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Article 20
Governance
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Management bodies must approve, oversee, and be accountable for cybersecurity risk-management measures. |
Applies encryption and tokenization at the data layer before data enters cloud or SaaS systems, providing measurable and controlled risk reduction rather than policy-only controls. |
Executive accountability supported by enforceable technical controls. |
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Article 21(1)
Cybersecurity risk-management measures
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Organizations must implement appropriate and proportionate technical measures to manage cyber risk. |
Protects sensitive data before it is transmitted to SaaS, cloud, or third-party platforms. Can either tokenize (keeping regulated data within sovereign boundaries) or end-to-end encrypt. |
Reduced systemic risk across platforms and integrations. |
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Article 21(2)(a)
Policies on risk analysis and information system security
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Establish and apply risk-based policies and technical measures to secure information systems and the data they process. |
Enforces encryption and tokenization of sensitive data across information systems, APIs, and cloud workflows, aligned with data classification and risk policies. |
Information system security controls are applied consistently based on risk, not left to downstream platforms or manual processes. |
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Article 21(2)(b)
Incident handling
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Limit the impact of cybersecurity incidents. |
Ensures exposed data is unreadable if a SaaS platform or supplier is breached. |
Significantly reduced breach severity and exposure. |
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Article 21(2)(c)
Business continuity and crisis management
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Maintain operations during and after cyber incidents. |
Applications continue operating using encrypted or tokenized values. |
Business continuity is maintained during incidents. |
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Article 21(2)(d)
Supply chain security
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Address cybersecurity risks introduced by suppliers and service providers. |
Prevents third parties from accessing plaintext sensitive data by securing it before it leaves your boundary. |
Maintains control over access to sensitive data. |
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Article 21(2)(e)
Security in acquisition, development and maintenance
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Build security into systems and integrations by design. |
Secures sensitive data inside API payloads ensuring integrations and automation do not introduce data exposure. |
Secure-by-design integrations without slowing digital transformation. |
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Article 21(2)(f)
Assessing effectiveness of measures
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Demonstrate that cybersecurity measures are effective. |
Consistent enforcement of encryption and tokenization across defined data flows, with auditable policy application. |
Controls are verifiable and auditable. |
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Articles 23–30
Incident reporting and supervision
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Report incidents and manage regulatory impact. |
By limiting data exposure at source, StratoKey reduces incident scope. In addition, the platform provides monitoring and audit features that support incident assessment. |
Lower regulatory exposure and faster, clearer incident classification. |