Managing the Challenges of the Cloud Under EU General Data Protection Regulation2 Introduction European Union data protection law requires organisations to take adequate measures to ensure the security of personal data. This obligation must be met regardless of the means used to process the personal data. The security obligation covers not only enterprise information systems, but also cloud services used to process the personal data. Data breach notification obligations, steep fines of 20 million euro or 4% of global turnover, whichever is higher, and increased public scrutiny of how organisations use and protect personal data require that they pay close attention to the security of personal data. One of the central principles of the Eur

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