When the GDPR came into force in May 2018 it introduced the principle of accountability – the data protection rule that requires you to be able to demonstrate you’re compliant. And whilst lots of businesses put in the effort to ensure they were compliant by the May deadline, GDPR compliance didn’t stop there.
Article 24 of the GDPR sets out that data controllers must not only be able to have put measures in place to ensure GDPR compliance but also that “those measures shall be reviewed and updated where necessary.“
So this brings us round to GDPR in 2019. May will mark the first anniversary since GDPR was introduced and a time where all the hard work you put in last year needs reviewing. Whilst we’ve seen, certainly in the UK, no GDPR enforcement actions to take into consideration this doesn’t mean you shouldn’t be checking your existing compliance is still up to scratch.
- A review of your data processing activities
- A review of your company data protection policies
- A review of your privacy policies
- Refresher training for your staff
- A review of third-party processor agreements
- A review of your DPIA
- A review of where data is being processed (non-EU data transfers)
- A review of other documentation (breach records, SAR, etc.)
- Carrying out spot checks to make sure internal processes are working
- Check your ICO registration is current and up to date
In terms of frequency of reviewing your compliance, yes there is an element of making sure you’re always compliant (being mindful of what to do if a breach occurs or your receive a subject access, for example, which could happen at anytime), but the main gist of your compliance should really be looked at, at least once a year. You won’t necessarily need to get a consultant or a lawyer in to conduct a full-on audit, but you should be assessing your internal processes, documents and approach and this something you can probably do in-house.
This is the focus of our new eBook: A Framework for ongoing GDPR compliance. In the eBook we set out the ten key areas you should be reviewing each year to make sure you’re still compliant and you can use the framework to structure your internal review.
So, what are you doing to make sure you’re still compliant?