This checklist covers the essential steps you need to take to demonstrate GDPR compliance
The EU’s GDPR (General Data Protection Regulation) demands greater accountability and transparency from organisations in how they collect, process and store personal data.
Some obligations can be fulfilled relatively simply and quickly. Others, particularly in large or complex organisations, could have significant budgetary, IT, personnel, governance and communication implications – this may require a great deal of work or expertise. Ensuring commitment from senior management and key stakeholders in your organisation will prove critical to ensure a top-down approach and sufficient resources for your compliance project.
The key steps to GDPR compliance
The GDPR states that organisations must be able to demonstrate their compliance with the Regulation; particularly with the six data processing principles. This is also known as the ‘accountability principle’. A comprehensive and effective PCF (privacy compliance framework) will naturally compile evidence to prove compliance.
This checklist with recommended solutions highlights the essential steps you need to take to prepare for the GDPR and demonstrate compliance.
1. Establish an accountability and governance framework
- Brief management on the GDPR-related risks and benefits.
- Gain management support for your GDPR compliance project.
- Give a director the responsibility of GDPR accountability.
- Incorporate data protection risk into the corporate risk management and internal control framework.
Our solutions
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EU GDPR – A Pocket Guide
This concise guide is essential reading for anyone wanting an overview of the GDPR and the new compliance obligations for handling personal data.
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GDPR Ask Us
Need a quick answer to a GDPR question? Get quick and easy advice on a GDPR topic by email or live chat.
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2. Scope and plan your project
What you need to do
- Appoint and train a project manager, and appoint a DPO (data protection officer) if necessary.
- Identify which entities will be in scope – business units, territories, jurisdictions.
- Identify other standards or management systems that could provide a framework for compliance; for instance, implementing ISO 27001 demonstrates information security best practice.
- Assess the principle of data protection by design and default against current or new processes and systems.
- Consider the implications of Brexit in your planning.
3. Conduct a data inventory and data flow audit
What you need to do
- Assess the categories of data held, where it comes from and the lawful basis for your processing.
- Map data flows into, within and from your organisation.
- Use the data map to identify the risks in your data processing activities and assess whether a DPIA (data protection impact assessment) is needed.
Our solutions
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Data Flow Mapping Tool and Compliance Manager
This Cloud-based software simplifies the process of creating data flow maps, giving you a thorough understanding of what personal data your organisation processes. Integration with Compliance Manager allows you to track your compliance with the GDPR articles.
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GDPR data flow audit
Receive, through an onsite audit, an inventory of the types of personal data collected and processed in your organisation, and a data flow map.
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4. Conduct a detailed gap analysis
What you need to do
- Audit your current compliance position against the requirements of the GDPR.
- Identify compliance gaps requiring remediation.
Our solutions
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EU GDPR Compliance Gap Assessment Tool
This questionnaire-driven tool helps you to assess of your organisation’s compliance position and identify the gaps for remediation.
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GDPR Gap Analysis
Get an onsite assessment of your organisation’s privacy management and data protection practices, and a report summarising compliance gaps and remediation recommendations.
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5. Develop operational policies, procedures and processes
What you need to do
- Create Article 30 documentation – the record of personal data processing activities drawn from the data flow audit and gap analysis.
- Bring data protection policies and privacy notices in line with the GDPR.
- Where relying on consent, ensure the conditions of that consent meet the new requirements.
- Review and update employees’, customers’ and supplier contracts.
- Plan how to recognise and handle data subject access requests (DSARs) and provide responses within a month.
- Have in place a process for determining whether a DPIA is required.
- Secure personal data through appropriate organisational and technical measures.
- Ensure policies and procedures are in place to detect, report and investigate a data breach.
- Review whether the mechanisms for data transfers outside the EU are compliant.
6. Secure personal data through procedural and technical measures
What you need to do
- Have an information security policy
- Put in place basic technical controls such as those specified by established frameworks like Cyber Essentials
- Use encryption and/or pseudonymisation where it is appropriate
- Ensure policies and procedures are in place to detect, report and investigate a personal data breach
Our solutions
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ISO 27001
ISO/IEC 27001 provides an excellent starting point for achieving the technical and operational requirements necessary to prevent a data breach under the General Data Protection Regulation (GDPR)
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Incident Response Management Foundation Training Course
Find out how to effective manage and respond to a disruptive incident and take appropriate steps to limit the damage of potential information security.
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Penetration testing
Undertake a security assessment of your websites and IT systems to ensure there is adequate protection against cyber attacks.
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7. Communications
What you need to do
- GDPR implementation affects your entire organisation – effective internal communication with stakeholders and staff is key.
- Employees need to understand the importance of data protection and be trained on the basic GDPR principles and procedures being implemented to achieve compliance.
8. Monitor and audit compliance
What you need to do
- Schedule regular audits of data processing activities and security measures.
- Keep personal data processing records up to date.
- Undertake DPIAs where required.
Free GDPR resources
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