GDPR Implementation

Monitor

Monitor compliance Governance framework. Risk metrics. Processes. Support. Guidance. DPO. Training, awareness, audits. Regulation updates. Validate privacy strategy on regular basis.

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Build remediation plan

Build a timeline for actions to perform on the ground of the gap, risk and LOE analysis Final decisions regarding priorities taken in consideration with: The initial project scope. Initial goals. Budget. Resources. People involved and responsible. Priorities for high risk gaps. Provide for longer periods of time for actions ranked high LOE (Level of

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Prioritize objectives and tasks

Conduct Level of Effort (LOE) Analysis Identify remediation action for each gap and estimate Levels of Effort (LOE): Low, Medium, and High. Mapping the Risk Levels to the LOE (Risk / LOE matrix) to visualize your plan’s priorities See Example Risk / Level of Effort Matrix Set of prioritized recommendations and includes the following elements:

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Assess the risk

Mandatory security measures depend on risk level. Taking into account the state of the art, the costs of implementation […] the controller and the processor shall implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including” (Article 32 GDPR: Security of processing). Consider areas particularly controlled and subject

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Perform a detailed gap analysis

Areas concerned shall include. Transparency. Collection & Purpose Limitation. Consent: How does your organization seek, obtain and record consent? Review your communication (not only digital channels). Which procedure to verify Children’s consent: age and collect parental authorization? Legal justification for processing personal data: Determine legal justification attached to each type of data. Reviewing external contracts.

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Explore and understand your data

Execute a detailed data Inventory and discovery Identify the differents kinds of personal data you collect When/Where it is collected from? How do you use it? How/Who do you share it with? Map your data flows. Point of data collection. Touch points shall include sub-processors. Storage, Retention, Deletion. Processing (including also internal systems, service providers

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Readiness compliance & project scope

Snapshot readiness assessment Understand the GDPR principles Answer key questions Checklist key actions to fit key new requirements regarding Lawful and fair processing Privacy notices Information governance/Accountability DPIA Data Privacy Impact Assessment DPO Data Protection Officer Data breach One-stop-shop International transfer Report results in a pre gaps analysis and key measures Frame the project Bring

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