6 Best Practices for GDPR Logging and Monitoring

The General Data Protection Regulation (GDPR) enforces strict security, transparency, and accountability standards for businesses handling EU citizens’ personal data.  While many focus on data collection and cybersecurity, GDPR logging and monitoring are crucial for compliance. Logging maintains records of data access and security events, while monitoring enables real-time detection of unauthorised access and potential breaches.

This guide outlines six essential best practices to help organisations achieve compliance while maintaining efficient log management.

GDPR requires businesses to track, store, and review records of personal data processing activities. This ensures compliance, strengthens security, and provides an audit trail that can be presented to a supervisory authority if needed.

GDPR logging – recording data activities for compliance

Logging refers to the systematic recording of events related to data access and processing. Proper log data management helps businesses maintain compliance by tracking:

• Who accessed personal data: The identifier of the user, such as user ID or IP address
• When and why data was accessed: Timestamped logs with justifications
• Types of data collected and processed: Includes phone numbers, email addresses, or any personally identifiable information (PII)

For example, if a data subject requests their personal information under Article 15 of GDPR, an organisation must present server logs showing when and how the data was accessed. Similarly, if unauthorised access occurs, logs help investigate security incidents and prevent further breaches.

GDPR monitoring – real-time data protection

While logging provides a historical record, monitoring enables real-time tracking of personal data activities. Organisations use monitoring tools to:

• Detect unauthorised access attempts before they lead to breaches
• Ensure compliance with legal obligations by tracking policy violations
• Strengthen information security by identifying unusual activity

For instance, if an employee suddenly downloads a large dataset from a web server, monitoring tools can trigger notifications and flag the action as a potential data privacy violation.

Without proper logging and monitoring, businesses risk failing GDPR audits, facing regulatory fines, and exposing sensitive user data.

GDPR mandates that businesses log and monitor personal data activities following specific standards. Here are three critical logging categories organisations need to implement.

Data access logs: tracking who, when, and why

Data access logs ensure that only authorised individuals handle personal information. These logs should include:

• User identifier: Name, employee ID, or IP address of the person accessing data
• Purpose of access: Justification for retrieving the data
• Timestamps: Log entries recording when access occurred

For example, if an IT administrator accesses sensitive customer payment details, the log should document their role, reason for access, and the time of access.

System event logs: securing IT infrastructure

System event logs track security-related activities and IT system modifications. These logs record:

• Authentication attempts: Successful and failed login attempts
• Unauthorised access alerts: Repeated failed logins or security threats
• Configuration changes: API updates, firewall modifications, and system patches

If a hacker attempts to bypass login security using brute-force attacks, system event logs help detect the activity and prevent unauthorised data access.

User activity logs: tracking data modifications

User activity logs capture how employees and external users interact with personal data. These logs help organisations:

• Monitor data modifications and erasures: Track updates and deletions
• Identify policy violations: Detect unauthorised data transfers
• Ensure compliance: Verify adherence to GDPR guidelines

For example, if a customer requests the erasure of their personal data under Article 17 (Right to Be Forgotten), logs should confirm when and how the request was processed.

• Ensure GDPR compliance effortlessly
• Track and manage consent logs automatically
• Strengthen data privacy with real-time consent trends

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To meet GDPR compliance standards and enhance security, businesses should follow these six best practices.

Retain logs only as long as necessary

GDPR enforces data minimisation and data retention policy, meaning businesses must collect and store logs only for the necessary period. Keeping logs indefinitely increases security risks and compliance violations.

Best practices include:

• Defining a log retention policy based on legal obligations and business needs
• Automating log expiration and secure deletion of outdated data
• Ensuring logs are encrypted before being erased to prevent unauthorised access

For example, healthcare organisations handling HIPAA-compliant medical records may need to retain logs for a legally defined period before secure deletion.

Encrypt logs to protect personal data

Since logs contain sensitive information, encryption helps protect log data from cyber threats.

To enhance security:

• Use AES-256 encryption for stored logs
• Apply TLS encryption for log transmissions
• Restrict log access to authorised personnel using multi-factor authentication (MFA)

Without encryption, an attacker could extract phone numbers, user IDs, or other identifiers from log files, violating data privacy and security standards.

Limit access to logs containing personal data

Restricting log access prevents unauthorised modifications and insider threats.

Best practices include:

• Implementing role-based access control (RBAC) to restrict log visibility
• Logging access requests to track data retrieval
• Regularly reviewing permissions to prevent unauthorised access

For example, while a data protection officer may need access to compliance logs, a marketing team should not have visibility into the processing of personal data stored in logs.

Maintain an audit trail for compliance

Audit trails provide proof of compliance and help businesses pass regulatory audits.

A proper audit log should include:

• Who modified or deleted data
• When the modification occurred
• Why the change was made

For example, if a customer requests data deletion, logs should confirm the exact time, processing activities involved, and any notifications sent to relevant data controllers.

Automate monitoring and anomaly detection

Manual log monitoring is inefficient. Automated tools improve compliance by detecting suspicious activity instantly.

Best practices include:

• Using automated monitoring to flag security threats
• Aggregating logs into a centralised system for efficient analysis
• Configuring real-time alerts for unauthorised access attempts

If an employee suddenly transfers thousands of user records, monitoring systems can flag the activity as potential data exfiltration.

Ensure data subject rights can be exercised

GDPR grants individuals control over their personal data with GDPR rights. Logging systems must support user requests such as data access, data correction, and data deletion.

For example, if a user wants to review their data processing history, logs should provide a detailed record of all interactions involving their personal data.

GDPR-compliant logging and monitoring are essential for data security, regulatory compliance, and user trust. By implementing secure log management practices, businesses can:

• Reduce regulatory risks
• Strengthen data privacy and cybersecurity
• Improve access control and compliance monitoring

Organisations that prioritise log data security and compliance can avoid penalties while ensuring robust data protection in their operations.