Our 2-part series highlights 12 key steps you can take now to prepare for the GDPR, the General Data Protection Regulation.
First and foremost, don’t panic! Many of the GDPR’s main concepts and principles are much the same as those in the current Data Protection Act (DPA), so if you are complying properly with the current law then most of your approach to compliance will remain valid under the GDPR and can be the starting point to build from. However, there are new elements and significant enhancements, so you will have to do some things for the first time and some things differently.
The GDPR places greater emphasis on the documentation that organisations must keep to demonstrate their accountability, and this requires organisations to review their approach to governance and how they manage data protection as a corporate issue. One aspect of this might be to review the contracts and other arrangements you have in place when sharing data with other organisations.
It is essential to plan your approach to GDPR compliance now and to gain ‘buy in’ from key people in your organisation. You may need, for example, to put new procedures in place to deal with the GDPR’s new transparency and individuals’ rights provisions. In a large or complex business this could have significant budgetary, IT, personnel, governance and communications implications.
You should make sure that decision makers and key people in your organisation are aware that the law is changing to the GDPR. It’s important 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.
Further information and resources
As well as our 2-part checklist, there is a range of resources available from the Information Commissioner’s Office (ICO) to help you compare the current law with the GDPR. The ICO has produced new guidance and tools to assist you, as well as contributing to guidance that the Article 29 Working Party is producing at the European level. These are all available via the ICO’s Overview of the General Data Protection Regulation. Look out for part 2 shortly…
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