Protect your organisation from data protection risks and fines by completing a GDPR audit. Compliance is an ongoing data protection requirement and as organisations evolve, how they collect and use personal data changes. Audits can help you identify non-compliance or areas requiring improvement so you comply with data protection legislation.
We recommend organisations conduct GDPR audits annually to ensure they are up to date with compliance and changes relating to the use of personal data within the organisation.
Preparation at the start of any GDPR audit will save time. Reading this step by step guide to completing a GDPR audit will give you confidence that your GDPR audit will be thorough and support your ongoing data protection programme.
Take the uncertainty out of your next GDPR audit by following these steps
1. Understand the GDPR requirements
Familiarise yourself with the key aspects of the GDPR, including the relevant data protection principles, rights of data subjects, data processing requirements, and security measures. If this is a focussed audit on a specific area, familiarise yourself on all the relevant GDPR requirements and any specific nuances for that type of processing or use of the personal data.
2. Form an audit team
Assemble a team with cross-functional expertise on the privacy areas you are assessing, for example this may include someone from legal, data governance, AI, IT, HR, marketing, etc. A key member of this team should be your data protection officer or other person responsible for data protection compliance.
3. Conduct data mapping
Identify and document all data processing activities, including data collection, storage, and sharing across departments and systems. Understand which entities are responsible for data processing, both within your organisation and with third-party processors or other controllers.
4. Assess legal basis for data processing
Evaluate and ensure that the correct legal basis has been chosen for the processing of the personal data and make sure you comply with the specific requirements for using that legal basis. For example, if you rely on consent, make sure that consent is obtained in accordance with the GDPR and other laws if applicable, for example, The Privacy Electronic Communications Regulations 2003 (PECR). Ensure details of the data processing being reviewed is added to the record of processing activities (also known as the ROPA).
5. Evaluate data subject rights compliance
Check that procedures are in place to handle data subject rights requests. Ensure that individuals can easily exercise their data subject rights. Ensure that your GDPR audit checks the application of the data subject rights and how your organisation handles these. Also review policies, procedures and processes in place for handling data subject rights.
6. Review data processing agreements and GDPR clauses
Ensure that all contracts with third-party vendors who process personal data on your organisations’ behalf as a “processor” include GDPR-compliant clauses and full details of the personal data being processed. For any cross-border data transfers, ensure that appropriate safeguards, for example, Standard Contractual Clauses or Binding Corporate Rules are in place.
7. Examine data breach management processes and procedures
Ensure that processes are in place for detecting and handling personal data breaches within the mandatory 72 hour time period. Review your organisation’s policies, procedures and templates and ensure these are tested regularly.
8. Review data retention policies
Ensure that personal data is retained for no longer than necessary and that there are clear data retention and deletion policies in place. Review if these are followed and personal data is being deleted or anonymised when no longer needed.
9. Data protection by design and default
Ensure privacy is embedded into business processes. Review templates for data protection impact assessments (DPIAs). Look at if DPIAs are being carried out, reviewed and maintained to ensure they stay up to date. Review business processes to see when the need for a DPIA is highlighted and a DPIA undertaken. Check that by default only the minimum amount of personal data is being processed and that individuals have control over the use of their data where possible.
10. Train employees and raise awareness
Review any training requirements in place in relation to data protection and the GDPR. Check that the training is offered on induction and regularly thereafter. Check if the training is tracked for completion. Also check to ensure employees who handle personal data in large volumes or where the personal data is sensitive have enhanced GDPR training.
11. Document findings
Keep detailed records of your audit findings, actions taken, and areas for improvement. Document these in a report template with clear actions for the business areas who own any privacy risks which have been identified.
12. Prepare a remediation plan
Based on the audit findings, implement corrective actions to address any gaps or non-compliance issues. Assign owners for any privacy actions and make sure these are followed up to ensure that the privacy risks are mitigated.
By following these steps, you’ll ensure that your GDPR audit is thorough, compliant, and helps reduce the risk of non-compliance within your organisation.
Why not download our GDPR audit checklist?
With our free GDPR Toolkit you’ll find templates for you to customise during your GDPR audit. These will aid preparation of your own data protection programme. The documents do not constitute legal advice, if you’re unsure we’re here to help.
If you’d like an impartial view and timely management of your GDPR audit, our expert team can provide tailored audits for your organisation. From short GDPR audits into an area of concern, to full compliance audits of your organisation’s processing activities.
Contact us to discuss your requirements.
FAQs
How does my GDPR audit prove I’m compliant?
By completing a GDPR audit, this demonstrates your organisation is aware of their data protection obligations, and they are actively documenting and managing them alongside considering how they meet or need to meet those requirements.
Which stakeholders should I share my GDPR audit with internally?
Typically, this will depend on your organisation. You may want to share the outcomes of the GDPR audit with the senior leadership team, IT and security colleagues, heads of departments and of course your data protection officer or person responsible with data protection compliance should have access to the full audit details. We recommend sharing the GDPR audit with the team who the audit was carried out on first though to allow them a chance to confirm details in the GDPR audit are correct!
Can a GDPR audit be outsourced?
Yes, and sometimes this is better than an audit being carried out internally because with HelloDPO, when we carry out an audit it will be independent. Our team has the expertise and impartial point of view to conduct a thorough GDPR audit. If this is something you’d like support with, contact us so we can discuss your requirements.
