9-Step Checklist for GDPR Compliance

Whether you’re a startup entering the European market or an established business updating your privacy practices, complying with the General Data Protection Regulation (GDPR) can feel overwhelming. But it doesn’t have to be. This checklist breaks down GDPR compliance into nine essential steps, making it easier to protect personal data, reduce legal risk, and build customer trust.

This guide is designed for professionals at all levels and aligns with both the letter and spirit of the GDPR. Let’s get started.

Why GDPR Compliance Matters

The GDPR, which went into effect in May 2018, is one of the most far-reaching data protection laws ever enacted. It applies to any organization that processes the personal data of individuals in the European Union regardless of where that organization is based (GDPR.eu). This includes businesses outside the EU that offer goods or services to EU residents or monitor their behavior.

Non-compliance can result in steep financial penalties up to €20 million or 4% of annual global revenue, whichever is higher. But the risks extend well beyond regulatory fines:

• Loss of consumer trust: Privacy-conscious users are more likely to abandon brands that mishandle data.
• Reputational damage: A breach or enforcement action can generate negative press and long-term brand harm.
• Operational inefficiencies: Without a structured privacy framework, businesses struggle to manage data responsibly across teams and systems.

Ultimately, GDPR compliance helps organizations build credibility, improve data hygiene, and gain a competitive advantage in a privacy-driven market.

GDPR Compliance Checklist: 9 Steps to Get Started

1. Map the Personal Data You Collect and Process

Start with a comprehensive data inventory. You need to know:

• What types of personal data you collect
• Where the data comes from (e.g., web forms, third-party integrations)
• Where it’s stored
• Who has access to it
• How it’s shared and for what purpose

This mapping process helps identify risks, reduce redundancies, and determine your legal basis for processing.

2. Identify Your Legal Bases for Data Processing

GDPR requires you to have a legal reason to collect and process personal data. The six lawful bases under GDPR are:

• Consent: Clear and specific permission given by the data subject
• Contract: Processing necessary to fulfill a contract
• Legal obligation: Required by law
• Vital interests: Necessary to protect someone’s life
• Public task: Performed in the public interest
• Legitimate interests: Balanced interests that don’t override data subject rights

You must document and communicate the basis you rely on for each type of processing activity.

Learn how to determine legal bases in this overview by the UK’s Information Commissioner’s Office.

3. Update Your Privacy Policy

Your privacy policy must be clear, comprehensive, and aligned with GDPR transparency requirements. It should explain:

• What data you collect
• Why you collect it
• How you process and store it
• Whether you share it with third parties
• How long you retain it
• What rights users have over their data

A vague or outdated policy can expose you to regulatory scrutiny. Make sure it’s easily accessible on your website.

4. Establish a Consent Management Process

If you rely on consent, it must meet specific GDPR standards:

• Freely given
• Specific and informed
• Clearly indicated (no pre-checked boxes)
• Easy to withdraw

You’ll need tools to capture, track, and document consent especially if you serve users across multiple jurisdictions.

Pro Tip: Cookie banners and opt-in forms should be reviewed to ensure they’re not misleading or overly broad.

5. Enable Data Subject Rights

The GDPR gives individuals several rights over their personal data:

• Right to access
• Right to rectification
• Right to erasure (“right to be forgotten”)
• Right to restrict processing
• Right to data portability
• Right to object
• Rights related to automated decision-making

Create internal processes and designate responsible teams or tools to handle these requests within GDPR’s timelines typically 30 days.

6. Implement Technical and Organizational Safeguards

Security is a core part of compliance. Article 32 of the GDPR requires organizations to implement “appropriate technical and organizational measures” to protect personal data. This includes:

• Encryption and pseudonymization
• Access controls
• Activity logging
• Regular vulnerability scanning
• Employee security awareness training

Bonus Tip: Establish an incident response plan. GDPR requires you to report personal data breaches within 72 hours when they pose a risk to individual rights. We have a guide to help you put together a robust BCDR/ IR document.

7. Audit Third-Party Vendors

If you share or store data using third-party providers (such as email marketing tools, cloud storage, or analytics platforms), those vendors must also be GDPR compliant.

Steps to take:

• Review vendor contracts
• Ensure they include Data Processing Agreements (DPAs)
• Confirm data transfer mechanisms for international vendors (e.g., Standard Contractual Clauses)

This article by IAPP offers a deep dive on cross-border data transfers.

8. Maintain Records of Processing Activities (RoPA)

Article 30 of the GDPR requires certain organizations to document their processing activities, including:

• Purposes of processing
• Categories of personal data
• Data recipients
• Retention schedules
• Security measures

Even if you’re not legally required to maintain these records, it’s best practice and strengthens your accountability framework.

A RoPA also supports audits, simplifies reporting, and clarifies internal data usage.

9. Appoint a Data Protection Officer (DPO) if Required

You must appoint a DPO if:

• You’re a public authority
• Your core activities require large-scale monitoring of individuals
• You handle large-scale special category data (e.g., health data)

Even if not mandatory, appointing a DPO or privacy lead can ensure day-to-day oversight and continuity in your compliance efforts.

Need help deciding if you require a DPO? We have some resources to learn more about what a DPO is responsible for under the GDPR.

Build a GDPR Program That Lasts

Following this checklist gives you a strong start but GDPR isn’t a one-and-done effort. Compliance requires continuous updates, monitoring, and adaptation to new risks and regulations.

That’s where Carbide comes in. Our hybrid platform helps companies:

• Automate controls and documentation
• Streamline third-party risk management
• Respond to audits and regulatory inquiries with confidence

Ready to reduce your compliance workload and stay ahead of GDPR? Talk to a Carbide expert today.