GDPR Compliance Checklist
December 5, 2024
Data Mapping and Documentation
Start by creating a comprehensive data inventory. Document what personal data you collect, where it comes from, how you use it, who has access to it, and where it's stored. This data map is the foundation of your compliance program.
Create and maintain a Record of Processing Activities (ROPA). This document should detail all your data processing operations, including the purposes of processing, categories of data subjects and personal data, and recipients of data.
Identify your lawful basis for each processing activity. GDPR requires a legal justification for processing – consent, contract, legal obligation, vital interests, public task, or legitimate interests. Document your rationale for the lawful basis chosen.
Privacy Policies and Notices
Update your privacy policy to meet GDPR requirements. It must be written in clear, plain language and include specific information about what data you collect, why you collect it, how long you keep it, and who you share it with.
Ensure your privacy notices are easily accessible and provided at the point of data collection. Individuals must be informed about their rights and how to exercise them. Include details about your data protection officer or contact person.
If you rely on consent as your lawful basis, ensure it meets GDPR standards – freely given, specific, informed, and unambiguous. Implement clear opt-in mechanisms and keep records of when and how consent was obtained.
Data Subject Rights Procedures
Establish clear procedures for handling data subject requests. You must be able to respond to requests for access, rectification, erasure, restriction of processing, data portability, and objection to processing within one month.
Create templates and workflows for each type of request. Train your team on how to recognize and handle these requests promptly. Ensure you can verify the identity of individuals making requests to prevent unauthorized disclosure.
Keep records of all data subject requests and how you responded. This documentation demonstrates compliance and helps identify trends or issues in your data handling practices.
Security and Breach Response
Implement appropriate technical and organizational measures to ensure data security. This includes encryption, access controls, regular backups, and security monitoring. The measures should be proportionate to the risks posed by your processing activities.
Develop and test a data breach response plan. GDPR requires notification to supervisory authorities within 72 hours of becoming aware of a breach that poses a risk to individuals' rights and freedoms. You must also notify affected individuals in some cases.
Conduct regular security assessments and penetration testing. Keep all systems updated with the latest security patches. Ensure your third-party vendors also maintain appropriate security standards.
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