Steps Towards Compliance
1. Awareness
You should make sure that decision makers and key people in your organisation are aware that the law has changed to the GDPR. They need to appreciate the impact this is likely to have have.
2. Information you hold
You should document what personal data you hold, where it came from and who you share it with. You may need to organise an information audit.
3. Communicating privacy information
You should have reviewed your privacy notices and put a plan in action making any necessary changes for GDPR implementation.
4. Individuals’ rights
You should have checked your procedures to ensure they cover all the rights individuals have, including how you delete personal data or provide data electronically and in a commonly used format.
5. Subject access requests
You should have updated your procedures and implemented a plan for handling requests within the new timescales and provide any additional information.
6. Lawful basis for processing personal data
You should have identified the lawful basis for your processing activity in the GDPR, documented it and updated your privacy notice to explain it.
7. Consent
You should have reviewed how you seek, record and manage consent and whether you need to make any changes and refreshed existing consents if they didn’t meet the GDPR standard.
8. Children
If needed you should have put systems in place to verify individuals’ ages and to obtain parental or guardian consent for any data processing activity.
9. Data breaches
You should have made sure you have the right procedures in place to detect, report and investigate a personal data breach.
10. Data Protection by Design and Data Protection Impact Assessments
You should have familiarised yourself with the ICO’s code of practice on Privacy Impact Assessments as well as the latest guidance from the Article 29 Working Party, and implemented them in your organisation.
11. Data Protection Officers
You should have designated someone to take responsibility for data protection compliance and assessed where this role sits within your organisation’s structure and governance arrangements. You should have considered whether you are required to formally designate a Data Protection Officer.
12. International
If your organisation operates in more than one EU member state (ie you carry out cross-border processing), you should have determined your lead data protection supervisory authority. Article 29 Working Party guidelines will help you do this.
