At the end of the day, I am the one person who has to answer that question/is responsible for being GDPR compliant. I've spent hours doing research, figuring out what we need to do and implementing it -- and it's a hollow victory because even though I've said yes and have 100s of articles/white papers/opinions that back up the decisions I've made, the real answer is still "I don't know".
And I absolutely know I'm not alone in this. I got GDPR compliance dropped on my lap because I did security compliance -- if you contrast NIST 800-53/800-171 against GDPR you'll see why people are pissed off. One has clear guidelines with enough room for evolving best practices written by obviously competent/experienced professionals, the other is written as basically "we'll know it when we see it".
Sounds like a win for the GDPR to me, we know rigid checkbox-ticking is ineffective.
Apart from that, NIST 800-53/800-171 are catalogs of "security controls and associated assessment procedures" for "Federal Information Systems and Organizations". GDPR is a data protection regulation in the context of the EU legal system. Apples to oranges.
Laws and regulations tend to stick around for longer than expected, and they're static. Technology and "cyber criminals" are dynamic. For better or worse, the GDPR acknowledges this. I think that's a testament to the Article 29 Working Party, in a world where most politicians are clueless about technology.
You're absolutely right! GDPR is wonderful for users as a ringing and clear statement of human rights.
Unfortunately, it also needs to be for companies because it affects companies just as much as users. I would go so far as to say GDPR rests almost entirely on companies to turn this stirring declaration of human rights into rights said humans can actually make use of. In this regard, it's a collection of opportunities for improvement of awe-inspiring proportions.
You're right. Technologies and threat landscapes change. Regulation needs to acknowledge this or be worse than useless. Yet, perhaps there are ways to deal with this that don't rest largely on handwaving away critical questions of what compliance actually might look like with weasel-words like "reasonable".
Does that seem possible?