GDPRArt. 35voice-validated
GDPR Art35: Art. 35
General Data Protection Regulation (EU 2016/679)
AL
Founder at SQUR · last verified 2026-06-19
Regulation text
Where a type of processing is likely to result in a high risk to the rights and freedoms of natural persons, the controller shall, prior to the processing, carry out an assessment of the impact of the envisaged processing operations on the protection of personal data. The assessment shall contain a systematic description of the envisaged processing, an assessment of necessity and proportionality, an assessment of risks, and the measures envisaged to address those risks.
ATT&CK techniques this article tests · 15
| Technique | Why it maps | Confidence |
|---|---|---|
| T1190 | 1. Exploiting public-facing applications is a primary initial access vector. A Data Protection Impact Assessment (DPIA) failing to identify and mitigate vulnerabilities in such applications, especially those processing personal data, directly enables this technique. GDPR Art. 35 mandates assessing risks to personal data. | 90% |
| T1566 | 1. Phishing campaigns target individuals with access to sensitive data. An inadequate DPIA, as required by GDPR Art. 35, may overlook human element risks and the need for security awareness training, facilitating initial access and credential theft. | 80% |
| T1547 | 1. Attackers establish persistence by modifying boot or logon processes. A DPIA not identifying critical system configurations or hardening requirements for systems processing personal data, as per GDPR Art. 35, allows this technique to succeed. | 70% |
| T1068 | 1. Exploitation for privilege escalation leverages software vulnerabilities. A DPIA failing to assess and address risks from unpatched or misconfigured software on systems handling personal data, as required by GDPR Art. 35, enables attackers to gain higher privileges. | 80% |
| T1027 | 1. Obfuscation helps attackers evade detection. If a DPIA does not mandate robust logging, monitoring, and security controls for data processing activities, as per GDPR Art. 35, adversaries can more easily hide their actions. | 70% |
| T1003 | 1. OS credential dumping targets credentials stored in memory or on disk. A DPIA failing to assess and mandate secure credential management practices for systems accessing personal data, as required by GDPR Art. 35, directly facilitates this technique. | 80% |
| T1083 | 1. File and directory discovery is crucial for locating personal data. A DPIA, as per GDPR Art. 35, should systematically describe data processing and data locations; a failure here makes data discovery easier for attackers. | 90% |
| T1046 | 1. Network service discovery helps attackers map the environment. A DPIA not assessing network architecture, segmentation, and exposed services related to personal data processing, as required by GDPR Art. 35, aids adversary reconnaissance. | 70% |
| T1021 | 1. Remote services are used for lateral movement. A DPIA failing to identify and secure remote access points to systems containing personal data, as per GDPR Art. 35, creates pathways for attackers to move across the network. | 80% |
| T1005 | 1. Data from local system involves collecting personal data directly from compromised endpoints. Inadequate access controls or data minimization, not identified by a DPIA (GDPR Art. 35), directly enables this collection. | 90% |
| T1039 | 1. Data from network shared drives is a common collection point. A DPIA failing to assess and restrict access to personal data stored on network shares, as required by GDPR Art. 35, facilitates bulk data collection. | 80% |
| T1074 | 1. Attackers stage collected data before exfiltration. A DPIA not mandating monitoring for unusual data aggregation or transfers within the network, as per GDPR Art. 35, allows this preparatory step to go unnoticed. | 80% |
| T1071 | 1. Application Layer Protocol is frequently used for command and control. A DPIA failing to assess network traffic patterns and the need for egress filtering, as required by GDPR Art. 35, can allow C2 communications to persist. | 70% |
| T1041 | 1. Exfiltration over C2 channel is a primary method for data theft. A DPIA not identifying and mitigating risks of unauthorized data egress, as per GDPR Art. 35, directly enables the loss of personal data. | 90% |
| T1486 | 1. Data encrypted for impact (ransomware) can severely disrupt operations and data availability. A DPIA failing to assess and implement measures against such impact, including robust backups and recovery, as required by GDPR Art. 35, leaves personal data vulnerable. | 80% |
Defending mitigations · 7
| Mitigation | What it does | Confidence |
|---|---|---|
| M1017 | 1. User Account Management directly controls who can access personal data. A DPIA, as per GDPR Art. 35, must assess necessity and proportionality of access, leading to robust account management to reduce risk. | 90% |
| M1035 | 1. Limiting Access to Resources is a fundamental measure to protect personal data. GDPR Art. 35 requires assessing risks and implementing measures, making access limitation a direct outcome of a compliant DPIA. | 90% |
| M1021 | 1. Auditing and logging are critical for detecting and responding to incidents involving personal data. A DPIA, as per GDPR Art. 35, identifies the need for such monitoring to address risks. | 80% |
| M1031 | 1. Network Segmentation isolates systems processing personal data, reducing the blast radius of a breach. A DPIA, as required by GDPR Art. 35, assesses network risks and recommends such architectural controls. | 80% |
| M1040 | 1. Data Backup mitigates the impact of data loss or destruction. GDPR Art. 35 mandates assessing risks and implementing measures, making data backup a crucial control identified by a DPIA for data integrity and availability. | 80% |
| M1015 | 1. Active Directory Configuration, when secure, prevents many credential access and lateral movement techniques. A DPIA, as per GDPR Art. 35, should assess identity and access management risks, leading to secure AD configurations. | 70% |
| M1048 | 1. Network Intrusion Prevention detects and blocks malicious network traffic, including C2 and exfiltration. A DPIA, as required by GDPR Art. 35, identifies the need for network security measures to protect personal data. | 70% |
Underlying weaknesses · 7
| CWE | Why it persists | Confidence |
|---|---|---|
| CWE-200 | 1. Exposure of Sensitive Information is the direct outcome a DPIA (GDPR Art. 35) aims to prevent. Failure to conduct or adequately perform a DPIA leads to unmitigated risks of personal data exposure. | 90% |
| CWE-284 | 1. Improper Access Control is a fundamental weakness that a DPIA (GDPR Art. 35) is designed to identify and address. Without proper assessment, personal data can be accessed by unauthorized individuals. | 90% |
| CWE-311 | 1. Missing Encryption of Sensitive Data is a critical risk for personal data. A DPIA, as per GDPR Art. 35, must assess the necessity and proportionality of data protection measures, including encryption, to mitigate this weakness. | 80% |
| CWE-269 | 1. Improper Privilege Management allows attackers to gain elevated access. A DPIA, as required by GDPR Art. 35, should identify and mandate controls to ensure least privilege for systems handling personal data. | 80% |
| CWE-522 | 1. Insufficiently Protected Credentials directly enables credential access techniques. A DPIA, as per GDPR Art. 35, must assess risks related to authentication and credential storage for systems processing personal data. | 80% |
| CWE-668 | 1. Exposure of Resource to Wrong Sphere refers to data or resources being accessible where they should not. A DPIA, as required by GDPR Art. 35, assesses data flows and storage locations to prevent such exposures. | 70% |
| CWE-732 | 1. Incorrect Permission Assignment for Critical Resource is a specific form of access control weakness. A DPIA, as per GDPR Art. 35, should identify and rectify such misconfigurations to protect personal data. | 70% |
What SQUR Covers
Web application + API pentesting for OWASP Top 10, business logic flaws, authentication bypass, injection attacks, and other application-layer vulnerabilities. €1,995 per scan, 24-hour turnaround, EU-only data.
What SQUR Does Not Cover
Internal network pentesting, endpoint security testing, physical security assessments, social engineering, or ICT third-party concentration risk reviews. Engage a complementary provider for those scope items.
Provenance
Mapped Q2.2026 using gemini-2.5-flash · €0.0204 compute · voice-rubric self-validated