October has rolled around again. It’s a month that marks two big events: Cybersecurity Awareness Month and Halloween.

But if you think we’re going to play off horror movie tropes to talk about the importance of cybersecurity, surprise! We’re taking things in another direction this year. Instead of scary scenarios, we’re going to talk about another Halloween staple: candy.

Just like the neighborhood kids mandate Halloween candy but don’t tell you which brand to buy (although full-size bars will make you the talk of the town), privacy regulations work the same way. They don’t hand companies a shopping list of tools or platforms, but they do set the security expectations: take appropriate measures to protect personal data, regardless of the brand you choose.

This is worth noting because when GDPR calls for “appropriate technical measures” or CCPA requires “reasonable security,” cybersecurity teams find themselves setting up controls specifically to protect personal data. And because traditional security programs weren’t designed for privacy compliance, they don’t always lead to results expected.

Building cybersecurity programs that satisfy both security and privacy requirements requires three tactical shifts:

1. Design security controls that generate privacy compliance evidence

Privacy regulations often require cybersecurity programs to prove they protect personal data according to legal standards, not just demonstrate technical security capabilities. This means selecting and configuring controls that generate the specific evidence privacy auditors expect.

Privacy laws define specific technical requirements

GDPR Article 32 requires encryption that renders personal data “unintelligible to unauthorized parties”—a legal standard that demands specific key management documentation, access logs showing who can decrypt what data, and evidence that the encryption method prevents unauthorized access to personal information.

Standard data encryption for breach protection won’t satisfy this requirement without the additional privacy-focused documentation.

The CCPA’s audit requirements, starting in 2027, will evaluate whether cybersecurity controls specifically protect personal data according to regulatory definitions. This means that access controls must capture not only who accessed systems, but also the legal justification for that access under privacy law.

Choose tools that generate audit evidence

When evaluating security tools, ask whether they can generate audit trails that prove compliance with privacy law requirements, not just whether they prevent attacks. Your firewall might stop intrusions, but can it demonstrate that personal data access complies with GDPR’s lawful basis requirements? Your backup system might ensure business continuity, but can it quickly identify what personal data was compromised during a ransomware attack?

Like choosing full-size candy bars instead of fun-size ones, privacy-compliant security controls cost more upfront but satisfy the audience that’s evaluating your efforts: the regulators who can impose million-dollar fines for inadequate technical measures.

2. Map personal data flows to security architecture decisions

Privacy regulations add personal data protection as a key factor in security architecture decisions. While factors such as network topology and system criticality are undeniably important, cybersecurity programs must also consider the types of personal data being processed and their associated privacy risks when determining protection levels.

Start with privacy risk assessments

Privacy Impact Assessments under the GDPR, CCPA risk assessments, and similar privacy evaluations identify which data processing activities create “high risk” or “significant risk” to individuals. These determinations trigger legal requirements for enhanced security measures, but they don’t specify which technical controls to implement.

When a privacy assessment determines that certain data processing creates “high risk” under GDPR—such as AI systems that profile customers or make automated decisions about them—it may trigger requirements for a Data Protection Impact Assessment and enhanced security measures under Article 32.

However, translating “enhanced security” into specific controls requires security assessments to understand technical vulnerabilities and implementation options. To achieve this, privacy and security can work together:

  • Privacy assessments identify what needs additional protection and why
  • Security assessments determine how to implement those protections

This coordinated approach allows for technical controls to address both privacy compliance requirements and security threats, instead of treating them like separate exercises.

Create data-specific security requirements

Create a matrix that maps personal data categories (customer contact information, financial records, health data, employee information) to the security controls each category requires under applicable privacy laws. Different data types require different protection levels based on their privacy impact, not just their business value.

For example, customer email addresses used for marketing might require standard encryption and access logging. But health information processed through AI algorithms would require enhanced encryption with documented key management, detailed access justification logs, algorithmic impact assessments, and additional monitoring to detect unauthorized processing.

3. Build an incident response that satisfies privacy notification requirements

When a cybersecurity incident happens, most teams focus on containment, recovery, and getting systems back online. But privacy laws have added another urgent requirement: proving to regulators that you understand what personal data was affected and how it impacts the individuals involved.

This dual requirement means cybersecurity incident response has two objectives: technical recovery and regulatory compliance. To achieve them both, security teams need response procedures that quickly assess personal data exposure while providing the detailed privacy impact information regulators require within strict notification timelines.

Understand regulatory notification requirements

GDPR requires notification within 72 hours that includes “the categories of personal data concerned” and “likely consequences for individuals.” This means incident response teams must quickly determine whether the breach involved customer contact information, financial records, health data, or other personal data categories—and assess specific privacy risks to individuals, not just system damage.

For ransomware attacks, teams must document whether personal data was exfiltrated before encryption, since privacy laws often treat data theft differently from data encryption. Many state breach notification laws require notification only if personal information was “acquired,” not just accessed. These legal distinctions require understanding privacy law definitions during active incident response.

Design privacy-aware response procedures

The tactical requirement is that incident response strategies must include privacy-specific procedures alongside technical recovery steps. Pre-identify where personal data is stored, establish communication protocols with privacy professionals during active incidents, and create templates for regulatory notifications that can be populated with technical findings.

Train response teams to capture the privacy compliance evidence that regulators expect, including which personal data categories were affected, the number of individuals impacted, the likely consequences for those individuals, and the measures being taken to address privacy risks. This isn’t just technical forensics—it’s regulatory compliance documentation that must be generated during the crisis.

Just like you wouldn’t wait until Halloween night to figure out your candy strategy, cybersecurity teams can’t wait until they’re managing an active breach to figure out how to assess privacy regulatory impact.

The Full-Size Bar Approach: Security + Privacy Done Right

Privacy regulations set the expectation—protect personal data—without specifying which security controls to use. The organizations that succeed choose their cybersecurity “candy” wisely: programs designed to satisfy both security threats and privacy regulatory requirements.

Red Clover Advisors offers downloadable resources to help you build privacy-compliant cybersecurity programs:

If your cybersecurity program needs to address privacy regulatory requirements, contact Red Clover Associates. We help organizations translate privacy law obligations into practical cybersecurity program requirements.

Downloadable Resource

6 Steps Privacy Leaders Can Use to Strengthen Cybersecurity Checklist

 

 

Turn your privacy expertise into cybersecurity resilience with six actionable steps in this checklist.

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