Infographic: GDPR 12 Steps You Can Take NOW

Click Here to Download the PDF: GDPR 12 Steps That You Can Take Right Now

 

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;

  • Awareness of Decision Makers
  • Information Audit
  • Update Privacy Notices
  • Procedures for Individual Rights
  • Subject access requests procedures
  • Consent procedures
  • Under-age Consent Procedures
  • Privacy Impact Assessments
  • Data Protection Officer
  • International Implications

The guide is summarised below for convenience.

1. Awareness 

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.

 

7. Consent

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.

 

8. Children

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.

 

12. International

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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