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GDPR Compliance Checklist

1. Establish an accountability and governance framework

GDPR compliance requires board-level support. It’s therefore essential that the board understands the implications of the Regulation – both positive and negative – so that they can allocate the resources needed to achieve and maintain compliance.

What you need to do:

  • Advise the board about data protection risks and the benefits of GDPR compliance.
  • Obtain management support for a GDPR compliance project.
  • Assign accountability for GDPR compliance to a director.
  • Incorporate data protection risk into your corporate risk management activities.

       Solutions:

2. Scope and plan your project

Once you have obtained top-level support, you will need to work out what areas of your organisation fall under the GDPR’s scope.

What you need to do:

  • Appoint and train a project manager.
  • Appoint a DPO (data protection officer) if necessary. If you’re unsure about whether or how to appoint a DPO, visit our DPO information page.
  • Identify other standards or management systems that could provide a framework for compliance, e.g. implementing ISO 27001 demonstrates that you follow information security management best practice, which helps you meet requirements for appropriate technical and organisational security measures.
  • Assess whether data protection by design and by default has been incorporated into processes and systems.
  • Consider the implications of Brexit in your planning.

       Solutions:

3. Conduct a data inventory and data flow audit

To comply with the GDPR's data processing requirements you must be able to fully understand what data you process and how you process it. You should therefore:

What you need to do:

  • Assess the categories of data you hold, where it comes from and the lawful basis for processing.
  • Create a map that shows how data flows to, through and from your organisation.
  • Use the data map to identify the risks in your data processing activities and determine whether a DPIA (data protection impact assessment is required.
  • Create records of personal data processing activities, as required by Article 30, drawn from the data flow audit and gap analysis.

       Solutions:

  • Data Flow Mapping Tool and Compliance Manager
    Simplify the process of creating data flow maps and gain a thorough understanding of the personal data your organisation processes. Integration with Compliance Manager helps you track your compliance against specific GDPR articles.

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  • GDPR data flow audit
    Our experts will conduct a thorough on-site audit of the personal data your organisation collects and processes, and provide a map that plots personal data in all its forms, wherever it is processed.

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4. Conduct a detailed gap analysis

You should assess your current workflows, processes and procedures to identify the gaps that you need to fill.

What you need to do:

  • Audit your current compliance position against the GDPR’s requirements.
  • Determine which compliance gaps require remediation.

       Solutions:

  • EU GDPR Compliance Gap Assessment Tool
    This questionnaire-driven tool helps you assess your organisation’s compliance position and identify any gaps for remediation.

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  • GDPR Gap Analysis
    Get an on-site assessment of your privacy management and data processing practices from our data protection consultants, who will summarise your compliance gaps and provide remediation recommendations.

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5. Develop operational policies, procedures and processes

Having established your compliance gaps, you should bring your existing policies, processes and procedures into line with the GDPR’s requirements, and develop new ones to ensure you fulfil all of your legal obligations.

What you need to do:

  • Ensure your data protection policies and privacy notices are in line with the GDPR.
  • Where you rely on consent as your lawful basis for processing, ensure it meets the GDPR’s requirements.
  • Review employee, customer and supplier contracts, and update them if necessary to cover personal data processing.
  • Plan how to recognise and handle DSARs (data subject access requests) and provide responses within one calendar month.
  • Have a process in place for determining whether a DPIA is required.
  • Review whether your mechanisms for transferring data outside the EEA are compliant, especially after Brexit.

       Solutions:

  • GDPR contract and legal services
    Get expert legal advice and support to update privacy notices, data protection policies, supplier contracts and international data transfer agreements in accordance with the GDPR.

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  • EU GDPR Documentation Toolkit
    Demonstrate your GDPR compliance with more than 80 indispensable policies, procedures, templates and worksheets to save you time and money on your GDPR compliance project.

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  • DPIA Workshop
    This one-day workshop covers when to conduct a DPIA under the GDPR and uses a real-life case study to demonstrate best practices and methodologies, including the application of a DPIA tool to help assess and address privacy risks.

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  • GDPR Manager
    The Gap Analysis module gives you instant visibility of your current compliance status, allowing you to easily identify the actions you need to take to protect your personal data in compliance with the GDPR and in conformance to BS 10012:2017

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6. Secure personal data through procedural and technical measures

The GDPR requires organisations to implement “appropriate technical and organisational measures” to ensure that personal data is processed appropriately.

What you need to do:

       Solutions:

7. Communications

Staff awareness and education is a key component of any organisation’s GDPR compliance framework. Everyone involved in processing data must be appropriately trained to follow approved processes and procedures.

What you need to do:

  • Ensure internal communications with stakeholders and staff effective.
  • Train your employees to understand the importance of data protection, basic GDPR principles and the procedures you have implemented to ensure compliance.

       Solutions:

8. Monitor and audit compliance

GDPR compliance is an ongoing project – a journey rather than a destination. You should undertake periodic internal audits and regularly update your data protection processes. This includes checking your records of processing activities and consent, testing information security controls, and conducting DPIAs.

What you need to do

  • Schedule regular audits of data processing activities and security controls.
  • Keep records of personal data processing up to date.
  • Undertake DPIAs where required.
  • Assess data protection practices and manage some of the more arduous elements of GDPR compliance. 

       Solutions:

  • GDPR Manager
    Enables organisations to manage a range of GDPR elements, such as recording and reporting data breaches, handling subject access requests, and monitoring third party compliance in a single platform.

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  • Live Online GDPR Consultancy
    Get expert advice on specific GDPR compliance issues whenever and wherever you need it with consultancy support by the hour.

    Find out more