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Preparing for the General Data Protection Regulation (GDPR)

1. Awareness


You should make sure that decision makers

and key people in your organisation are aware

that the law is changing to the GDPR. They

need 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 Individual's 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



6 Lawful basis


You should identify the lawful basis for your

processing activity in the GDPR, document it and

update your privacy notice to explain it.

7 Consent


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.

8 Children


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


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 officers


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

12 International


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.


© 2016 Harwood Brittain Technology Ltd


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