Data Security Requirements for DAC8 Reporting

Protecting DAC8 data from unauthorized access, breaches, and misuse is both a GDPR obligation and a practical necessity. This article outlines the security measures CASPs should implement.

GDPR Security Requirements

Article 32 of GDPR requires data controllers to implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk. Given the sensitivity of DAC8 data — which includes financial transaction details, TINs, and personal identification information — the required security level is high.

Technical Measures

CASPs should implement encryption of all DAC8 data at rest and in transit using strong encryption standards, access controls that limit DAC8 data access to authorized personnel on a need-to-know basis, audit logging that records all access to DAC8 data including who accessed what data and when, network security measures including firewalls, intrusion detection, and segmentation of DAC8 data systems, secure backup and recovery procedures to ensure data availability, and secure deletion procedures that permanently remove data when retention periods expire.

Organizational Measures

Beyond technical controls, CASPs should implement regular security training for staff with access to DAC8 data, background checks for personnel in sensitive compliance roles, incident response procedures specifically addressing DAC8 data breaches, regular security assessments and penetration testing, vendor management procedures for any third parties that process DAC8 data, and documented security policies that are reviewed and updated regularly.

Breach Notification

Under GDPR Article 33, CASPs must notify the supervisory authority within 72 hours of becoming aware of a personal data breach. If the breach is likely to result in a high risk to affected individuals, the individuals must also be notified under Article 34. A breach of DAC8 data — containing financial and tax identification information — would almost certainly meet the high-risk threshold.

Conclusion

DAC8 data security is not optional — it is a legal requirement under GDPR and a practical necessity to protect both users and the CASP's reputation. CASPs should implement comprehensive security measures proportionate to the sensitivity and volume of the data they process.