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Section 17.3

Security Focus Areas and the Process for Each

Last updated 12 Oct 2026

01

At a glance

An index of the security-related focus areas an operator has to cover, grouped under the three pillars (privacy, cybersecurity, telecom regulatory compliance), with the process each one calls for and what that process leaves behind. A map for knowing which conversation to start, not a manual for having it.

02

The picture

PRIVACY — GDPR, EPRIVACYPersonal data processingDPIA · RoPAData flows & third partiesdata-flow map · DPAData protection in systemsclassification · retentionConsent & communications datalawful basis · consentCYBERSECURITY — NIS2Riskrisk assessment · threat modelIdentity & accessJML · access review · PAMAPI & integration securityAPI security reviewVulnerabilitiesvuln. management · pen testIncident responseIR plan · drills · notificationSupplier securitysupplier assessmentBusiness continuityBCP / DR · restore testSecure changesecurity & privacy reviewTELECOM REGULATORY — EECCNetwork & service securitymeasures per serviceResilience & continuitycontinuity plan · recordsLawful obligations on comms datanational-law processRegulatory reportingincident notification
The focus areas under each pillar, each labelled with the process it calls for. A programme that cannot name the process for a focus area has not started on it, whatever the design says.
03

How it works

17.1 gave the chain and 17.2 the boundaries. Here each focus area is reduced to the process to follow and what it produces. If nothing was produced, the process did not happen.

Privacy: GDPR and ePrivacy

Focus areaProcess to followWhat it produces
Personal data processingDPIA (Art. 35) before high-risk processing begins; RoPA entry (Art. 30) for every processing activitySigned-off DPIA; a current record of processing
Data flows and third partiesData-flow mapping; a data processing agreement (Art. 28) with every processor; a transfer assessment for data leaving the EEAData-flow map with an owner per copy; DPAs on file
Data protection in systemsData classification; masking or pseudonymisation in non-production; a retention and deletion schedule that reaches every copyDeletion proven in the lake, ticket history and vendor backups
Consent and communications dataLawful-basis assessment per purpose; consent management; ePrivacy rules for traffic and location dataConsent records; logged access to traffic and location data

Cybersecurity: NIS2

Focus areaProcess to followWhat it produces
RiskRisk assessment and threat modelling, repeated on every architecture changeRisk register; exceptions with an owner and an expiry
Identity and accessJoiner / mover / leaver; periodic access review; PAM for the management planeAccess review records; PAM session logs; no shared or unexpiring credentials
API and integration securityAPI security review at design time: authentication, authorisation, rate limits, mTLS; gateway policy as codeAn API register with a reviewed security profile per API
VulnerabilitiesVulnerability management with patch targets by severity; penetration testing of exposed channels and APIsScan coverage; pen-test findings with remediation dates
Incident responseIR plan and playbooks; tabletop drills; NIS2 notification: early warning within 24 hours, notification within 72 hours, final report within a monthDrill records; notifications filed within the deadlines
Supplier securitySupplier security assessment before onboarding; contractual terms; a register of privileged supplier accessSupplier access reviewed like any other privileged identity
Business continuityBCP / DR planning; restore tests actually performedA restore record, not a restore assumption
Secure changeSecurity and privacy review in architecture governance and change management (GDPR Art. 25)A review record per significant change

Telecom regulatory compliance: EECC

Focus areaProcess to followWhat it produces
Network and service securitySecurity measures documented per service, mapped onto the NIS2 control frameworkOne measure set that satisfies both regimes
Resilience and continuityContinuity planning and availability recording against the obligationsAvailability records; tested continuity plans
Lawful obligations on communications dataThe national-law process for lawful interception and retention, with access strictly controlled and auditedControlled, logged access the regulator can inspect
Regulatory reportingIncident notification to the regulator; periodic compliance reportingReports filed on time

Two processes that are often confused

A DPIA assesses privacy risk to the individual. The NIS2 risk assessment assesses risk to networks and services. They are two processes in two pillars, and completing one does not satisfy the other.

04

Who owns what

EntitySystem of RecordSystem of EngagementSystem of ReferenceNotes
Record of processing activities (RoPA) and DPIAsPrivacy management or GRC tool, owned by the DPO—Architecture, system ownersGoes stale whenever a new data flow is built without a review.
Consent records and marketing preferencesCRM consent store / consent management platformDigital channels, care agentsMarketing platforms, billingDownstream systems read consent; they should not hold their own version of it.
Risk register and control frameworkGRC tool—Security architecture, system ownersOne control set, with NIS2, EECC, GDPR and ePrivacy mapped onto it.
Access rights and access-review recordsIAM platform (identity governance)—PAM, each applicationIncludes supplier accounts, which are privileged identities like any other.
Security incident recordsSecurity incident or case management (often SIEM/SOAR or ITSM)—SIEM, regulator notification recordThe clock for NIS2 notification starts here, so timestamps matter.
Evidence for regulatorsGRC tool / evidence store—DPO, security operations, network operationsDrill records, restore tests, pen-test findings, filed notifications. The record set should exist before it is asked for.
05

In practice

The most common failure in this area is two parallel compliance programmes, typically privacy under the DPO and NIS2 under security, producing two versions of the same control and two evidence sets. NIS2 and the EECC both ask for network and service security; ePrivacy and GDPR both ask for protection of communications data. Overlap is the norm, not the exception.

The processes that slip first in a busy delivery programme are the ones that leave evidence only when done properly: restore tests, access reviews and deletion that reaches every copy. Deletion is the hardest in an old estate, because personal data has been copied into data lakes, ticket histories, test environments and vendor backups that were never on the data-flow map.

06

The trade-off

What it solves

Coverage. Each focus area has a named process and a named output, so a programme can see which conversations have not started and which have no evidence behind them.

What it does not solve

  • Doing the processes well; the index says a DPIA is needed, not how to write a good one.
  • National variation in lawful interception and retention law.
  • Legacy data copies that nobody has mapped yet.

What it adds

  • A common control framework needs an owner with authority across privacy, security and regulatory teams.
  • Mapping each regulation onto shared controls is ongoing work as regulations and the estate change.
  • Evidence has to be produced continuously, which means process change in operations, not just documents.

Architecture decision

Run privacy, cybersecurity and telecom compliance as separate programmes, or as one control framework with one evidence store?

  • One framework, one evidence store

    Choose when the same systems and data are in scope of several regulations, which for a BSS/OSS estate is almost always.

  • Separate programmes, mapped afterwards

    Choose when organisational ownership is split and cannot be merged yet, and there is a funded plan to map both onto one control set.

Breaks if the separate programmes are never mapped together. Each assumes the other covers the shared controls, and the regulator finds the gap.

07

Takeaways

Key Takeaways

  • Three pillars, a fixed list of focus areas under each, and for every focus area a named process.
  • Every process leaves something behind. If nothing was produced, the process did not happen.
  • A DPIA and a NIS2 risk assessment are different processes; one does not satisfy the other.
  • One control framework, one evidence store, every regulation mapped onto it.

Check yourself

  • A programme launches location-based analytics on customer data. Which processes must run before it goes live?Show answer

    A DPIA, because it is high-risk processing of personal data; a RoPA entry; a lawful-basis assessment and ePrivacy handling for location data; and a security and privacy review through architecture governance. The data-flow map should gain the new copies.

  • The security team says the DPIA for a new CIAM covers the NIS2 risk assessment. Is that right?Show answer

    No. The DPIA assesses privacy risk to individuals; the NIS2 risk assessment assesses risk to networks and services. Both are needed, and both should map onto the same control framework.