Under the General Data Protection Regulation (GDPR), "I didn't know" is not a defense. If your organization suffers a data breach from a credential stuffing attack, you are not just a victim—you are non-compliant.
Up to 4% of your total global annual revenue.
Recent enforcement actions by Data Protection Authorities (DPAs) have made one thing clear: failing to protect against known, foreseeable attack vectors like credential stuffing is a direct violation of your duty to secure personal data.
GDPR Article 32, "Security of processing," is the core of your technical obligation. It legally requires you to implement "appropriate technical and organisational measures" to ensure data security, specifically "taking into account the state of the art."
Like P@ssword1! — these are outdated and insufficient to meet modern security standards.
This is the modern, "state of the art" approach that regulators are demanding.
Leading EU data protection authorities, including the UK's Information Commissioner's Office (ICO), explicitly recommend that "state of the art" password systems must:
"Screen passwords against a password 'deny list' of the most commonly used passwords, leaked passwords from website breaches, and common words or phrases..."
This is not a suggestion; it is their definition of the minimum technical safeguard required to protect personal data.
If you are not checking passwords against a database of known-leaked credentials, you are failing to meet the "state of the art" and are in breach of Article 32.
You are expected to know your risks. The joint investigation into the 23andMe breach by EU and UK authorities was a landmark event.
Regulators explicitly stated that the company:
"...should have specifically identified credential stuffing as a high risk..." and that "...multiple standards and guidelines... identified credential-based attacks, including credential stuffing, as a highly likely attack method."
— Joint EU/UK Data Protection Authority Investigation
Credential stuffing is a known, foreseeable, and high-impact risk
You have a legal duty to defend against it
Failure to do so is non-compliance with Article 32
Our Leaked Credential Monitoring platform is the exact technical measure regulators are demanding. We provide the "state of the art" defense you need to demonstrate compliance.
Proactive Check
Our API integrates directly with your user sign-up and password reset forms. We instantly check any new password against our database of billions of known-leaked credentials.
This allows you to block compromised passwords before they can ever be set in your system, satisfying the core "state of the art" requirement.
Continuous Monitoring
A password that is secure today may be leaked tomorrow. Our platform monitors multiple intelligence sources 24/7—underground forums, threat actor networks, the deep and dark web, and HUMINT operatives.
The moment an active password for one of your users or employees appears in a new breach, we alert you. This moves you from a passive to a proactive defense.
The 72-Hour Clock
A single unauthorized login to an account containing personal data is a "personal data breach." This triggers the 72-hour notification clock under Article 33, requiring you to report to your DPA.
By detecting the leaked credential first, you can force a password reset and neutralize the threat before an attacker logs in. You prevent the breach, stop the 72-hour clock, and avoid the fines and reputational damage that follow.
Of total global annual revenue or €20 million, whichever is higher.
To notify your DPA of a personal data breach from discovery.
DPAs are actively enforcing Article 32 technical measures.
Failing to defend against credential stuffing is no longer an option. It is a documented failure to implement "appropriate technical and organisational measures."
Our service provides the critical, "state of the art" defense you need to protect your users' data, satisfy auditors, and fulfill your fundamental obligations under GDPR.
Comprehensive deny list
Instant password validation
Proactive breach prevention
Meet GDPR requirements, satisfy DPA expectations, and protect your users with comprehensive leaked credential monitoring. Demonstrate your commitment to data protection.
Article 32 - Security of Processing: GDPR Article 32 requires controllers and processors to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, taking into account "the state of the art, the costs of implementation and the nature, scope, context and purposes of processing."
What "State of the Art" Means: This is a dynamic standard that evolves with technology and the threat landscape. In 2025, credential stuffing is a well-documented, prevalent threat. Regulators expect organizations to defend against known attack vectors using available technology—including password deny lists and breach monitoring.
ICO Guidance: The UK Information Commissioner's Office (which enforces GDPR in the UK) explicitly recommends screening passwords against deny lists of commonly used and leaked passwords. This is considered best practice and part of "state of the art" security.
Article 33 - Breach Notification: If a personal data breach occurs, you must notify your supervisory authority (DPA) within 72 hours of becoming aware of it. Unauthorized access via a stolen credential constitutes a breach, triggering this obligation and potential fines if not properly managed.
Enforcement Precedents: The 23andMe case demonstrated that regulators will investigate whether organizations adequately identified and mitigated foreseeable risks like credential stuffing. Failure to do so is considered non-compliance with Article 32.