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SecureToken Digital Twin

One tokenized twin. Four regulations answered.

A one-way, format-preserving twin of production for dev, test, UAT and CI. Every system, every table, every join intact. GDPR, DORA, NIS2 and BCBS 239 evidence generated on every refresh.

The non-production estate is where all four regulations meet.

Dev, test, UAT and CI copies of production carry real customer records into wide teams, tools and vendors. GDPR, DORA, NIS2 and BCBS 239 each ask about that same estate in a different vocabulary. One tokenized twin answers all four at once and produces the evidence on every refresh.

Regulation mapping

Four regulations, one twin

Each regulation asks its own question of the test estate. The twin gives one answer to all of them.

Regulation
Obligation it meets
How the twin answers it
GDPR
Obligation it meetsArt. 25 data protection by design, Art. 32 pseudonymisation, Art. 5 minimisation
How the twin answers itReal personal data stays in production. Keys stay in a separate domain, which matches the Art. 4(5) definition of pseudonymisation. Destroyed-key mode produces anonymised output.
DORA
Obligation it meetsRTS 2024/1774 Art. 16 on non-production data, Art. 24 resilience testing
How the twin answers itCoverage, transform and key attestation per field. Realistic data for TLPT and scenario testing.
NIS2
Obligation it meetsArt. 21(2): secure development and maintenance, cryptography, access control, supply chain
How the twin answers itOffshore and vendor test teams only ever receive tokens. Key separation is attested.
BCBS 239
Obligation it meetsPrinciples 3, 4 and 6: accuracy, completeness, adaptability of risk data
How the twin answers itReferential integrity and distributions carry over, so changes to risk aggregation and reporting pipelines are validated at production scale before release.

The table describes each regulation and how the twin answers it. Bluemetrix makes no compliance guarantee on a customer's behalf.

Business challenges

Where compliant test data breaks down

Six problems appear in almost every test estate, in roughly the same order.

Four regulations, one test estate

Each regulator asks about the same copy of production in a different vocabulary.

Masking scripts drift

Each schema change opens a gap that nobody sees until audit.

Joins break across systems

The same customer becomes three different people in CRM, core banking and the warehouse.

Free text and streams escape

Notes, attachments, Kafka topics and logs sit outside the masking scope.

Masked data fails validation

Broken IBANs and check digits push teams to copy real data back.

The evidence gap

Job logs prove rules ran. Supervisors ask what was found and what happened to it.

Also for AI agent testing

Test AI agents on production-shaped data.

Agents, prompts and evaluation suites run against the twin, so teams exercise real data shapes before any agent touches production. Tokens stay consistent across tools, retrieval stores and logs.

Realistic prompts

Names, accounts and free text keep the shape agents meet in production.

Consistent tokens

One customer keeps one token across every tool an agent calls.

Tokens only

Evaluation runs and logs hold tokens, and real values stay in production.

Mitigate risk with Bluemetrix data compliance solutions

Adopt a comprehensive approach with the SecureToken Digital Twin.

Test data that behaves like production

Tokens keep the length, type and structure each field expects. IBANs keep valid check digits, dates stay dates, and phone numbers keep their format.

Validation rules, parsers and reports run as they do in production, so teams stop copying real data back into test.

Format kept

IBANIE46 PTSB 9906 0123 4567 89
Date of birth27/09/1978
Phone+353 85 904 2218
Emailkelvo.drasmen@example.ie

How do Bluemetrix data compliance solutions work?

Four steps turn production data into a compliant twin, and the record of each step arrives with every refresh.

01 · DISCOVER

Find every regulated field

Discovery scans the estate before anything changes and returns a coverage map.

  • Scan tables, documents, free text and streams.
  • Classify names, IDs, card numbers and account data.
  • Produce a coverage map for every system in scope.

Discovery scan

customers.namePerson
accounts.ibanIBAN
case_notes.bodyFree text
kafka: payments-eventsAccount ID

Coverage map ready

02 · TOKENIZE

Turn each value into a format-preserving token

Tokenization is one-way, and the keys stay in a separate domain.

  • The same input produces the same token in every system.
  • IBANs, dates and phone numbers keep format and check digits.
  • Free text is tokenized in place.

Production to twin

Tommy BrennanKelvo Drasmen
14/03/198127/09/1978
IE29 AIBK … 78IE46 PTSB … 89

One-way. Keys held in a separate domain.

03 · PROVISION

Deliver the twin to dev, test, UAT and CI

Every table and join arrives intact, on a schedule or on demand.

  • Refresh environments from the same twin.
  • Keep referential integrity and distributions.
  • Use the TDM tool or pipeline that moves data today.

Twin refreshed

Dev
Test
UAT
CI

04 · EVIDENCE

Generate the audit record on every refresh

Coverage, transform and key attestation arrive per field, ready for the reviewers who ask.

  • One record answers GDPR, DORA, NIS2 and BCBS 239 questions.
  • Every refresh adds a new record.
  • Auditors see what was found and what happened to it.

Refresh record

CoveragePer field
TransformPer field
Key attestationPer field

GDPR · DORA · NIS2 · BCBS 239

Developers need production data. Give them its twin.

Build, test and migration teams can’t work on toy data — they need production’s shape, volume and edge cases. SecureToken serves them a tokenized digital twin, provisioned through the test data management tooling they already use.

Worked example

One customer row, before and after

Sample data for illustration. The same token appears in every system, so joins keep working.

Field
Production
Twin
Name
Tommy Brennan
Kelvo Drasmen
Date of birth
14/03/1981
27/09/1978
Email
tommy.brennan@example.ie
kelvo.drasmen@example.ie
Phone
+353 87 123 4567
+353 85 904 2218
IBAN
IE29 AIBK 9311 5212 3456 78
IE46 PTSB 9906 0123 4567 89
Case note
Tommy Brennan asked to change his address.
Kelvo Drasmen asked to change his address.

Works with your TDM tool

Keep your TDM tool

The tool that provisions environments today keeps doing so.

Add one step

Tokenization turns production data into the twin before it reaches any environment.

Keep your schedules

Existing pipelines, jobs and refresh windows carry on as they are.

Meet every framework you report against

CCPA / CPRA

The California Consumer Privacy Act, amended by the CPRA, gives California residents rights over the personal information that businesses hold. Cybersecurity audit and risk assessment rules phase in from 2026.

Read CCPA blog

DORA

The Digital Operational Resilience Act has applied to EU financial entities since January 2025. It covers ICT risk management, incident reporting, resilience testing and third-party risk for every entity in scope.

Read DORA blog

GDPR

The General Data Protection Regulation is the EU regulation on processing the personal data of people in the EU. Fines reach up to 4% of global annual turnover for organisations in scope.

Read GDPR blog

NIS2

NIS2 is the EU directive that raises the cybersecurity baseline for essential and important entities across 18 sectors. Each EU member state transposes the directive into its own national law.

Read NIS2 blog

POPIA

South Africa’s Protection of Personal Information Act has been fully in force since July 2021, and the Information Regulator enforces it. It requires security safeguards for the personal information that organisations hold.

Get POPIA solution brief

Saudi Arabia PDPL

The Personal Data Protection Law is overseen by SDAIA and has been enforced since September 2024. It covers the processing, security and cross-border transfer of personal data in Saudi Arabia.

Read Saudi Arabia PDPL blog

Data compliance FAQs

Answers on the tokenized twin and the regulations it addresses.

Test, UAT and CI environments hold copies of production that reach developers, vendors and offshore teams. Regulators treat those copies as personal data, so the same obligations apply there as in production.

Masking scripts rewrite values one system at a time and drift as schemas change. A tokenized twin applies one policy across every system, keeps formats and joins intact, and records what it did on every refresh.

Tokenization reduces risk and scope, and tokenized data stays pseudonymised until the keys are destroyed. Under GDPR, pseudonymised data is still personal data. Destroyed-key mode produces anonymised output.

Yes. They receive tokens only, and the keys stay in a separate domain that those teams never reach.

Yes. The same input produces the same token in every system, so a customer stays one customer wherever the data lands.

No. Keep the TDM tool that provisions environments today. Tokenization becomes the step that turns production data into the twin.

It produces evidence for GDPR, DORA, NIS2 and BCBS 239, and for the frameworks listed on this page. Each regulation describes its own obligations, and Bluemetrix makes no compliance guarantee on a customer’s behalf.

Pick one non-production estate. Bluemetrix delivers a coverage report and a twin sample within two weeks.