Data Inventory and Mapping: Begin the GDPR audit by conducting a thorough data inventory and mapping exercise. Identify all types of personal data collected, processed, and stored by the organization. Determine the legal basis for processing each data type and the purposes for which the data is used. This includes data collected from customers, employees, vendors, or any other individuals. Ensure that the data flow is clearly documented, including data transfers within and outside the EU, and any third-party data processors involved. Identifying all data touchpoints within the organization is crucial to assess potential risks and compliance gaps.
Lawful Basis and Consent: Review the lawful basis for data processing to ensure that the organization has a valid reason to process personal data under GDPR. Evaluate whether consent has been obtained appropriately for data processing activities that require explicit consent. Assess the procedures for obtaining, recording, and managing consent from data subjects. Confirm that individuals have the right to withdraw their consent easily. Additionally, evaluate whether the organization has mechanisms in place to manage data subject requests related to access, rectification, erasure, and data portability. Compliance with data subject rights is a fundamental aspect of GDPR, and it’s essential to ensure that the necessary processes and documentation are in place.
Data Security and Breach Response: Evaluate the organization’s data security measures to protect personal data from unauthorized access, disclosure, or accidental loss. This includes reviewing technical and organizational security measures such as access controls, encryption, pseudonymization, and data minimization practices. Assess whether the organization has a robust data breach response plan in place, detailing the steps to be taken in the event of a data breach. Confirm that data breaches are reported to the relevant supervisory authority and, if necessary, to affected data subjects within the required timeframe. Additionally, verify that employees and other personnel handling personal data are adequately trained in data protection and GDPR compliance.
