What data security measures does the new FADP require?

By Advisorn · updated on 25 October 2026 · Art. 8 and 61 let. c FADP, Art. 1-6 Data Protection Ordinance, Art. 32 GDPR

In short

The FADP requires technical and organisational measures that ensure security appropriate to the risk (Art. 8 FADP). The ordinance specifies the objectives: data must be accessible only to authorised persons, available when needed, not modified without authorisation and processed in a traceable way (Art. 1-3 Data Protection Ordinance). Whoever wilfully fails to meet these minimum requirements risks a fine (Art. 61 let. c FADP).

Typical measures for an SME

  • personal log-ins, rights limited to what each person needs and two-factor authentication;
  • regular updates, antivirus and firewall;
  • regular backups, kept separately and tested;
  • encryption of laptops, phones and external media;
  • written rules for employees and training on phishing and the use of data;
  • contracts with, and checks on, the vendors that process data for you;
  • a procedure for breaches of data security.

When more is needed

Whoever processes sensitive personal data on a large scale or carries out high-risk profiling by automated means must keep processing regulations (Art. 5-6 Data Protection Ordinance) and, if preventive measures are not enough, log the operations on the data (Art. 4 Data Protection Ordinance).

The measures must be reviewed over the whole duration of the processing and adjusted where needed (Art. 1 para. 5 Data Protection Ordinance).

Related questions

Useful templates

General information, not advice on your case: for your case the text of the law prevails. For a question about your case there is Advisorn's consulting.