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> GDPR nowhere says "student data should be encrypted at rest". It says it should be protected from unauthorized access,

The reality is that you can't protect unencrypted data from unauthorized access. You can try, but you can't guarantee it, not when you have hosting partners, for example. Encryption is just one completely reasonable defense mechanism that needs to be part of a larger strategy. I wasn't comfortable defending the company without personally identifiable data being encrypted. You might be. I'm not.

> this business owner basically failed at his primary mission: managing risk.

To the contrary, I succeeded. I eliminated the risk at the cost of 5% of my revenue. I sleep great at night not worrying about the GDPR.



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