GDPR, HIPAA, PCI-DSS: Cybersecurity Compliance Frameworks Explained
GDPR, HIPAA, PCI-DSS, ISO 27001, and SOC 2 are the major cybersecurity compliance frameworks. Learn what each one requires, who it applies to, the penalties for non-compliance, and how to approach certification.
cybersecurity-the-internets-core-protocol)-the-backbone-of-reliable-internet-communication) compliance frameworks are sets of rules, standards, and controls that organisations must follow to protect data, privacy, and systems. Some are government regulations with legal penalties; others are voluntary standards that demonstrate security maturity.
Understanding which frameworks apply to your organisation — and what they require — is fundamental to enterprise cybersecurity-the-internets-core-protocol)-the-backbone-of-reliable-internet-communication).
GDPR — General Data Protection Regulation
Who it applies to: Any organisation that processes personal data of individuals in the EU/EEA — regardless of where the organisation is based. A US company with EU customers is subject to GDPR.
What it protects: Personal data (any information relating to an identifiable natural person).
Key Requirements
Lawful basis for processing: Data must be collected with a valid legal basis — consent, contract, legal obligation, vital interests, public task, or legitimate interests.
Individual rights:
- Right of access — individuals can request a copy of their data
- Right to erasure ("right to be forgotten") — individuals can request deletion of their data
- Right to portability — individuals can receive their data in a machine-readable format
- Right to object — individuals can object to processing for direct marketing
Data minimisation: Collect only the data you need; retain it only as long as necessary.
Privacy by design: Security controls must be built into systems from the start, not added later.
Data breach notification: Report breaches to the supervisory authority within 72 hours; notify affected individuals "without undue delay" if there is high risk.
Data Protection Officer (DPO): Required for public authorities and organisations that process data at scale.
Penalties
Up to €20 million or 4% of global annual turnover (whichever is higher) for serious violations. Lower tier: up to €10M or 2% for less severe breaches.
Key Roles
- Data Controller: Determines the purpose and means of processing (e.g. the business collecting data)
- Data Processor: Processes data on behalf of the controller (e.g. a cloud provider, SaaS tool)
HIPAA — Health Insurance Portability and Accountability Act
Who it applies to: US healthcare organisations — covered entities (hospitals, clinics, insurers) and their business associates (cloud providers, billing services, IT vendors handling health data).
What it protects: Protected Health Information (PHI) — any information about health status, treatment, or payment linked to an individual.
Key Rules
Privacy Rule: Defines when PHI can be used or disclosed. Patients have rights to access and correct their records.
Security Rule: Requires administrative, physical, and technical safeguards for electronic PHI (ePHI):
- Administrative: Risk assessments, workforce training, incident response-security-operations-centre-SIEM-incident-response-explained) plans
- Physical: Facility access controls, workstation security, device disposal
- Technical: Access controls, audit logs, encryption, automatic logoff
Breach Notification Rule: Notify affected individuals within 60 days of a breach; report large breaches (500+ individuals) to HHS and media.
Minimum Necessary Standard: Only use or disclose the minimum amount of PHI needed for the purpose.
Penalties
Tiered civil penalties from $100 to $50,000 per violation, up to $1.9 million per category per year. Criminal penalties: up to 10 years in prison for wilful violations with intent to sell data.
PCI-DSS — Payment Card Industry Data Security Standard
Who it applies to: Any organisation that stores, processes, or transmits cardholder data (credit/debit card numbers, CVVs, expiry dates). Set by the major card brands (Visa, Mastercard, Amex).
What it protects: Cardholder data and the systems that handle it.
The 12 PCI-DSS Requirements
| # | Requirement | |---|---| | 1 | Install and maintain [Network Security)](/learning-center/what-is-a-firewall-and-how-does-it-protect-your-network) controls (firewalls) | | 2 | Apply secure configurations to all system components | | 3 | Protect stored account data (encryption, tokenisation) | | 4 | Protect cardholder data in transit with strong cryptography-symmetric-vs-asymmetric) | | 5 | Protect all systems from malware | | 6 | Develop and maintain secure systems and applications | | 7 | Restrict access to system components by business need | | 8 | Identify users and authenticate access | | 9 | Restrict physical access to cardholder data | | 10 | Log and monitor all access to system components | | 11 | Test security of systems and networks regularly | | 12 | Support information security with organisational policies |
Compliance Levels
- Level 1: 6M+ transactions/year — annual on-site audit by a Qualified Security Assessor (QSA)
- Levels 2–4: Quarterly vulnerability scans, annual Self-Assessment Questionnaire (SAQ)
Non-compliance can result in fines from card brands ($5,000–$100,000/month), increased transaction fees, or loss of the ability to accept card payments.
ISO 27001 — International Standard for Information Security
Who it applies to: Any organisation, any sector, any size. Voluntary international standard.
What it is: A framework for establishing, implementing, maintaining, and continually improving an Information Security Management System (ISMS) — a systematic approach to managing sensitive information.
Key Elements
Context of the organisation: Define internal and external issues, interested parties, and the ISMS scope.
Risk assessment and treatment: Identify information security risks, assess their likelihood and impact, and select appropriate controls.
Annex A controls: 93 controls across 4 themes:
- Organisational controls (policies, roles, supplier relationships)
- People controls (screening, training, disciplinary process)
- Physical controls (secure areas, equipment)
- Technological controls (access control, encryption, monitoring, incident management)
Continual improvement: Regular internal audits, management reviews, and corrective actions.
Certification: A UKAS-accredited certification body audits the ISMS and issues a certificate-certificates-and-PKI-explained) valid for 3 years (with annual surveillance audits).
SOC 2 — Service Organisation Control 2
Who it applies to: SaaS companies, cloud providers, and data centres that store or process customer data. Common requirement from enterprise customers during vendor due diligence.
What it is: An audit framework created by the American Institute of CPAs (AICPA). A CPA firm audits the organisation's controls against the Trust Services Criteria:
- Security (required): Protection against unauthorised access
- Availability (optional): Systems are available as committed
- Processing Integrity (optional): Processing is complete, accurate, and authorised
- Confidentiality (optional): Designated confidential information is protected
- Privacy (optional): Personal information is collected, used, and retained appropriately
Type I: Point-in-time audit — confirms controls are designed correctly Type II: Period audit (6–12 months) — confirms controls operated effectively over time. Enterprise customers strongly prefer Type II.
Frameworks Comparison
| Framework | Type | Applies to | Enforcement | |---|---|---|---| | GDPR | Regulation | EU personal data | Government fines up to 4% revenue | | HIPAA | Regulation | US health data | HHS enforcement, criminal penalties | | PCI-DSS | Industry standard | Card payments globally | Card brand fines, payment suspension | | ISO 27001 | Standard | Any organisation | Voluntary; market/contract pressure | | SOC 2 | Audit framework | US cloud/SaaS | Voluntary; enterprise customer pressure |
The NIST Cybersecurity Framework (NIST CSF)
The NIST CSF is a US voluntary framework widely used alongside regulatory compliance. It organises security activities into five functions:
Identify → Protect → Detect → Respond → Recover
Many organisations align GDPR, HIPAA, or ISO 27001 controls to the NIST CSF to get a unified view of their security posture.
Key Takeaways
- GDPR protects EU citizens' personal data globally; fines reach 4% of global revenue
- HIPAA mandates administrative, physical, and technical safeguards for US healthcare data
- PCI-DSS protects payment card data; non-compliance can mean losing the ability to accept cards
- ISO 27001 is the international standard for an ISMS; certification demonstrates security maturity to customers
- SOC 2 Type II is the vendor security report most enterprise customers request
- Most frameworks overlap significantly — implementing one well accelerates compliance with others