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GDPR Checklist

These are all high-level items that are required or recommended to roll out in the E.U. or areas where GDPR is prevalent.
Last edited 716 days ago by Jamie Heindl.

Principles:

Lawfulness, fairness and transparency.
Purpose limitation.
Data minimization
Accuracy
Storage limitations
Integrity and Confidentiality
Accountability.
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Resources:

megaphone

Useful Resource:

megaphone
Trust Service Providers:

Checklist:

Item
Notes
Required
Expected
Suggested
Needs Review
Implemented

Legal and Regulatory Compliance







Record of Processing Activities (ROPA) documentation (Data Mapping and other processes for website, product and resource centers, etc.)
Should include all activities from the time the data is acquired through deletion. Includes what categories of data are processed, legal basis, how, why, where data is transferred and retention policies.





Data Protection Impact Assessment (DPIA)





Data Retention Policy





International Data Transfer (Standard Contractual Clauses, Binding Corporate Rules, etc.)





Security Audit Protocols Plan





Data Breach Response Plan





Develop and Implement Cybersecurity Policy
is the authority on this. This is very important considering the remote work environment.





Employee Training and Awareness Documentation and Plan





Establish confidentiality and access privilege protocols (need to know) access rights to housed data.





Data Privacy and Security (Website and Product)

GDPR Compliant Privacy Policy





Cookie Declaration





Explicit Consent for data collection on web and product





Data Portability Process





Cybersecurity threat analysis





Organizational and Staffing

Appoint a Data Protection Officer
Contingent on several factors - I believe if we intend on doing things as basic as marketing retargeting or tracking product behaviors we will fall into the "required" category. This needs to be vetted by someone who understand the finer details of this requirement.





Legal Advisor (Regional)
This person could also be the DPO





Requirements for local staffing?










Technology and Infrastructure

Consent Management and Cookie Banner
Website and Product





Method to notify and require acceptance of changes to policies, cookies, etc.
Website and Product





Data Center Locations





TLS Certificate (or SSL but TLS likely preferred)





Right to be Forgotten Implementation





Data Erasure Request Process (Support stations and Product)





User Data Encryption in transit and at rest
See Art. 32 GDPR Security of Processing





Establish ongoing testing schedules for security, processes, services and systems.





Simple Electronic Signature





Advanced Electronic Signature (AdES)
(See Detailed Requirements Here)
uniquely linked to and capable of identifying the signatory; created in a way that allows the signatory to retain control; linked to the document in a way that any subsequent change of the data is detectable. The most commonly used technology able to provide these features is the use of a public-key infrastructure (PKI), which involves the use of certificates and cryptographic keys





Qualified Electronic Signature (QES)
(See Detailed Requirements Here)
created by a qualified signature creation device; and is based on a qualified certificate for electronic signatures.










Contractual and Partner Management

Data Processing Agreements (as applicable) (PSPDFKit, FreshDesk/Sales, Sendgrid, etc.)










Risk Management and Insurance

Data Brach Protocols





Security Audit Protocols










Marketing and Customer Relations

Data Subject Request Handling
Product and Web










Financial Planning and Management

Establish Bank Accounts















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