GDPR Compliance Checklist: 10 Steps to Protect Personal Data & Stay Compliant 

The General Data Protection Regulation (GDPR) is one of the most significant data privacy laws in the world, affecting businesses that collect and process personal data. Whether you’re operating within the European Union (EU) or handling EU residents’ data from another country, GDPR compliance is essential to protect user privacy and avoid hefty fines. A GDPR compliance checklist is a crucial tool for businesses to navigate the complexities of GDPR compliance, helping them assess their compliance status, manage personal data responsibly, and mitigate risks associated with data breaches and non-compliance penalties. 

In this guide, we’ll break down what GDPR compliance entails, who it applies to, and the steps businesses need to take to align with the regulation.

What is GDPR Compliance?

GDPR compliance refers to adhering to the EU General Data Protection Regulation, which governs how organizations collect, process, and store personal data. The regulation is designed to:

• Safeguard personal data by enforcing strict security measures
• Ensure transparency about how businesses use customer data
• Empower individuals to control their personal information

Compliance also necessitates proactive measures, such as conducting a Data Protection Impact Assessment (DPIA), particularly when processing sensitive data.

Failure to comply with GDPR can result in severe penalties, with fines reaching up to €20 million or 4% of annual global revenue—whichever is higher. (Data according to gdprinfo.eu)

What is Considered Personal Data Under the EU GDPR?

GDPR defines personal data as any information related to an identifiable person. This includes:

• Direct identifiers: Names, email addresses, phone numbers
• Indirect identifiers: IP addresses, location data, and online behavior
• Special categories of data: Health records, biometric data, racial or ethnic origin, religious beliefs, and sexual orientation, which require extra protection

Understanding personal data processing is essential to ensure lawful and responsible handling of personal data, ultimately building trust with users and enhancing brand reputation.

Who Does the GDPR Apply To?

The GDPR has a broad reach, applying to:

1. EU-based organizations processing any personal data
2. Non-EU organizations that collect, store, or process data of EU residents (e.g., a U.S. e-commerce company selling to customers in Germany)

 GDPR compliance is mandatory for organizations that process the personal data of individuals residing in the EU, regardless of where their company is located.

Data Controllers vs. Data Processors: What’s the Difference?

GDPR distinguishes between:

• Data Controllers – Determine the purpose and method of processing personal data
• Data Processors – Handle data on behalf of a controller

 Both controllers and processors must adhere to strict data protection obligations and can be held accountable for non-compliance. Controllers are responsible for ensuring that their processors comply with GDPR, making robust vendor risk management and due diligence essential.

Data Mapping and Inventory

Conduct Data Mapping to Understand Data Flows

Data mapping is a crucial step in understanding how personal data flows through an organization. It involves creating a visual representation of the data flows, including the sources, storage, and processing of personal data. This helps organizations identify potential risks and vulnerabilities in their data processing activities.

To conduct data mapping, organizations should follow these steps:

1. Identify the types of personal data collected, processed, and stored: Start by cataloging all the personal data your organization handles. This includes direct identifiers like names and email addresses, as well as indirect identifiers such as IP addresses and location data.
2. Determine the sources of personal data: Identify where the data comes from, whether it’s collected directly from data subjects, obtained from third parties, or generated internally.
3. Map the data flows: Create a visual representation of how personal data moves through your organization. This includes how data is transmitted, where it is stored, and how it is processed.
4. Identify the data processors and data controllers involved: Determine who is responsible for the data at each stage of its lifecycle. This includes both internal teams and external partners.
5. Assess the risks and vulnerabilities: Evaluate the potential risks associated with each data processing activity. This includes identifying any weak points in your data protection measures.

By conducting data mapping, organizations can better understand their data processing activities and identify areas for improvement to ensure GDPR compliance. This proactive approach helps safeguard personal data and mitigate potential risks.

Data Subject Rights

Provide Data Rights Provision

The GDPR provides data subjects with several rights, including the right to access, rectify, erase, restrict processing, object, and data portability. Organizations must provide data subjects with these rights and ensure that they are able to exercise them easily.

To provide data rights provision, organizations should follow these steps:

1. Implement a data subject access request (DSAR) process: Establish a clear process for handling requests from data subjects. This includes verifying the identity of the requester and responding within the required timeframe.
2. Provide clear and concise information: Ensure that data subjects are informed about their rights and how to exercise them. This information should be easily accessible, such as in your privacy policy.
3. Facilitate access and rectification: Make it easy for data subjects to access their personal data and request corrections if needed. This can be done through user-friendly online portals or dedicated support teams.
4. Implement a process for erasing personal data: When a data subject requests the deletion of their data, ensure that it is promptly and securely erased from all systems.
5. Restrict processing upon request: If a data subject requests to restrict the processing of their data, ensure that this is implemented without delay.
6. Provide the right to object and data portability: Allow data subjects to object to certain types of processing and to request the transfer of their data to another organization.

By providing data rights provision, organizations can ensure that they are respecting the rights of data subjects and complying with the GDPR. This not only builds trust with customers but also helps in avoiding potential fines and penalties.

International Data Transfer

Ensure Compliant International Data Transfer

The GDPR regulates the transfer of personal data outside the European Union (EU) and the European Economic Area (EEA).  Organizations must comply with GDPR when transferring personal data internationally. To ensure a compliant transfer, they should follow these steps:

1. Determine the destination country: Identify the country or countries to which personal data will be transferred. This is crucial as different countries have varying levels of data protection.
2. Assess the level of protection: Evaluate the data protection measures in place in the destination country. This includes understanding the local data protection laws and any adequacy decisions by the European Commission.
3. Use standard contractual clauses (SCCs) or binding corporate rules (BCRs): These legal tools help ensure that personal data transferred outside the EU is protected to the same standard as within the EU.
4. Implement additional safeguards: Enhance data protection by using measures such as encryption and pseudonymization. These techniques help protect personal data during transfer and storage.
5. Obtain consent from data subjects: Before transferring personal data internationally, ensure that you have obtained explicit consent from the data subjects. This consent should be informed and freely given.
6. Keep records of international data transfers: Maintain detailed records of all international data transfers. This includes documenting the legal basis for the transfer and any safeguards implemented.

By ensuring compliant international data transfer, organizations can avoid violating the GDPR and facing significant fines and penalties. This proactive approach helps maintain the trust of data subjects and protects personal data across borders.

10-Step Checklist to be GDPR-Compliant

To achieve GDPR compliance, businesses must follow a structured approach. Here’s a step-by-step checklist to guide you:

1. Know All of the Data Your Business Collects

Conduct a data audit to:

• Identify what personal data you collect
• Determine where and how it is stored
• Classify data as personal or sensitive

This helps ensure compliance with data minimization principles—only collecting what’s necessary.

2. Appoint a Data Protection Officer (DPO)

If your business processes large amounts of sensitive data, appointing a DPO is required. The DPO:

• Monitors GDPR compliance
• Conducts internal audits
• Advises on data protection best practices

3. Create a GDPR Diary

A GDPR diary (data processing log) tracks:

• Data collection purposes
• Legal bases for processing
• Retention periods

Keeping detailed records demonstrates accountability to regulators.

4. Evaluate Your Data Collection Requirements

Under GDPR, businesses must ensure they:

• Only collect necessary data
• Have a lawful basis for data processing
• Inform users why their data is being collected

5. Instantly Report Data Breaches

Organizations must report data breaches within 72 hours to authorities and, in some cases, affected individuals. A robust incident response plan is essential for compliance.

6. Be Transparent About Data Collection Motives

Businesses must provide clear privacy policies that detail:

• What data is collected
• How it is used
• Who it is shared with

Users should always be informed about their rights.

7. Verify the Ages of All Users Consenting to Data Processing Activities

GDPR mandates age verification for minors. Businesses must ensure:

• Parental consent for users under 16 (or the applicable age in EU countries)
• Age verification mechanisms to prevent non-compliant data collection

8. Include a Double Opt-in for All New Email List Sign-Ups

A double opt-in process ensures users explicitly consent before being added to mailing lists. This helps:

• Reduce spam complaints
• Strengthen compliance with GDPR’s consent requirements

9. Keep Your Privacy Policy Updated

Regularly review and update your privacy policy to reflect any changes in:

• Data collection methods
• Processing purposes
• Third-party relationships

Users must be notified of material changes to the policy.

10. Regularly Assess All Third-Party Risks

If your business works with third-party vendors, assess their GDPR compliance by:

• Reviewing Data Processing Agreements (DPAs)
• Conducting third-party audits
• Ensuring they follow GDPR security standards

Shared Assessments Helps Businesses Remain GDPR Compliant

Achieving and maintaining GDPR compliance is an ongoing process that requires continuous effort. Partnering with compliance experts ensures your organization meets the highest data protection standards while effectively mitigating risks.

At Shared Assessments, we support businesses by providing:

• Tailored Third-Party Risk Management Solutions: Our Standardized Information Gathering (SIG) Questionnaire enables organizations to build, customize, analyze, and store vendor assessments, streamlining the third-party risk assessment process. ​
• Data Governance Tools: Our Data Governance Products assist in identifying, tracking, and monitoring the use and disclosure of personal data to third and fourth parties, helping organizations address specific data protection obligations.
• Thought Leadership and Training: We offer resources and training courses to ensure continuous data protection and compliance and to adapt to evolving regulations and emerging risks.​ 

By leveraging tools like the SIG Questionnaire and Data Governance Products, organizations can enhance their data privacy strategies and maintain robust GDPR compliance.

Explore how Shared Assessments products, education, and membership can assist you in navigating the complexities of remaining GDPR compliant.