--- title: "Meet NIS2, DORA & GDPR Compliance | Firevault" url: https://fire-vault.com/compliance/uk-gdpr-physical-disconnection description: "Navigate complex data regulations with our dedicated compliance hub. We detail how offline storage helps meet NIS2, DORA, and GDPR obligations. Explore." lang: en-GB --- Whitepaper, UK GDPR, Article 32 # Physical Disconnection And UK GDPR Technical whitepaper: why physical disconnection at Layer 1 is a stronger technical measure under UK GDPR Article 32 than logical isolation, and how to evidence it to the ICO, insurers and your board. - Offline by default - Identity locked access - Hardware encrypted Framework matrix: https://fire-vault.com/compliance/frameworks Image: Security analyst reviewing an isolated workstation with disconnected cables (https://fire-vault.com/assets/hero-square-analyst-DI5B7V_E.jpg) Art. 32 UK GDPR security of processing, including timely restore £17.5m Maximum UK GDPR fine, or 4% of global turnover if higher Layer 1 Where Offline Secure Storage® disconnects, below the network 01 The requirement ## Article 32 Asks For Measures Appropriate To The Risk UK GDPR Article 32 requires appropriate technical and organisational measures, including the ability to ensure ongoing confidentiality, integrity and availability, and the ability to restore availability and access to personal data in a timely manner after an incident. Article 5(1)(f) adds the integrity and confidentiality principle. The ICO expects controllers to consider the state of the art. Logical isolation reduces exposure, but a copy that remains addressable on a network remains within reach of a compromised credential. This paper is a technical argument, not legal advice. This is a mapping, not a certification claim. Firevault holds Cyber Essentials Plus. Everything else on this page is stated as alignment: Offline Secure Storage® produces evidence you can point at in your own submission, assessment or audit. - Art. 32 — UK GDPR security of processing, including timely restore. Source: ICO, A guide to data security (https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/security/a-guide-to-data-security/) - £17.5m — Maximum UK GDPR fine, or 4% of global turnover if higher. Source: ICO (https://ico.org.uk/for-organisations/law-enforcement/guide-to-le-processing/penalties/) 02 What is tested ## Physical Versus Logical, The Technical Argument Each line below is something an assessor, regulator or underwriter can ask you to evidence. Logical isolation (VLANs, firewalls, object lock) is enforced by software that can be misconfigured or bypassed An immutable bucket is still reachable over an API with valid credentials Physical disconnection removes the network path entirely while offline Availability after an incident depends on a copy the attacker could not reach Confidentiality improves when exfiltration has no route to the data Evidence of the disconnected state is simpler to prove than a policy configuration 03 Consequences ## Where Logical Isolation Leaves Residual Risk What happens when the control is missing, and the record cannot be produced. ### Always Addressable Anything with an IP address can be scanned, targeted and eventually reached. ### Credential Compromise Stolen administrator or cloud console credentials can change retention, delete or exfiltrate. ### Configuration Drift Firewall rules and bucket policies change over time, often without the data owner knowing. ### Exfiltration Path A logically isolated copy can still be copied out, creating a reportable personal data breach. 04 The architecture ## Physical Disconnection As A Technical Measure Offline Secure Storage® holds personal data on dedicated hardware in the customer's chosen jurisdiction, physically disconnected between identity-verified windows. ### Integrity And Confidentiality With no network interface while offline, there is no remote path to alter, encrypt or exfiltrate the copy. ### Timely Restore (Art. 32(1)(c)) Scheduled restore windows return a clean copy after ransomware, supporting availability duties. ### Hardware Encryption At Rest Data is encrypted on dedicated hardware, with identity factors held by the customer. ### Jurisdiction Chosen By You Bunkers across Europe including the UK, so international transfer questions are answered by design. ### Regular Testing (Art. 32(1)(d)) Recurring verification windows test and evaluate the effectiveness of the measure. ### Accountability Evidence Every connection, identity check and restore is logged to support Article 5(2) accountability. “A policy can be changed by whoever holds the keys. A cable that is not connected cannot. That is why physical disconnection is the stronger measure.” Mark Fermor, CTO, CMO & Founder, Firevault 05 What sits offline ## Personal Data Best Held Offline The records most often moved into Offline Secure Storage® for this framework. HR and payroll records Client and patient records Legal case files Customer databases CCTV and identity documents Backups of production systems ### Alongside, not instead of Physical disconnection complements encryption, access control and immutable backups. It provides the copy of last resort. ### Aligned with NCSC The NCSC advises keeping at least one backup offline. Physical disconnection turns that advice into a provable state. ### Easier breach assessment If the offline copy had no network path during an incident, it is simpler to show it was not affected. ### Not legal advice Controllers remain responsible for their own risk assessment. Firevault supplies the architecture and the evidence. UK GDPR and Offline Secure Storage: https://fire-vault.com/compliance/gdpr Layer 1 vs logical air gap: https://fire-vault.com/learn/physical-vs-logical-air-gap NCSC ransomware-resistant backups: https://fire-vault.com/compliance/ncsc-ransomware-resistant-backups All compliance frameworks: https://fire-vault.com/compliance Image: Mark Fermor (https://fire-vault.com/assets/mark-fermor-aWtKNSv7.jpg) Image: David Bailey (https://fire-vault.com/assets/david-bailey-Dgqj8eaE.jpg) Image: Kenny Phipps (https://fire-vault.com/assets/kenny-phipps-Dy-CtCjw.jpg) Online Now Get started ## Tell us which framework you are being tested against. We will map Offline Secure Storage® to the outcomes your assessor is checking, and give you the wording and evidence to submit. From £360 a month including VAT. 36-month commitment. First payment at checkout. 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