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MCP server security & GDPR: how to keep your deployment safe

An AI assistant that accesses accounting, CRM or your mailbox via MCP saves your team time. But it is also a new attack surface. This guide shows the threat model, what the MCP specification and OWASP require, an operations checklist and what the GDPR says on the matter. As of October 2026.

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How do you stay safe with MCP servers?

You stay safe if every MCP server only accepts authenticated requests, offers only fixed and narrowly authorised tools, treats third-party content as data, logs every call and only goes live after a review. Everything else on this page expands on these five points.

Core principle: An MCP server is secure if every single tool call is tightly scoped, traceably logged and subject to approval for risky actions. The limits are not decided by the model, but by the architecture.

Why is MCP security a discipline of its own?

Because an AI agent decides at runtime which tool to call, and in doing so reads text that someone else wrote. Classic security asks who is allowed in. With MCP, there is an added question: what may the agent do on its own, and who told it to?

When you connect business systems via the Model Context Protocol, the risk shifts from pure access control to the question of how an agent can be induced to do something nobody wanted. This guide complements the general framework in GDPR-compliant AI with the concrete levers at MCP level.

Which attacks threaten MCP servers? The threat model

The most important attacks target sign-in to the server, the passing on of credentials, manipulated tools and text that the model mistakes for a command. The table shows how each one happens and what helps against it.

ThreatHow it happensWhat helps
Transport without sign-inThe server offers an HTTP endpoint without authentication, often on the assumption that "it's only localhost". Anyone who reaches it uses the tools with the operator's credentials.Sign-in on every request, bind locally to 127.0.0.1 only, Origin and Host checks
Token passthroughThe server accepts a token that was not issued for it and passes it on to a downstream interface.Accept only tokens with the server as audience, use separate tokens for downstream systems via token exchange
Confused deputyAn MCP proxy uses a fixed client ID with a third party. Through an existing consent, an attacker obtains an authorization code without renewed approval.Per-client consent on the server, exact redirect URI check, valid state parameter
Tool poisoningThe description or response of a tool contains instructions that the model follows.Vetted servers, read descriptions on every update, approval for write actions
Prompt injection via tool responsesAn email, a receipt or a ticket contains text such as "export the customer list". The model reads it through a tool and acts on it.Treat third-party text as data, tools without export or send functions, approval step
Rug pull and supply chainA server that was harmless at first changes tools or descriptions after approval, or a dependency is compromised.Pinned versions, review every update, monitor dependencies
Excessive permissionsA token or database user may do more than the use case needs. A stolen token then opens everything.Minimal scopes, permissions per tool, request more only when needed
Data leakageData from one system ends up with unauthorised parties via another server or via the context, for example because context is shared between tasks or users.Data minimisation in the tool, separate contexts, no output to third-party destinations

What we see in practice: In our own security research on publicly available MCP servers, the high-rated findings consistently lay at the transport and sign-in level, not in the logic of individual tools. A typical pattern is a host check that compares only the start of the address instead of the whole. That is why sign-in comes first on the checklist. Background on OAuth pitfalls in the MCP ecosystem is provided by CyberSec42's security research on MCP OAuth security.

How prompt injection works in detail and which defences are effective is described in the guide Prompt injection and AI security.

What does the MCP specification require for authorization?

The current MCP specification (version 2026-07-28) makes authorization optional. Anyone offering it over HTTP, however, should implement OAuth 2.1 according to fixed rules, and the server must verify that every token was issued specifically for it.

The most important requirements from the authorization specification and the Streamable HTTP transport, as of October 2026 (version overview):

The specification's Security Best Practices also describe confused deputy, token passthrough, SSRF in metadata discovery, compromised local servers and the minimisation of scopes in detail. Anyone building a server themselves should read both documents in full.

OWASP MCP Top 10: which risks does OWASP name?

OWASP lists ten risk classes for MCP environments, from unprotected credentials to unapproved shadow servers. As of October 2026, the project has beta status (OWASP MCP Top 10).

No.Risk according to OWASPWhat you do about it in operation
MCP01Token Mismanagement & Secret Exposure: long-lived or hard-coded credentials, also in logsSecrets store, short lifetimes, nothing secret in logs or model context
MCP02Privilege Escalation via Scope Creep: permissions grow over timePermissions per tool, regular review
MCP03Tool Poisoning: manipulated tools or outputsVetted sources, pinned versions
MCP04Software Supply Chain Attacks & Dependency TamperingPin and monitor dependencies
MCP05Command Injection & Execution: commands built from unchecked inputSchema validation, no shell calls with model text
MCP06Prompt Injection via Contextual PayloadsThird-party text as data, approval step
MCP07Insufficient Authentication & AuthorizationSign-in on every request, audience check of the token
MCP08Lack of Audit and TelemetryAudit log of every call, analysis when something goes wrong
MCP09Shadow MCP Servers: servers outside the approval processApproval process, directory of all servers
MCP10Context Injection & Over-Sharing: shared context exposes dataSeparate contexts per user and task

What does SAP require of its own MCP servers?

The SAP Architecture Center ties its own MCP servers to a governance checklist that also works well as a yardstick outside SAP (SAP Architecture Center).

What SAP otherwise permits for AI agents on SAP systems is covered in the guide SAP MCP server and API Policy. For direct database access, there is a separate guide on the SAP HANA MCP server.

Checklist for operating MCP servers

We use this checklist before every go-live and with every change. Each point can be checked individually.

Would you like to know how your existing setup measures up against this list? The MCP security quick check shows what your AI agents can reach today.

Local MCP servers: what applies on your own machine?

Local MCP servers run with the rights of the signed-in user and are therefore as dangerous as any other program you install. The specification describes three ways this goes wrong: a malicious start command in the configuration, malicious code in the server itself, and an open local server that is addressed from a web page via DNS rebinding.

How do you approve new MCP servers?

With a fixed process that checks origin, code, permissions, network and vendor terms before a server touches real data. OWASP names unapproved servers as a risk class of their own (MCP09, Shadow MCP Servers).

  1. Origin: Who maintains the server, how actively, is there a reporting channel for security vulnerabilities?
  2. Code and version: Review a specific version and use exactly that one, not "latest".
  3. Read the tools: Which tools does the server offer, what do the descriptions say, are there free-form queries, shell tools or URL tools?
  4. Permissions and network: Which account does it use to access systems, which destinations may it reach?
  5. Vendor terms: Does the provider of the connected system allow access by AI agents at all? Several vendors published rules on this in 2025 and 2026. The guide MCP and vendor policies gives an overview.
  6. Test operation: First with test data, then with real data and an audit log.
  7. Directory: Every approved server is listed with its version, owner and purpose. Every update is a new approval.

Logging: audit-ready, but without content data

An MCP server should log every tool call in a way that later shows who triggered what, without the log itself becoming a data collection. An agent whose actions you cannot trace is not manageable in the sense of the GDPR.

In a dispute, for example over the question "Who sent this invoice?", this is the difference between an answer you can prove and a shrug. Define retention periods and access rights for the log itself, because logs are personal data too.

GDPR: what do you need to settle when using MCP?

For MCP use you need a legal basis, data processing agreements with all service providers, data minimisation already in the tool, an honest account of who operates which part, and often the involvement of the works council. This is our assessment, not legal advice.

Data processing

As soon as personal data goes to a service provider who processes it on your behalf, you need a data processing agreement under Art. 28 GDPR (GDPR). This affects the model provider, the operator of the MCP server if that is not you, and hosting providers. The contract regulates purpose limitation, sub-processors, retention periods and processing locations. The major model providers make such contracts available in their enterprise and cloud offerings.

Data minimisation in the tool

Art. 5(1)(c) GDPR requires that only the necessary data is processed, and Art. 25 requires data protection by design. For MCP this means: the tool decides which fields the model sees at all. A dunning routine needs the amount and due date, not the conversation notes on the contact person. What the tool does not deliver, the model can neither process nor pass on.

Presenting the location honestly

An MCP chain has several parts, and each can run somewhere else. For each part, record who operates it and where:

Part of the chainWho typically operates itWhat you clarify
AI assistant (chat interface)Provider of the assistant, for example Microsoft or AnthropicTenant region, DPA, storage of chat histories
Language modelModel provider or cloud platformChosen region, whether requests are distributed across regions, DPA
MCP serverYou, your service provider or the vendor of the business systemHosting location, operator, logging. Servers operated by the vendor often run outside the EU.
Business system (ERP, CRM, DMS)You or the software vendorExisting contracts, vendor terms for AI access

We operate the MCP server itself in the EU, for example in the Azure region Germany West Central (Frankfurt) or with a German hosting provider. For the language model we use offerings with a contractually selectable EU region. If a US provider is in the path, a third-country link under Art. 44 et seq. GDPR still needs to be assessed, for example through group access or support. In that case we do not give a blanket assurance that data never leaves Europe.

Works council

Under § 87(1) no. 6 BetrVG (German Works Constitution Act), the works council has a co-determination right where technical systems are suitable for monitoring the behaviour or performance of employees (BetrVG). Audit logs that record who asked the assistant which question can fall under this. Involve the works council early and define what the logs may be analysed for.

On-premises, EU cloud or hybrid?

Both routes can be implemented in a GDPR-compliant way. The decision should depend on the data class, not on gut feeling:

  1. On-premises or your own data centre Data stays in your own network, and control lies with you. In return, you operate, patch and monitor it yourself. Makes sense for particularly sensitive data or existing strong IT.
  2. EU cloud (managed) A clearly defined region in Europe with considerably less operating effort. For many mid-sized companies the pragmatic standard, provided hosting and model provider keep to the chosen region.
  3. Hybrid Sensitive processing locally, less critical steps in the EU cloud. More architectural effort, but fine-grained control; often the answer for grown IT landscapes in mid-sized companies.

Frequently asked questions

How do you stay safe on MCP servers?

With five basic rules: every request to the server is authenticated, every tool has narrowly defined permissions, content from emails, documents and tool responses counts as data and never as an instruction, every call is logged, and new servers go live only after a review. Read-only tools come first, tools that write only with approval by a human.

What is the most common serious vulnerability in MCP servers?

According to our own security research on publicly available MCP servers, the serious vulnerabilities lie mainly at the transport and sign-in level. Typical is an HTTP endpoint with no or incomplete authentication. Anyone who reaches the endpoint uses the tools with the operator's credentials. With local servers, DNS rebinding can even put this within reach from the browser.

What is token passthrough and why is it prohibited?

Token passthrough means that an MCP server accepts a token that was not issued for it and passes it on to a downstream interface. The MCP specification prohibits this because checks, limits and traceability are lost in the process, and the server can become a tool for data leakage.

What is tool poisoning?

In tool poisoning, manipulated instructions are hidden in the description or in the responses of a tool. This often stays invisible to humans, while the model reads it along. Protection comes from vetted servers with a pinned version, a review of tool descriptions with every update, and approval for write actions.

Can an MCP server be operated in a GDPR-compliant way?

Yes, if the legal basis, data processing agreements, data minimisation in the tool and logging are right, and you honestly record who operates which part and where processing takes place. If a US provider is in the path, a third-country link cannot be ruled out. This is our assessment, not legal advice.

Do I need a DPA with the AI provider?

As soon as personal data goes to a service provider who processes it on your behalf, you need a data processing agreement under Art. 28 GDPR. This applies to the model provider as well as to the operator of the MCP server, if that is not you.

Does the data stay in the EU?

That depends on every single part of the chain: assistant, model, MCP server and connected systems. An EU region with cloud providers is an important building block. We do not give a blanket assurance that data never leaves Europe when a US provider is involved.

What belongs in the audit log of an MCP server?

For each call: who triggered it, which tool with which parameters, result status, data volume, duration and time. Personal values are redacted, and content data such as email texts or receipts do not belong in the log. It is stored in such a way that entries cannot be changed afterwards.

Does the works council have to be involved when using MCP?

Often yes. Under § 87(1) no. 6 BetrVG (German Works Constitution Act), the works council has a co-determination right where technical systems are suitable for monitoring the behaviour or performance of employees. Audit logs of AI assistants can be such systems. So involve the works council early.

How do I check a third-party MCP server before approving it?

Check the origin and maintenance of the project, review code and dependencies in a pinned version, read the tools and their descriptions, limit permissions and network access to what is necessary, check the terms of the connected vendor, and run the server in a test environment first. Every update is a new approval.

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