GDPR compliance in 10 clear steps

1. 1

   Document the legal basis for data processing

2. 2

   Create a record of processing activities

3. 3

   Conduct a risk assessment

4. 4

   Implement technical and organizational security measures

5. 5

   Prepare documentation for internal processing

6. 6

   Review and conclude data processing agreements

7. 7

   Structure data transfers to third countries in a legally sound way

8. 8

   Ensure data subject rights (access, erasure, objection)

9. 9

   Prepare data breach emergency procedures

10. 10

    Appoint a data protection officer where required

A note on step 10: Appointing a data protection officer is not mandatory for every business. Under Article 37 GDPR and section 38(1) BDSG, it is required only where at least 20 people are, as a rule, permanently engaged in the automated processing of personal data. Regardless of that headcount, large-scale monitoring of data subjects or the processing of special categories of data under Article 9 GDPR can trigger the obligation. Below those thresholds, appointment is voluntary.