So now we know what it is and what it means, this week we take a look at what we should do about it. A really useful starting point is contained in the Information Commissioners website which provides a range of resources explaining GDPR and how organisations can go about preparing to comply with it.
Their 12 steps guide covers the initial activities that can be started immediately and include;
The guide is summarised below for convenience.
You should make sure that decision-makers and key people in your organisation are aware that the law is changing to the GDPR. They need to appreciate the impact this is likely to 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 review your current privacy notices and put a plan in place for making any necessary changes in time for GDPR implementation.
4. Individuals’ rights
You should check your procedures to ensure they cover all the rights individuals have, including how you would delete personal data or provide data electronically and in a commonly used format.
5. Subject access requests
You should update your procedures and plan how you will handle requests within the new timescales and provide any additional information.
6. Lawful basis for processing personal data
You should identify the lawful basis for your processing activity in the GDPR, document it and update your privacy notice to explain it.
You should review how you seek, record and manage consent and whether you need to make any changes. Refresh existing consents now if they don’t meet the GDPR standard.
You should start thinking now about whether you need to 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 make 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 familiarise yourself now with the ICO’s code of practice on Privacy Impact Assessments as well as the latest guidance from the Article 29 Working Party, and work out how and when to implement them in your organisation.
11. Data Protection Officers
You should designate someone to take responsibility for data protection compliance and assess where this role will sit within your organisation’s structure and governance arrangements. You should consider whether you are required to formally designate a Data Protection Officer.
If your organisation operates in more than one EU member state (i.e you carry out cross-border processing), you should determine your lead data protection supervisory authority. Article 29 Working Party guidelines will help you do this.
In our next blog we will discuss some of the technical implications borne out of GDPR compliance.
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