Our 2-part series highlights 12 key steps you can take now to prepare for the GDPR, the General Data Protection Regulation.
If you missed part 1 of our 2-part series you can read it here. Otherwise, read on for the next 6 key steps to help you achieve GDPR compliance…
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 Officer
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 (ie 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. 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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