Preparing for GDPR – 12 steps to take now

The Information Commissioner’s Office (ICO) have produced a checklist highlighting 12 steps you should take now to prepare for the  new General Data Protection Regulations (GDPR) which will apply from May 25th 2018.


The twelve steps are as follows:


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. Individuals’ 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 information. 


6. Lawful basis for processing personal data


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 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 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 (i.e. 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. 


Information above quoted directly from “Preparing for the General Data Protection Regulation (GDPR): 12 steps to take now V2.0 20170525”


You can download the full guide from the ICO’s website here.