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ARTICLE · 10 JANUARY 2019

ICO Issues Guidance On Encryption And Passwords Under The GDPR

Herzog Fox & Neeman
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The ICO added that in some circumstances, organisations might be subject to regulatory action if unencrypted data is lost or destroyed.

United KingdomPrivacy
Herzog Fox & Neeman
Herzog Fox & Neeman

The Information Commissioner's Office ("ICO") has updated its GDPR guidance ("the Guidance ") in order to include security guidance that focuses on encryption and passwords, in the context of taking appropriate technical and organisational security measures (as required by Article 32 of the GDPR):

Encryption:

The ICO suggests that all organisations should have an encryption policy in place, which will govern the use of encryption and will include guidelines to assist staff training in relation to the use of encryption.

In addition, the organisations must ensure that the planned encryption solution meets current acceptable standards, such as FIPS 140-2 and FIPS 197. Organisations should also be aware of the residual risks of encryption (e.g., by conducting a data protection impact assessment), and take steps to address such risks.

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