15 November 2017
Every organisation that processes personal data must be compliant with new General Data Protection Regulations (GDPR) that come into effect on 25 May 2018, including charities and voluntary organisations. Getting to grips with GDPR can be daunting and it can be difficult to know where to start, so we have drafted a 12 point plan, adapted from the Information Commissioners Officer (ICO) guidance, to help you take the right steps.
Make sure that decision makers and key people within your organisation are aware that the law is changing. They need to understand what GDPR means and appreciate the impact that the new regulations are 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 may need to organise an information audit.
3. Communicating privacy information
You should review your current privacy notices and put a plan in place for making any necessary changes in time for GDPR implementation.
4. Individuals’ rights
You should check your procedures to ensure they cover all the rights individuals have, including how you would delete personal data or provide data electronically and 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, as well as providing any additional information.
6. Lawful basis for processing personal data
Ensure you have a lawful basis for your data processing activity (eg. explicit consent from an individual), document it and update your privacy notice to explain it.
You should review how you elicit, record and manage consent and whether you need to make any changes to this process. Refresh any existing consent that you have now if they do not meet the new standards set out by GDPR.
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 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 latest guidance when it comes to GDPR, and identify when this should be implemented within 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’s structure and governance arrangements. You should consider whether you are required to formally designate a Data Protection Officer.
If your organisation operates in more than one EU member state (ie. you carry out cross-border processing), you should determine your lead data protection supervisory authority.