For many Small and Medium-sized Enterprises (SMEs) across the EU, achieving GDPR compliance was a scramble to add a privacy policy and a cookie banner to their website. While these are necessary first steps, true compliance is a far deeper, ongoing commitment that builds customer trust and provides a significant competitive advantage. If your GDPR journey stopped at surface-level fixes, it’s time to dive deeper and ensure your business is genuinely protected.
A cornerstone of robust compliance is the Data Protection Impact Assessment (DPIA). Are you conducting a DPIA before launching any new project that involves processing personal data in a way that is likely to result in a high risk to individuals? This could be anything from implementing a new CRM system to using AI for customer analytics. A DPIA is a systematic process to identify and minimise data protection risks, and failing to conduct one when required is a clear violation that can attract hefty fines. It forces you to think critically about the data you’re collecting, why you’re collecting it, and how you’re protecting it.
This leads directly to the principle of Data Protection by Design and by Default. This means baking data privacy into the very foundation of your projects and systems. “By Design” means considering data protection from the earliest stages of any new technology or business practice. “By Default” means that the most privacy-friendly settings are the default choice for your customers. For example, on a sign-up form, consent for marketing emails should be an unticked checkbox, not a pre-ticked one. This proactive approach is far more effective than trying to bolt on privacy features as an afterthought.
Finally, every organisation processing personal data should maintain a Record of Processing Activities (RoPA). While there are some exemptions for very small businesses, maintaining this record is a best practice for all. This internal document details what personal data you hold, where it came from, who you share it with, and what you do with it. It’s not just a legal formality; it’s your single source of truth for data governance. A well-maintained RoPA is invaluable during a data audit or in the unfortunate event of a breach.
True GDPR compliance is not a one-time project; it’s a cultural shift. It’s about respecting customer data, understanding your legal obligations, and building a framework of accountability that protects both your clients and your business.