Proportionate Response

Action taken by an organization or regulator that is appropriate and suitable in scope and severity relative to the circumstances, particularly in the context of data breaches, compliance violations, or security incidents. A proportionate response considers the severity of the incident, potential harm to individuals, the organization's cooperation and remediation efforts, whether violations were intentional or negligent, and the organization's history of compliance. For data breaches, proportionate responses might range from enhanced monitoring and notification for low-risk incidents to extensive remediation, regulatory investigation, and significant penalties for serious breaches affecting many people. Regulators are generally required to apply proportionate enforcement measures—GDPR empowers authorities to issue warnings, reprimands, orders to bring processing into compliance, temporary or permanent processing limitations, or administrative fines, with the choice depending on proportionality considerations (Article 58). Organizations should likewise apply proportionate internal responses to privacy incidents, balancing thoroughness with practical resource constraints.