Today’s guest post is by Ken Lynch from Reciprocity Labs
Recently, the General Data Protection Regulation (GDPR) went into effect. The GDPR is a framework put forth by the European Union (EU) that sets guidelines on the collection and processing of personal information. The aim of this framework is to protect the rights of individuals and oversee the management of personal data.
If your company deals with data of EU citizens, then you will have to comply with GDPR. According to Article 3 of the GDPR, other instances that might require you to comply with GDPR are: when your company operates or is established in the EU, when your organization is monitoring the behavior of EU residents or when you are offering products to EU citizens. Essentially, if you do any marketing, prospecting, or business in the EU, you should strive to ensure that it is in compliance with GDPR.
The GDPR regulation will greatly impact your organization, since you will have to make several changes to your processes and business functions to meet the new standards. GDPR compliance is an ongoing effort. What follows are six steps you should take to ensure that your organization becomes and stays compliant with GDPR.
A Step-by-Step Guide on How to Comply with GDPR
Now that you understand the key details about GDPR, there are several steps that you should take to comply with GDPR:
1. Come up with a GDPR team
You’ll need to appoint a Data Protection Officer (DPO), who will be in charge of your GDPR team . Basically, this team should access all the data sources in your organization. They should investigate and conduct an audit on the storage and usage of personal data. It is crucial to determine the risk of exposure to privacy in your company. In addition, the GDPR team helps to access privacy controls, correct the deficiencies of the controls, conduct the necessary training and manage data breaches that may occur.
2. Identify sources of personal data
Your GDPR team should access all inventory assets and applications that transmit, process, or store personal data. Your team should also categorize and label any source that has personal data. It is important to list the data processing activities since it will make the process of compliance much easier.
3. Governance and compliance accountability
Your GDPR team should train your employees and third-party contractors on how the GDPR defines personal data and the primary ways that relates to your organization. This team also has to come up with privacy rules for determining who should access personal data, the nature of data to be accessed, and the usage of the personal data.
Additionally, the GDPR team has to access all your third-party processors. This will ensure that you have modified the processes and agreements you have with these parties to be in accordance with GDPR compliance. You should screen contractors regularly and fully document the engagement documents that follow the requirements set by the GDPR. It is also important to provide periodic GDPR notices that train them and increase their awareness about GDPR rules and how to act accordingly.
4. Protect data and address data breaches
One of the easiest ways to protect personal data is to delete data that is no longer in use. You can also review, create, and update privacy policies according to GDPR requirements. It is crucial to review the privacy policies to see if they are complying with GDPR.
Also, the privacy policies and consents have to follow GDPR compliance. Your company should record and manage those consents so that they can be proven as evidence. If the consents need to be updated, they have to be simple and transparent.
You will also need to outline the measures that you will take to handle data breaches. These measures should include detecting the breaches early, reporting, management, and investigation. It is crucial that you review these data breach procedures to involve timely protocols that meet the notification requirements for people and EU supervisors.
5. Conduct periodic data protection impact assessments
This means that you should assess your data sources regularly. You should also include technical measures that show that you are protecting all data processing activities in your company.
6. Ensure your vendors and data supply chain are GDPR compliant
If you receive leads or customer data from outside parties, it is your responsibility to ensure that that data and those customer lists are in compliance with GDPR before you contact anyone. Even if a lead came from a 3rd party, for example, if contacting them violates GDPR, you are still responsible.
You should incorporate tools that establish, manage, and monitor your GDPR program. More so, include GDPR requirements in your audits and monitoring tools that evaluate the effectiveness of the programs you’ve put in place. Evaluations indicate the changes that are needed in GDPR compliance, changes in the operations, regulations, review of the results, and the feedback.
Just like other organizations around the world, you will have to comply with the General Data Protection Regulation irrespective of the location of your organization.
Failure to comply with GDPR could cost you huge legal fees and fines. Worse still, it could taint your organization’s name and brand. The GDPR compliance process might seem to be overwhelming, but with the right tools you will be able to:
Show the regulators the nature and location of personal data.
Indicate that you have a proper data management process and consents from the individuals that are involved.
Prove how you use personal data, the people who use it and the purposes you use it for.
Demonstrate the procedures that you have put in place to handle data breaches.
Ken Lynch is an enterprise software startup veteran, who has always been fascinated about what drives workers to work and how to make work more engaging. Ken founded Reciprocity to pursue just that. He has propelled Reciprocity’s success with this mission-based goal of engaging employees with the governance, risk, and compliance goals of their company in order to create more socially minded corporate citizens. Ken earned his BS in Computer Science and Electrical Engineering from MIT. You can learn more at ReciprocityLabs.com.