The General Data Privacy Regulations, GDPR, are less than a year away. Businesses around the world actively participating in the markets of the European Union are scrambling to comply with the new law. We at Privacy Ref have been looking at how to best assess an organization’s readiness for compliance with the different articles of GDPR and have found an easy to understand way to meet this challenge.
Know what matters
The best way to minimize inefficiency in an assessment is to define the scope before anything else. Some parts of your business may not be required to meet GDPR’s requirements because they do not handle personal information coming from, or concerning a data subject in the EU. These areas of a business can be passed over until the other parts that are more directly affected, those that have more risk, are researched.
Now that you know what is being checked, review any policy, notice, or formalized privacy procedures that you can. Also review organizational documents such as organizational charts, codes of conduct, employee handbooks, and privacy-related training materials to name a few. These artifacts provide insight into how the organization operates as well as the baseline for the assessment.
Compare the documents to GDPR requirements and look for areas that require adjustment to be compliant. Once this is done, it is time to speak to the key individuals identified within the organization.
Discuss their daily activities, what kind of data they handle, where that data came from or is stored, and check to see if they are compliant with policies. The individuals you meet with will span the organization’s operations. Marketing, IT, Human Resources, Finance, and Customer Service will be important to speak with, but the departments touched will vary by organization. Special attention should be paid to any functions that are a shared service across lines of business. Compare the answers of the interviewees against the policy and GDPR; you can then start the heavy lifting of the assessment.
Applications and Processes
The different programs and processes that are used daily all consume, or rather utilize, data to work. This can be as simple as processing a data subject’s address to ship out their order. You want to check each of these processes or programs individually and compare them to the GDPR. What kind of data do you use? Does this process respect the rights of a data subject? These are some of the questions you need to ask.
At Privacy Ref we have constructed an GDPR Compliance Workbook that facilitates gathering the status of compliance with GDPR requirements and noting evidence of that status.
Each requirement is identified for status by topic. In some cases the same requirement’s status is gathered multiple times. For example, how the right to be forgotten is implemented in one application may be different than how it is implement in another and may be different from the guidance given by the Data Protection Officer. The requirement must be viewed from each of these perspectives.
Preliminary and Final Conclusions
Once you have all your findings you need to analyze them. See where you are strong and where you need to improve your compliance with the law. From there, you need to begin creating a plan of attack, a road-map, for how you want to further develop your program. Prioritize the biggest tasks and worry about minor details as you go. You will find that by handling the big fish first, the smaller details get fixed as an indirect result.
At Privacy Ref, our assessments always includes identifying the gaps you will need to fill to be compliant as well as a risk-based list of recommendations on how to proceed to close those gaps.