GDPR Compliance Checklist
GDPR Compliance Checklist
I. Compliance Overview
Organizations can use this checklist to assess the GDPR compliance status of third-party vendors and partners with whom they share personal data, ensuring they adhere to the required standards.
Responsible Party: [YOUR NAME]
Date of Last Review: June 9, 2050
Next Scheduled Review: June 9, 2051
II. Vendor Assessment
-
Identify all third-party vendors and partners that handle personal data.
-
Check vendor contracts for GDPR compliance clauses.
-
Assess the necessity and proportionality of sharing personal data with each vendor.
III. Data Processing Agreement (DPA)
-
Ensure that a Data Processing Agreement (DPA) is in place with each vendor.
-
Verify that the DPA includes clauses required by GDPR Article 28.
-
Confirm the DPA details of both parties' data protection responsibilities.
IV. Data Security Measures
-
Evaluate the security measures implemented by vendors to protect personal data.
-
Verify encryption methods, access controls, and data breach response procedures.
-
Assess the physical and logical security of data storage facilities and systems.
V. Data Transfer Safeguards
-
Check if vendors transfer personal data internationally and evaluate their safeguards.
-
Ensure vendors follow GDPR rules for data transfers outside the EEA.
-
Review data transfer mechanisms like SCCs or BCRs.
VI. Data Subject Rights
-
Confirm that vendors have processes in place to fulfill data subject rights requests.
-
Ensure vendors meet GDPR response timelines for data subject requests.
-
Review data subject rights: access, rectification, erasure, and portability procedures.
VII. Data Breach Notification
-
Verify that vendors have procedures to detect, report, and investigate data breaches.
-
Ensure vendors report data breaches promptly and review response procedures.
VIII. Data Minimization and Retention
-
Limit vendors to collecting and processing only the necessary personal data.
-
Ensure vendors delete or anonymize unneeded personal data.
-
Review and ensure contract data retention complies with GDPR.
IX. Subprocessing Controls
-
Assess vendors' practices for engaging subprocessors and ensure GDPR compliance.
-
Ensure vendors get pre-approval before using subprocessors.
-
Review subprocessor agreements for GDPR compliance.
X. Privacy by Design and Default
-
Evaluate vendors' adherence to privacy by design and default principles.
-
Ensure vendors prioritize data protection and privacy in their products.
-
Review vendor DPIAs.
XI. Training and Awareness
-
Ensure vendors train employees on GDPR and data protection.
-
Verify that vendors maintain records of employee training and awareness activities.
-
Assess vendor communications for GDPR commitment.
XII. Auditing and Monitoring
-
Set up systems to audit and monitor vendor GDPR compliance.
-
Conduct regular assessments or audits of vendor practices and controls.
-
Review audit reports and address identified issues promptly.
XIII. Completion and Sign-off
By checking the box below, I acknowledge that I have reviewed and completed the GDPR compliance checklist for vendor management.
Completed by: [YOUR NAME]
Date: June 9, 2050
