GDPR Compliance Audit

GDPR Audit is an evaluation process examining organization compliance to the GDPR Regulation. The General Data Protection Regulation Act is a privacy law developed to protect the personal data of citizens of the EU. With the enforcement of this regulation, organizations are expected to comply with GDPR requirements and take the necessary steps to achieve compliance.

That said, organizations are now steadily making progress in implementing the legal requirements of GDPR. However, translating these legal requirements are seen as a huge challenge for most businesses. This is mainly due to the lack of knowledge and understanding of the regulation and its requirements.

So, to make things simpler for organizations, we have shared an easy guide that provides direction to organizations for a successful GDPR Audit process and to ultimately achieve Compliance. But, before that let us first understand what GDPR audit is to understand its process better.  

What is GDPR Audit?

GDPR Audit is an evaluation process that involves identifying key risks and gaps within an organization’s process, procedures, and policies concerning the GDPR Regulation.  Based on these audit findings, the organization is recommended the future course of action to close these gaps and mitigate the identified risks.

Implementing necessary measures, appropriate processes, procedures, and policies that include monitoring of personal data, controls to prevent data breaches, training staff on GDPR regulations are some of the most crucial aspects of ensuring a successful audit process and GDPR Compliance. Interestingly, GDPR also has specific requirements for online platforms. So, this audit process also covers the working of these online platforms as per GDPR requirements.

Why is GDPR Audit Important?

GDPR Compliance is a complex regulation difficult to achieve. However, once achieved companies will need to regularly conduct an internal GDPR Audit to assess their level of compliance. Not only will the audit help identify and bridge gaps but also the documentation of these audits must be vital in the event of a breach to demonstrate the organization’s efforts of compliance.

This can also possibly help reduce the severity of the penalty levied on them. Besides, the audit process ensures accountability and constant monitoring of the organization’s privacy and compliance program. Compliance is an ongoing process which is why the program needs to be re-visited and evaluated to ensure organizations remain compliant.

GDPR Audit will ensure processes are in place and organizations are making every effort to oblige to consumer’s rights under the GDPR. So, here is a guide for organizations to follow for a successful audit process. 

Guide to follow for a successful GDPR Compliance Audit

GDPR Compliance requires an understanding of the regulation and implementation of the legal requirements outlined in the regulation. So here is what an organization is expected to do to ace the GDPR Audit process.

Scope of GDPR Compliance 

Determine the scope of compliance is essential in a compliance audit. Further, determining the personal data of citizens of the EU taking into account all the data processing in activity in the organization be it as a data controller or as a data processor is also essential. For organizations to determine the scope of compliance, they also need to identify all the databases that hold personal data.

The regulation defines personal data as any data involving the personal data of citizens of the EU. Organizations are also required to identify any cross-border processing activity as GDPR Regulation applies to any business irrespective of their business location if involved in processing personal data of EU citizens.

Determine & Map Personal Data

Determining the categories of personal data you process is crucial for compliance. It is also essential for organizations to understand where the data comes from, and document the purpose of its collection, use, and processing activity. Organizations are also expected to map the flow of personal data through their organization and identify individuals who have access to it.

This provides a clear direction for organizations to prioritize their security measures to protect systems and networks that hold such sensitive data. Data mapping is an integral part of any GDPR Audit and should be documented for future reference. 

Current Compliance Status 

Evaluating the current compliance status is crucial. Organizations need to determine the extent to which the data protection measures and controls are implemented to identify the gap. Examining and monitoring compliance is essential for it helps identify and bridge gaps.

Organizations should always plan a GDPR internal audit to identify gaps in the compliance status and requirements of GDPR.  This gives the organization a clear direction towards the implementation of appropriate measures. This will further ensure a smooth audit.

Appoint Data Protection Officer (DPO)

Appointing a Data Protection Officer who is also known as a DPO is essential in GDPR Compliance.  A DPO can be an existing employee or an externally appointed individual who has a good background in data protection requirements and regulations.

DPO can help demonstrate compliance and ensure accountability in the organization. They assist in monitoring internal compliance, inform and advise on various data protection obligations, and offer advice on Data Protection Impact Assessments (DPIAs). They also act as a single point of contact for data subjects and the Information Commissioner’s Office (ICO). 

Establish Policies and Procedures

Organizations must understand the regulation and its requirements to accordingly develop policies and procedures around the GDPR Regulation. Establishing appropriate policies and procedures is crucial as it facilitates uniform enforcement of security controls and measures that protect personal data. So, the organization must carefully develop policies and procedures that are aligned with the compliance requirements and also the business goals to ensure compliance.  

Define Roles and Responsibilities 

Organizations must clearly define the roles and responsibilities of individuals who are directly or indirectly involved in protecting personal data. Not just that, organizations must also conduct awareness and training programs for employees to educate them about their responsibilities and explain the consequences of not adhering to the requirements. All of this needs to be documented to ensure a smooth GDPR Audit process .

Data Protection Impact Assessment

Data Protection Impact Assessment (DPIA) is a type of risk evaluation process that helps identify and minimize risks relating to personal data processing activities. Organizations must conduct DPIA to measure the efficiency and effectiveness of the security measures implemented for securing personal data.

DPIA must be conducted before the beginning of any data processing activity, at the planning stages of a new project. Conducting regular DPIA supports GDPR Regulation and its accountability principle.

Personal Information Management System (PIMS)

GDPR calls for a wide range of documentation required to ensure that your organization is effectively implementing measures and demonstrate compliance with the GDPR.  The organization needs to have in place a Personal Information Management System to address issues including documenting data protection policy, a data breach notification procedure, subject access request forms, and procedures, DPIAs and consent forms, etc. Further, the PIMS should also include processes that ensure conducting of regular staff training and awareness program for employees of the organizations.  

Information Security Management System (ISMS)

Adopting industry best practices for testing security, and established cybersecurity certifications, standards, and codes of practice is essential in GDPR Compliance. This can be achieved through the implementation of ISMS which will ensure appropriate technical and organizational measures are in place.

This will ensure the implementation of adequate security measures for personal data held in hard copy or electronic form, or processed through your organization’s systems.  It is also important to note that a regular review of such systems and practices is crucial for business. 

Processes to Oblige Data Subjects Rights 

The organization will need to have in place processes to ensure Data Subject Rights are met. Establishing appropriate procedures and processes is essential to enable both facilitating and responding to data subjects exercising any or all of their rights, including the right to access, right to rectification, right to erasure, right to restrict processing, right to data portability, to name a few.  

Conclusion

We strongly recommend organizations take the help of a professional consultant in ensuring a smooth GDPR Audit process. While there may always be a temptation and an inclination towards getting the issues fixed or resolved internally, but having an external perspective is essential to ensure that the audit carried out is thorough.

Experts like us at VISTA InfoSec have the experience and knowledge to guide organizations in their efforts of compliance. We work as an extension of your team and help you bridge identified gaps in the GDPR Audit findings. To our credibility, we have helped numerous multinational companies around the globe with their GDPR compliance program. Our team will help you cover every aspect of the GDPR Audit process and provide appropriate remediation to fix gaps and make compliance achievable. 

Narendra Sahoo
Narendra Sahoo

Narendra Sahoo (PCI QSA, PCI QPA, CISSP, CISA, and CRISC) is the Founder and Director of VISTA InfoSec, a global Information Security Consulting firm, based in the US, Singapore & India. Mr. Sahoo holds more than 25 years of experience in the IT Industry, with expertise in Information Risk Consulting, Assessment, & Compliance services. VISTA InfoSec specializes in Information Security audit, consulting and certification services which include GDPR, HIPAA, CCPA, NESA, MAS-TRM, PCI DSS Compliance & Audit, PCI PIN, SOC2 Compliance & Audit, PDPA, PDPB to name a few. The company has for years (since 2004) worked with organizations across the globe to address the Regulatory and Information Security challenges in their industry. VISTA InfoSec has been instrumental in helping top multinational companies achieve compliance and secure their IT infrastructure.