On 25 May 2018 most processing of personal data by organisations will have to comply with the General Data Protection Regulation (GDPR). Preparing for the general data protection regulation – 12 steps that you should take now
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 net you may need to organise an information audit
3. Communication privacy information – you should review your current privacy notices and put a plan in place for making any necessary changes in time for the GDPR Implementation
4. Individuals Rights -You should check your procedures to ensure they cover all the rights of individuals. Including how you would delete Personal Data or provide Data Electronically 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 of Your Processing activity in the GDPR, documented 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 do not 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 do 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 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 (That Is 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.
