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NIS2 and GDPR compliance

VaultPAM is designed as compliance infrastructure for EU organisations subject to NIS2 and GDPR. This article maps VaultPAM capabilities to the specific requirements that apply to privileged access management.

NIS2 Article 21

NIS2 Directive Article 21 requires organisations to implement appropriate and proportionate technical and operational measures to manage risks. The table below maps the specific measures to VaultPAM capabilities.

NIS2 Article 21 requirementVaultPAM capabilityWhere to configure
Multi-factor authentication for all privileged accessMFA enforcement policy; supports TOTP and hardware keysOrganisation settings > Security > MFA enforcement
Logging and monitoring of privileged sessionsFull session recording with audit trail; every action is loggedAdmin > Audit log
Access control and least privilegeSafe-level access policies; Just-in-Time (JIT) grants; approval workflowsPolicy engine > Creating policies
Incident response and audit trailTamper-evident audit log with CSV export; session recordings as forensic evidenceAdmin > Audit log > Export CSV
Supply chain securityConnector isolation; each connector has a scoped token; compromised connectors can be revokedAdmin > Connector management

GDPR privileged access obligations

GDPR imposes obligations on the controllers and processors of personal data. Privileged access to systems holding personal data must be controlled and evidenced.

Article 32 -- Technical and organisational measures

VaultPAM satisfies Art. 32 by providing encryption of credentials at rest (via OpenBao secrets engine), encrypted session recordings, MFA enforcement, and a complete audit trail of all privileged access events.

Article 5(1)(f) -- Integrity and confidentiality

The integrity and confidentiality principle (Art. 5(1)(f)) requires that personal data is processed in a manner that ensures appropriate security. VaultPAM enforces this at the infrastructure level: credentials are never exposed in plaintext in the UI after checkout, sessions are recorded and auditable, and access policies prevent unauthorised users from reaching protected resources.

Article 30 -- Records of processing activities

VaultPAM's audit log provides a continuous record of who accessed which system, when, and for how long. This log can be exported as CSV and used as evidence in your Art. 30 records of processing activities (ROPA). The audit log is tamper-evident and retained for a configurable period (default: 90 days).

Data residency

For SaaS deployments, all tenant data is stored exclusively in GCP europe-central2 (Warsaw, Poland). Data does not leave the EU. This satisfies the data residency requirements of GDPR and NIS2 for EU-based organisations.

To receive written confirmation (for example, for a Data Transfer Impact Assessment), request a Data Processing Agreement (DPA) from support@vaultpam.com. The DPA specifies the processing region and sub-processors.