It’s been two years since the GDPR (General Data Protection Regulation) took effect, and despite many people saying it was a lot of fuss over nothing, it has had a significant effect on the way organisations operate.
For one, DSARs (data subject access requests) spiked, meaning organisations need an effective way of storing personal data and ensuring that it’s accurate, up to date and that information is kept to a minimal.
Perhaps more significantly, authorities have started enforcing the Regulation, and have issued more than €48 million (about £43 million) in 2020 alone.
So, if you want to be sure that your organisation is complying with the GDPR, what should you do? Here are four key areas you need to consider.
1. General compliance
The GDPR includes 99 articles with hundreds of individual legal requirements, some of which only apply to some organisations, or only in certain circumstances, so it can be difficult to really gauge whether you are meeting your obligations.
A gap analysis guides you logically through all the Regulation’s relevant requirements to identify which ones you are meeting and where you are falling short.
It gives you instant visibility of your current compliance status and enables you to easily identify the actions you need to take to protect personal data and comply.
A DSAR is a request from a data subject – whether a customer, partner, supplier, employee or other stakeholder – for a copy of the personal data you hold and process about them.
Under the GDPR, you must respond to a DSAR within one month and for free – and you must make sure that you can demonstrate that you have met this obligation. Clearly, then, it makes sense to have a consistent and – where possible – automated means of responding to DSARs.
The gap analysis may identify this as an area you need to work on. The point is that, to achieve ongoing GDPR compliance, you need to ensure that every new DSAR is treated properly.
3. Breach reporting
GDPR compliance requires you to keep a record of all breaches and incidents involving personal data that occur within your organisation, and it’s valuable to streamline how you report these to your supervisory authority.
Again, the gap analysis may identify this as an area you need to work on, but to maintain ongoing GDPR compliance, you need to ensure that your recording and reporting processes are adhered to every single time.
4. Third-party management
It is important to remember that the chain of responsibility for GDPR compliance stretches beyond the boundaries of your organisation to any third-party partners or suppliers that are involved in processing personal data. You need to be able to monitor these and ensure that they are contributing to, not damaging, your own GDPR compliance.
Only by taking a logical approach to all four of these areas can you be sure that your organisation is truly GDPR compliant – and only by reviewing them on a dynamic, continual basis can you be sure that you are maintaining compliance.
That is why we launched CyberComply, which guides organisations through cyber risk and privacy management monitoring and compliance in a scalable, repeatable and maintainable way.
The platform brings together our five popular privacy and risk management tools, so you have everything you need in one place for governance, risk management and compliance.
A version of this blog was originally published on 13 May 2019.