1. Section 4: Security, breaches and complaints

1.1. 4.1 Security and personal data breaches

UK data protection learning

4.1 Security and personal data breaches

Recognising security measures and different forms of breach.

Appropriate security

The UK GDPR requires appropriate technical and organisational measures. “Appropriate” depends on risk, context, cost, current technology and the nature of the data.

Technical measuresOrganisational measures
Multi-factor authentication, encryption, patching, backups, logging, network controls, secure configuration, malware protection and tested recovery. Policies, training, access reviews, supplier management, incident plans, clear roles, secure disposal, physical security and auditing.

What is a personal data breach?

It is a security breach leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data.

Confidentiality breach: data is disclosed to or accessed by an unauthorised person.
Integrity breach: personal data is changed incorrectly or without authorisation.
Availability breach: personal data is lost, destroyed or made unavailable.
A cyberattack is not required. Sending an email to the wrong person, losing an unencrypted device or accidentally deleting records can all be personal data breaches.

Knowledge checkpoint

Answer each question before opening the suggested answer.

1. A spreadsheet is sent to the wrong external recipient. Is this potentially a breach?

Suggested answer: Yes. It may be an unauthorised disclosure.

2. A system encrypts its own database after a ransomware attack. Which aspects may be affected?

Suggested answer: Availability and potentially confidentiality and integrity.

3. Does every personal data breach have to be reported to the ICO?

Suggested answer: No. The reporting threshold depends on risk, but every breach should be assessed and documented.


Official reference points

Legal accuracy: reviewed against official UK sources on 14 July 2026. This learning content is educational and is not a substitute for case-specific legal advice.