is general guidance, not legal advice.

Core legal pillars to design against

• Principles (GDPR Art. 5): lawfulness, fairness, transparency; purpose limitation; data minimization; accuracy; storage limitation; integrity and confidentiality; accountability.
• Lawful basis (Art. 6) and, if applicable, special-category data conditions (Art. 9) and criminal-offence data (Art. 10).
• Privacy by design and by default (Art. 25).
• Security of processing (Art. 32): risk-based technical and organizational measures.
• Records of processing (Art. 30) and vendor contracts (Art. 28).
• DPIA for high-risk processing (Art. 35).
• Breach notification (Arts. 33–34).
• International transfers (Chapter V).
• Data subject rights enablement (Arts. 12–22).
• DPO if required (Arts. 37–39).

Technical and security measures commonly expected under Art. 32

• Data inventory and classification

  • Maintain a data map of systems, data types, locations, purposes, retention, and recipients (feeds your ROPA).
  • Classify personal data (including special categories) and tag records for retention/deletion.

• Access control and identity security

  • Least-privilege, role-based access; formal access provisioning and periodic reviews.
  • Strong authentication (MFA) for admins and remote access; conditional access; session timeouts.
  • Segregate duties and separate production from test; no live personal data in test unless strictly necessary and protected.

• Encryption and key management

  • Encrypt personal data in transit (TLS 1.2+ with modern ciphers) and at rest (e.g., AES-256).
  • Manage keys securely (HSM or managed KMS), rotate keys, segregate keys from data, restrict key access to EU personnel if used as a transfer safeguard.
  • Consider field-level encryption or tokenization for high-risk data.

• Pseudonymization and minimization

  • Use robust pseudonymization for analytics or internal sharing; keep re-identification keys separately, with strict access controls.
  • Collect and store only what is necessary; turn off non-essential logging that captures personal data.

• Application and SDLC security

  • Secure coding standards, code review, SCA and SAST/DAST; fix critical vulnerabilities promptly.
  • Threat modeling and privacy-by-design reviews for new features; document residual risks.
  • Protect APIs with authentication, authorization, and rate limiting; validate inputs; prevent injection and IDOR.

• Infrastructure and endpoint security

  • Harden servers, patch OS and applications on defined SLAs; minimize attack surface.
  • Network security: segmentation, firewalls/WAF, least-privilege outbound, secure bastions.
  • EDR/antimalware on endpoints and servers; device encryption; mobile device management for BYOD.

• Logging, monitoring, and auditability

  • Centralize security logs; protect integrity and restrict access; keep audit trails for access to personal data.
  • Detect and alert on suspicious access, exfiltration, and privilege changes.
  • Time-synchronize logs and retain them per policy (and proportional to risk).

• Backups, availability, and integrity

  • Regular, encrypted backups; test restores; protect backups as strictly as production.
  • Anti-tamper controls, checksums, and database integrity constraints.
  • Business continuity and disaster recovery plans with RPO/RTO; test regularly.

• Retention and secure disposal

  • Implement data retention schedules aligned with purposes and legal obligations.
  • Automate deletion/anonymization at end-of-need; cover primary, replicas, analytics stores, caches, and backups (with documented deletion windows).
  • Use verifiable, secure wipe methods for media disposal.

• Data subject rights enablement

  • Ability to find, export, rectify, restrict, and delete data per data subject within one month.
  • Export in a structured, commonly used, machine-readable format (e.g., JSON/CSV).
  • Identity verification process, rate limiting, and secure delivery channels.

• Incident response and breach notification

  • Written IR plan: triage, containment, forensics, communication, lessons learned.
  • Assess personal data breach impact and notify the supervisory authority within 72 hours if required; notify affected individuals if high risk.
  • Keep a breach register.

• Vendor and cloud management (Art. 28)

  • Data Processing Agreements with processors, including confidentiality, TOMs, subprocessor approval, assistance with rights and breaches, deletion/return on termination, and audit rights.
  • Due diligence: security posture, certifications (e.g., ISO 27001/27701), penetration tests, location of processing and support.
  • Ongoing oversight and documented risk assessments.

International data transfers (Chapter V)

• No general EU data-localization rule, but transfers outside the EEA require safeguards.
• Use an adequacy decision where available (e.g., EU–US Data Privacy Framework for certified US recipients), or Standard Contractual Clauses/BCRs plus a Transfer Impact Assessment.
• Implement supplementary measures when needed, such as strong encryption with EEA-only key control, minimization, and access transparency. Monitor legal developments and EDPB guidance.

Special categories and children’s data

• If processing special-category data (health, biometrics, etc.), apply stricter access, stronger encryption, and explicit lawful bases (Art. 9).
• For children, verify age and obtain/verify parental consent where required; member-state ages vary (13–16).

Organizational measures that support the tech controls

• Appoint a DPO if your processing triggers Art. 37 criteria; otherwise designate a privacy lead.
• Maintain ROPA (Art. 30), policies (security, retention, access control, incident response), training, and regular risk assessments/DPIAs for high-risk processing.
• If you are outside the EU but target EU residents, appoint an EU representative (Art. 27).

Standards and helpful frameworks

• ISO/IEC 27001 for ISMS; ISO/IEC 27701 for privacy extensions.
• ENISA security recommendations; CIS Controls v8 mapped to GDPR; OWASP ASVS for app security.
• Industry codes of conduct or certifications (where applicable) can help demonstrate accountability.

Common pitfalls to avoid

• Backups and logs retaining personal data beyond stated retention.
• Using production personal data in test without equivalent protections.
• Over-broad admin access and lack of access reviews.
• Collecting more data than needed or keeping it “just in case.”
• Relying on a DPA alone without verifying a processor’s actual controls.

Quick starter checklist

• Map your data and systems; create ROPA entries.
• Set lawful bases and retention periods per data set; implement deletion jobs.
• Enforce MFA, RBAC, encryption in transit/at rest, patching SLAs, and centralized logging.
• Build DSR tooling and workflows; test with a mock request.
• Draft and test an incident response plan; set 72-hour breach assessment workflow.
• Sign Art. 28 DPAs with vendors; complete TIAs for any international transfers.
• Run a DPIA for any high-risk processing; document privacy-by-design decisions.