Make Sure You’re Ready For GDPR With Our GDPR Checklist

GDPR is all about making sure companies are accountable for responsibly storing and using their users’ data. It has the effect of placing significant regulatory burden on companies that process and store user data, but this kind of thing has been a long time coming. Complete lack of oversight in storing personally identifiable information was not something that we could have expected to stick around. You can use our GDPR checklist to make sure your up to snuff on compliance.

GDPR Checklist Step 1: Are You Included?

GDPR applies to citizens in the European Economic Area. If your company is located in that region, or any of your users are located in that region, you must work within the GDPR regulations. As you might guess, this applies to nearly every online company. With users all over the world, few internet-based companies are exempt from the requirements of GDPR. Before you jump into the checklist, familiarize yourself with the GDPR legislation and get a better sense of the requirements.

GDPR Checklist Step 2: What Data You Have?

  • What personally identifying data do you have?
  • Do you have a list of all the data you hold and how you store it?
  • Have you mapped where the data is stored and how data flows work within your organization?
  • Are you collecting any of what the GDPR calls “Sensitive Personal Data?” This includes children’s data, biometric data, genetic data, health data and similar.
  • If you are, do you meet the requirements for collection, processing, and storage?
  • Is data being sent outside of the EU for processing or storage?
  • If so, is it being handled and transmitted securely and properly during and after its trip?

GDPR Checklist Step 3: Do You Have Permission?

  • Did you get that information in accordance with appropriate collection policies?
  • Did you get the required consent to collect the data, and did you inform the subjects of collection about how and why you were using the data?
  • Did you do so clearly and without prevarication or misleading people?
  • Did you give people a right to withdraw their consent from use of their data?
  • Is this information clearly communicated to the user before their data is collected?
  • Does your company have a publicly accessible privacy policy that outlines processes related to personal data?
  • Does your privacy policy include a lawful basis for collection and processing of the data?

GDPR Checklist Step 4: How Do You Store Data?

  • Is data being secured with encryption and security protocols relevant to the risk of exposure?
  • Will encryption or anonymization (or pseudonymity) be necessary to protect the user data?
  • Are you collecting any of what the GDPR calls “Sensitive Personal Data?” This includes children’s data, biometric data, genetic data, health data and similar.
  • If you are, do you meet the requirements for collection, processing, and storage?

GDPR Checklist Step 5: How Do You Use The Data?

  • Is the data being held for only the length of time necessary for use?
  • Is the data you’re holding being kept up to date?
  • Is access being limited to only those that need the data to do their jobs?
  • Is access limited to the part of the data required and nothing else?

GDPR Checklist Step 6: Educating the Team

  • Is the security team aware of their new obligations under GDPR and do they have the training and resources to implement new processes and methods to satisfying the legislation’s requirements?
  • Is there a GDPR-compliant methodology in place to handle requests from subjects to modify, remove or access their data?
  • Are security breaches notifications appropriately and timely to meet enhanced requirements for actions under the GDPR?
  • Have our data handlers been trained in the relevant areas of EU law to make sure they’re up to the task of meeting GDPR’s extra burden?
  • Do we review and audit the data we hold on a regular basis?

GDPR Checklist Step 7: Updating the Privacy Policy

  • Do we have a Privacy Policy in place and if so, do we need to update it to comply with the GDPR?
  • Do we have a defined policy on retention periods for all items of personal data, from customer, prospect and vendor data to employee data? Is it compliant with the GDPR?
  • Are our internal procedures adequately documented?
  • If we’re a data processor, have we updated our contracts with the relevant controllers to ensure they include the mandatory provisions set out in Art. 28 of the GDPR?
  • In cases where our third party vendors are processing personal data on our behalf, have we ensured our contracts with them have been updated to include those same processor requirements under the GDPR?

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