Assess current data protection policies and procedures
3
Evaluate the organization's data processing activities
4
Map the locations and flow of personal data within the organization
5
Identify risks associated with the personal data stored and processed
6
Evaluate the subject's rights procedure
7
Assess the consent gathering processes
8
Evaluate data breach reporting and response procedures
9
Assess vendor compliance status
10
Train staff on GDPR principles
11
Evaluate data protection impact assessments
12
Check adequacy of data anonymization and pseudonymization techniques
13
Assess data retention and deletion procedures
14
Evaluate the physical and technical measures in place to protect data
15
Assess the procedures to handle a data breach
16
Ensure data transfer outside EU is in compliance with GDPR
17
Check if privacy design and default principles have been implemented
18
Review data protection policies, breach notification, and subject's rights processes
19
Approval: Data Protection Officer
Identify the Data Protection Officer
This task involves identifying the person within the organization who is responsible for overseeing GDPR compliance. The Data Protection Officer (DPO) plays a crucial role in ensuring that personal data is processed in accordance with the regulations. They are responsible for monitoring compliance, providing advice on data protection matters, and acting as a point of contact for data subjects and supervisory authorities. In order to complete this task, you will need to identify the individual who will fulfill the role of the DPO. This person should have an understanding of data protection laws and practices and should be able to carry out their duties independently. If you do not currently have a DPO, consider assigning someone within the organization or hiring a qualified professional. Resources or tools required: Job description for the DPO role, internal communication channels to announce the appointment of the DPO.
Assess current data protection policies and procedures
This task involves evaluating the organization's current data protection policies and procedures to ensure they align with GDPR requirements. It is important to assess and document the existing policies and procedures to identify any gaps or areas that need improvement. To complete this task, review the current data protection policies and procedures in place. Consider what personal data is collected, how it is processed, who has access to it, and how it is protected. Assess whether the policies and procedures address key GDPR requirements such as data minimization, purpose limitation, and lawful processing. Once the assessment is complete, document any identified gaps or areas for improvement and develop a plan to address them. Resources or tools required: Current data protection policies and procedures, GDPR regulations or guidelines.
Evaluate the organization's data processing activities
This task involves assessing the organization's data processing activities to ensure they comply with GDPR requirements. It is important to identify and document the types of personal data being processed, the purposes for which it is processed, and the legal basis for processing. To complete this task, review the organization's data processing activities. Identify the types of personal data being processed, the purposes for which it is processed, and the legal basis for processing. Assess whether the data processing activities align with GDPR requirements such as lawful processing, purpose limitation, and data minimization. Once the assessment is complete, document any identified non-compliance or areas for improvement, and develop a plan to address them. Resources or tools required: Data processing records, GDPR regulations or guidelines.
Map the locations and flow of personal data within the organization
This task involves mapping the locations and flow of personal data within the organization. It is important to understand where personal data is stored, who has access to it, and how it is transferred or shared. To complete this task, create a visual representation of the locations and flow of personal data within the organization. Identify where personal data is stored, such as databases, servers, or cloud storage platforms. Map the flow of personal data, including transfers between different locations or systems. Once the mapping is complete, assess whether the locations and flow of personal data comply with GDPR requirements. Identify any risks or areas for improvement, and develop a plan to address them. Resources or tools required: Data flow diagram template, data inventory, data transfer agreements.
Identify risks associated with the personal data stored and processed
This task involves identifying and assessing the risks associated with the personal data stored and processed by the organization. It is important to identify potential risks to the confidentiality, integrity, and availability of personal data. To complete this task, review the personal data stored and processed by the organization. Identify potential risks such as unauthorized access, data breaches, data loss, or data inaccuracies. Assess the impact and likelihood of each risk. Once the risks are identified and assessed, document them and develop a plan to mitigate or manage them. This may involve implementing security measures, updating policies and procedures, or providing staff training. Resources or tools required: Data inventory, risk assessment template, GDPR regulations or guidelines.
Evaluate the subject's rights procedure
This task involves evaluating the organization's procedures for handling data subject rights requests. It is important to ensure that individuals can exercise their rights under the GDPR, such as the right to access their personal data or the right to erasure. To complete this task, review the organization's procedures for handling data subject rights requests. Assess whether the procedures align with GDPR requirements, such as the timeframes for responding to requests and the mechanisms for verifying the identity of the data subject. Once the evaluation is complete, document any identified non-compliance or areas for improvement, and develop a plan to address them. Resources or tools required: Data subject rights procedures, GDPR regulations or guidelines.
Assess the consent gathering processes
This task involves assessing the organization's processes for obtaining and managing consent for data processing activities. It is important to ensure that consent is obtained in a clear, specific, and informed manner. To complete this task, review the organization's consent gathering processes. Assess whether the processes align with GDPR requirements, such as providing individuals with clear information about the purposes of processing and obtaining their explicit consent. Once the assessment is complete, document any identified non-compliance or areas for improvement, and develop a plan to address them. Resources or tools required: Consent gathering processes, GDPR regulations or guidelines.
Evaluate data breach reporting and response procedures
This task involves evaluating the organization's procedures for reporting and responding to data breaches. It is important to have processes in place to detect, report, and investigate data breaches in a timely manner. To complete this task, review the organization's data breach reporting and response procedures. Assess whether the procedures align with GDPR requirements, such as the timeframe for reporting breaches to the supervisory authority and notifying affected individuals. Once the evaluation is complete, document any identified non-compliance or areas for improvement, and develop a plan to address them. Resources or tools required: Data breach reporting and response procedures, GDPR regulations or guidelines.
Assess vendor compliance status
This task involves assessing the compliance status of vendors or third parties that process personal data on behalf of the organization. It is important to ensure that the organizations you work with have appropriate safeguards in place to protect personal data. To complete this task, review the list of vendors or third parties that process personal data on behalf of the organization. Assess their compliance status, such as whether they have implemented appropriate security measures, have data protection agreements in place, and conduct regular audits. Once the assessment is complete, document any identified non-compliance or areas for improvement, and develop a plan to address them. Resources or tools required: List of vendors or third parties, vendor due diligence questionnaire, GDPR regulations or guidelines.
Train staff on GDPR principles
This task involves providing training to staff members on GDPR principles and their responsibilities in relation to data protection. It is important to ensure that staff members have a good understanding of the GDPR and know how to comply with its requirements. To complete this task, develop a training program on GDPR principles. This may include topics such as data protection principles, data subject rights, data breach management, and consent management. Deliver the training to staff members and track their completion. Once the training is delivered, assess its effectiveness and document any areas for improvement or additional training needs. Resources or tools required: GDPR training materials, training delivery platform, training assessment questionnaire.
Evaluate data protection impact assessments
This task involves evaluating the organization's processes for conducting data protection impact assessments (DPIAs) for high-risk processing activities. It is important to assess the effectiveness of the DPIA process in identifying and mitigating risks to data protection. To complete this task, review the organization's DPIA process. Assess whether the process aligns with GDPR requirements, such as conducting DPIAs for high-risk processing activities and involving relevant stakeholders. Once the evaluation is complete, document any identified non-compliance or areas for improvement, and develop a plan to address them. Resources or tools required: DPIA process documents, GDPR regulations or guidelines.
Check adequacy of data anonymization and pseudonymization techniques
This task involves checking the adequacy of the organization's data anonymization and pseudonymization techniques. It is important to ensure that personal data is de-identified in a way that prevents re-identification. To complete this task, review the organization's data anonymization and pseudonymization techniques. Assess whether the techniques used provide an adequate level of protection, such as removing direct identifiers or replacing them with pseudonyms. Once the assessment is complete, document any identified non-compliance or areas for improvement, and develop a plan to address them. Resources or tools required: Data anonymization and pseudonymization techniques, GDPR regulations or guidelines.
Assess data retention and deletion procedures
This task involves assessing the organization's procedures for data retention and deletion. It is important to ensure that personal data is not retained for longer than necessary and is securely deleted when no longer needed. To complete this task, review the organization's data retention and deletion procedures. Assess whether the procedures align with GDPR requirements, such as defining retention periods for different types of personal data and implementing secure deletion processes. Once the assessment is complete, document any identified non-compliance or areas for improvement, and develop a plan to address them. Resources or tools required: Data retention and deletion procedures, GDPR regulations or guidelines.
Evaluate the physical and technical measures in place to protect data
This task involves evaluating the physical and technical measures that are in place to protect personal data. It is important to have appropriate safeguards in place to prevent unauthorized access, disclosure, alteration, or destruction of personal data. To complete this task, review the physical and technical measures in place to protect data. Assess whether the measures align with GDPR requirements, such as physical access controls, encryption, and network security. Once the evaluation is complete, document any identified non-compliance or areas for improvement, and develop a plan to address them. Resources or tools required: Physical and technical measures documentation, GDPR regulations or guidelines.
Assess the procedures to handle a data breach
This task involves assessing the organization's procedures for handling a data breach. It is important to have a clear and effective plan in place to detect, respond to, and recover from a data breach. To complete this task, review the organization's procedures for handling a data breach. Assess whether the procedures align with GDPR requirements, such as notifying the supervisory authority and affected individuals within the required timeframes. Once the assessment is complete, document any identified non-compliance or areas for improvement, and develop a plan to address them. Resources or tools required: Data breach response procedures, GDPR regulations or guidelines.
Ensure data transfer outside EU is in compliance with GDPR
This task involves ensuring that any transfer of personal data outside the European Union (EU) is in compliance with GDPR requirements. It is important to have appropriate safeguards in place to protect personal data when it is transferred to countries outside the EU. To complete this task, review the organization's data transfer processes. Assess whether the processes align with GDPR requirements, such as implementing standard contractual clauses or using other approved transfer mechanisms. Once the assessment is complete, document any identified non-compliance or areas for improvement, and develop a plan to address them. Resources or tools required: Data transfer agreements, GDPR regulations or guidelines.
Check if privacy design and default principles have been implemented
This task involves checking whether privacy design and default principles have been implemented in the organization's systems and processes. It is important to ensure that privacy is embedded into the design of systems and that data protection settings are set to the highest level by default. To complete this task, review the organization's systems and processes. Assess whether privacy design and default principles have been implemented, such as incorporating privacy by design into system development and ensuring that privacy settings are set to the highest level by default. Once the check is complete, document any identified non-compliance or areas for improvement, and develop a plan to address them. Resources or tools required: System design documentation, GDPR regulations or guidelines.
Review data protection policies, breach notification, and subject's rights processes
This task involves reviewing the organization's data protection policies, breach notification processes, and procedures for handling data subjects' rights requests. It is important to ensure that these policies and processes are up-to-date and compliant with GDPR requirements. To complete this task, review the organization's data protection policies, breach notification processes, and procedures for handling data subjects' rights requests. Assess whether these documents and processes align with GDPR requirements. Once the review is complete, document any identified non-compliance or areas for improvement, and develop a plan to address them. Resources or tools required: Data protection policies, breach notification procedures, subject's rights procedures, GDPR regulations or guidelines.