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This checklist covers the essential steps you need to take to demonstrate GDPR compliance

The EU General Data Protection Regulation (GDPR) demands greater accountability and transparency from organisations in how they collect, process and store personal information.

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, and require a great deal of work or expertise. Ensuring commitment from senior management and key stakeholders in your organisation will prove essential when it comes to meeting your obligations.

Being able to prove compliance is critical, and a comprehensive and effective privacy compliance framework will naturally compile evidence to prove that you are compliant.

 

The key steps to GDPR compliance

This checklist covers the essential steps you need to take to demonstrate GDPR 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.

 

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2. Scope and plan your project

To do:

  • Appoint and train a project manager, and appoint a DPO 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.

 

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Certified EU GDPR Foundation and Practitioner Combination Course

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3. Conduct a data inventory and data flow audit

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 data protection impact assessment (DPIA) is needed.

 

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GDPR data flow audit

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4. Conduct a detailed gap analysis

To do

  • Audit your current compliance position against the requirements of the GDPR.
  • Identify compliance gaps requiring remediation.

 

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EU GDPR Compliance Gap Assessment Tool

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GDPR Gap Analysis

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5. Develop operational policies, procedures and processes

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.

 

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6. Communications

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.

 

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Monitor and audit compliance

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

GDPR green paper

Download

 

GDPR infographic

Download

 

GDPR webinars

Download

 

2017 GDPR survey report

Download

 

Speak to an expert

Please contact our GDPR team for advice and guidance on our products and services