Implementing the General Data Protection Regulation (GDPR) and translating the complex GDPR requirements into practice can be challenging for any organization. Even with extensive knowledge of GDPR, it can be difficult to know where to start and end and create the necessary overview to ensure GDPR compliance.
We have prepared five simple steps to create a GDPR action plan to make the process more manageable and comprehensible.
Map personal data and workflows
An essential first step towards GDPR compliance is to gain a comprehensive overview of data within your organization. This involves identifying and understanding the various types of data you process. Ensuring that you have the necessary security measures and processes is crucial.
By mapping and creating an overview, it becomes easier to compare your current data protection practices with GDPR requirements and identify gaps in your GDPR efforts. For instance, you might uncover situations where data is retained beyond the permitted duration or realize that you are not employing an appropriate legal ground for data processing.
The GDPR process is a team process: Select the people involved
To gain a comprehensive insight into all data across the organization, you should assemble a team of experts responsible for conducting the mapping. Unless your organization is very small, it is unthinkable that one person would possess enough knowledge about all organizational processes to ensure 100% compliance. The size of the GDPR team should, therefore, be determined based on the organization's size and complexity.
In addition to mapping and identifying gaps, the team will assist with the implementation process and ensure that all changes are GDPR compliant, which entails documenting and recording everything.
Documentation of your GDPR efforts is crucial to ensure your actions are visible and verifiable. At the same time, it shows that appropriate procedures, policies, and security measures are implemented to protect personal data. Without this, even the best intentions and initiatives may lose their value, at least in the eyes of the Data Protection Agency.
Appoint a Data Protection Officer
Besides assembling a team, it is also a requirement for some organizations to designate a specific person - a so-called Data Protection Officer (DPO) - whose primary focus is to advise, guide, and monitor compliance with data protection regulations.
The DPO is the link to senior management and the Data Protection Agency and is responsible for handling and developing the organization's data position.
Data Protection: Use of software for GDPR
Investments in software and external expertise play a crucial role in GDPR compliance. For example, there are requirements on how an organization should encrypt and anonymize personal data. You should also consider whether the method you use to document your efforts is adequate.
Many organizations may use Excel as a tool for this purpose due to its familiarity, but it can pose challenges with compliance. Excel is not the most suitable tool and may have limitations concerning GDPR requirements.
By choosing a specialized software solution for GDPR, you can effectively meet the dynamic and complex demands of GDPR. This provides you with better control, automated processes, and reliable management of the GDPR overview.
GDPR Compliance Culture: Create a Common Understanding of the Proces
All employees must be involved in the work with GDPR to ensure that your organization becomes compliant. Data permeates the entire organization, and the task must be tackled collectively to avoid vulnerabilities.
Creating the right mindset and understanding among those involved is necessary to implement the necessary processes and measures in everyday work. Implementing a comprehensive cultural change for GDPR compliance requires integrating GDPR into goals, strategies, processes, and decisions.
This includes, among other things:
- Communicating about GDPR across hierarchies and departments.
- The cultural change starts within the management group.
- Developing a communication and training plan.
Schedule regular updates
GDPR is not a static process but a dynamic approach to personal data protection. It is a never-ending story; you and your colleagues must continuously work on it. And if the past years have shown us anything, there are constantly emerging new levels to consider in the form of guidelines and decisions - such as the Schrems II ruling.
Therefore, it is crucial to stay ahead by planning regular updates of policies and processes. As an organization, you need to establish a mechanism for how you want to handle this and how you want to inform the responsible parties when an update is due.