← NDPA 2023 · Security
s.39 — Security, integrity and confidentiality
Requirement
A data controller or processor shall implement appropriate technical and organisational measures to ensure the security, integrity and confidentiality of personal data, taking into account the risk — such as pseudonymisation or encryption, access controls, resilience of systems, and periodic testing of the effectiveness of those measures (s.39).
What the engine looks for
Every group below must be satisfied — by an affirmative statement, not a plan, a hedge or a denial — for the control to count as covered. A term ending in … matches any word it begins. Supporting terms do not change the verdict — they raise confidence and distinguish a policy that names a mechanism from one that gestures at a category.
Finding any of these outranks coverage — a policy that admits the gap is worse than silence.
Equivalent controls elsewhere
Matched on shared topics. Satisfying this control usually moves these too.
| Framework | Control | Title | Shared topics |
|---|---|---|---|
| GDPR | Art.32 | Security of processing | encryption-at-rest encryption-in-transit access-control backup |
| GDPR | Art.5(1)(f) | Integrity and confidentiality | encryption-at-rest encryption-in-transit access-control |
| CCPA/CPRA | 1798.100(e) & 1798.150 | Reasonable security procedures | encryption-at-rest access-control |
| SOC 2 | CC6.1 | Logical access provisioning and restriction | access-control encryption-at-rest |
| SOC 2 | CC6.7 | Restriction of information transmission, movement and removal | encryption-in-transit encryption-at-rest |
| ISO 27001 | A.8.24 | Use of cryptography | encryption-at-rest encryption-in-transit |
| GLBA | 314.4(c)(3) | Encryption of customer information in transit and at rest | encryption-at-rest encryption-in-transit |
| GDPR | Art.29 | Processing under the authority of the controller | access-control |