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The key steps to GDPR compliance

The ability to prove General Data Protection Regulation (GDPR) compliance is critical, and a comprehensive and effective privacy compliance framework will develop evidence to support your compliance claims.

In some cases, the following GDPR compliance steps will supplement existing measures that many organisations adopt to comply with national laws in the Gulf region, including the DIFC Data Protection Law 2007, Abu Dhabi Global Market’s Data Protection Regulations and Qatar Personal Privacy Protection Law.

This checklist highlights the essential steps you need to demonstrate compliance, and recommends solutions.

 

1. Establish an accountability and governance framework

To do

  • Assess whether your business activity falls within the territorial scope of the GDPR.
  • Brief management on the GDPR risks and benefits.
  • Gain management support for a GDPR compliance project.
  • Assign a director with accountability for the GDPR.
  • Incorporate data protection risk into the corporate risk management and internal control framework.

 

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2. Scope and plan your project

To do

  • Appoint and train a project manager, and appoint a DPO if necessary.
  • Identify which entities will be in scope: business units, territories, jurisdictions.
  • Identify your organization’s lead supervisory authority in the EU
  • Identify other standards or managements systems that could provide a framework for compliance, e.g. implementing ISO 27001 demonstrates information security best practice.
  • Assess the principle of data protection by design and by default against current or new processes and systems.

 

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3. Conduct a data inventory and data flow audit

To do

  • Assess the categories of data held, where it comes from and the lawful basis for your processing.
  • Map data flows into, within and from your organisation.
  • Use the data map to identify the risks in your data processing activities and whether a data protection impact assessment (DPIA) is needed.

 

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Data Flow Mapping Tool and Compliance Manager

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GDPR data flow audit

Receive, through an onsite audit, an inventory of the types of personal data collected and processed in your organisation, and a data flow map.

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4. Conduct a detailed gap analysis

To do

  • Audit your current compliance position against the GDPR’s requirements.
  • Identify compliance gaps requiring remediation.

 

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EU GDPR Compliance Gap Assessment Tool

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GDPR Gap Analysis

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5. Develop operational policies, procedures and processes

To do

  • Create Article 30 documentation – the record of personal data processing activities drawn from the data flow audit and gap analysis.
  • Bring data protection policies and privacy notices in line with the GDPR.
  • Where relying on consent, ensure quality of consent meets new requirements.
  • Review and update employee, customer and supplier contracts.
  • Plan how to recognise and handle data access requests and provide responses within a month.
  • Have in place a process for determining whether a DPIA is required.
  • Secure personal data through appropriate procedural and technical measures.
  • Ensure policies and procedures are in place to detect, report and investigate a personal data breach.
  • Review whether the mechanisms for data transfers outside the EU are compliant.

 

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EU GDPR Documentation Toolkit

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6. Communications

To do

  • GDPR compliance is a business change project – effective internal communications with stakeholders and staff is key.
  • Employees need to understand the importance of data protection and be trained on the basic principles of the GDPR and the procedures being implemented for compliance.

 

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7. Monitor and audit compliance

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.

 



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Please contact our GDPR team for advice and guidance on our products and services