GDPR Compliance Services
Introduction to our GDPR compliance services
- An individual approach for each company during a GDPR audit. It is the audit that will allow a detailed study of the full cycle of movement of personal data of the company’s users.
- After conducting a GDPR audit, FINTECH HARBOR CONSULTING specialists will determine the further needs of the company regarding the development of mandatory policies and the implementation of certain procedures in the company.
- Conducting internal compliance: processing personal data, determining the need to implement a DPIA and/or involving a DPO, analyzing data security issues in the company and implementing further actions in case of information dissemination.
- Preparation of privacy policy, security policy, and Data processing agreements for relations with counterparties, as well as other document templates related to personal data protection.
- Provision of services for the introduction of developed documents into the company’s business processes.
- Conducting trainings with the company’s personnel explaining how each of the employees must comply with the provisions of the GDPR.
- Periodic control by lawyers of FINTECH HARBOR CONSULTING of the results of implemented changes after GDPR compliance services, namely: compliance maintenance developed documents for legislative changes, recording of processes that take place during the processing of personal data; conducting periodic audits of personal data processing processes, as well as checking compliance by employees who have access to personal data with regard to data protection and information security issues.
Full range of GDPR services
The full range of GDPR compliance services includes the following:
- GDPR non-compliance gap analysis and data inventory: identification of the scope of data processed by the company, including data sources, storage locations and the person/s who have access to such data;
- Inventory of all personal data of the company: recording how data is collected, processed, exchanged and stored by the company;
- Creation of policies and procedures: development of policies and procedures that/are compliant with the requirements of the GDPR, with subsequent communication of such policies to data subjects;
- Processing of personal data: creation of road maps for the processing of personal data, requests regarding the rights of data subjects and response to data breaches;
- Data Protection Officer (DPO) services: outsourcing DPO to oversee GDPR compliance, handle data protection requests and act as contact person for supervisory authorities;
- Ensuring the management of the rights of data subjects: implementing a system and processes to manage requests for the rights of data subjects (including, but not limited to rectification, erasure and portability of data);
- Data protection impact assessment (DPIA), in cases where it is required: carrying out a DPIA in order to identify and assess the potential risks to privacy that are associated with its data processing activities;
- DPIA development: creating a framework for conducting a DPIA, including templates and guidelines for consistent and thorough evaluation;
- Management of suppliers and third parties: assessment of compliance with the mandatory provisions of the GDPR on third-party suppliers and data processors;
- Contractual work: development of new and verification of existing contracts for data protection provisions and guarantees;
- Security audit: conducting a security audit to assess the adequacy of technical and organizational measures that exist to protect personal data;
- Implementation of incident response planning measures: development and implementation of data breach response plans;
- Accounting and documentation: creating a Record of Processing Activities (RoPA) that describes the company’s data processing activities, in particular, what personal data is processed, the reason for processing such data, to whom it is transferred (to which person) and how it is protected. RoPA is also used to demonstrate compliance with the data protection principles set out in the GDPR;
- Continuous monitoring and maintenance of compliance: the company’s implementation of a system for continuous monitoring of data protection practices to ensure continuous compliance with the GDPR.
- Legal and regulatory support: processing requests and managing company actions during investigations related to violations of GDPR provisions.
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Approach based on proven practices
The implementation of GDPR practices in the company’s daily activities will allow us to affirmatively state that the company is adapted to today’s realities in terms of requirements aimed at protecting personal data. Among the confirmed practices, the following can be distinguished:
- A comprehensive data audit to determine the sources of personal data in the company in order to understand what personal data is collected, processed, stored and provided.
- Development of privacy policies and procedures for data processing actions, data subject rights requests and incident response.
- Data protection impact assessment (DPIA) with subsequent development of templates and standards for assessment: identification of processing activities that pose a high risk to the rights and freedoms of data subjects.
- Organization of training and awareness of employees regarding data protection within the scope of GDPR: conducting training of employees who work with personal data or participate in compliance activities will allow in the future to react and act correctly when processing personal data.
- Organization of a clear procedure for processing requests for the rights of data subjects, as well as an incident response plan: a timely response to requests will allow strict compliance with GDPR requirements.
- Conducting constant monitoring of counterparties and any third parties: analysis of suppliers will allow checking their compliance with data protection requirements.
- Record keeping of data processing (RoPA): will ensure that records are regularly updated to reflect any changes in processing activities.
- Monitoring of regulatory changes: timely adaptation of company policies will avoid violations, as well as the consequences of such violations and their impact on the company’s activities.
GDPR Compliance Audit and Assessment
GDPR compliance audit and assessment is a systematic process of assessing a company’s compliance with the main privacy law in the EU – the General Data Protection Regulation (GDPR). This process involves a review and full assessment of the company’s policies and procedures in place related to the protection of personal data to ensure that they are indeed GDPR compliant.
It is a data protection audit that will allow you to check what type of personal information the company collects, how, in what way such information is used, where it is stored and who has access to it.
In turn, a GDPR compliance risk assessment will allow you to identify, assess and mitigate risks associated with the processing and use of personal data in accordance with GDPR requirements.
Conducting a GDPR compliance audit and assessment is essential to ensure an organization complies with the GDPR and continues to effectively protect personal data. GDPR compliance audit and assessment involves a systematic approach to GDPR compliance audit and assessment. The following elements can be included in such constituent elements of the above measures:
- Preliminary, preparatory actions: will allow to determine the scope of the audit, the process that will accompany it, as well as the types of data that will be checked.
- Formation of a team of auditors: to conduct an audit, it is possible to involve both company employees and external GDPR specialists or auditors for an independent assessment.
- Conducting a review of policies and procedures: the analysis of documents in the company related to the protection of personal data will allow to adapt such policies and procedures to the provisions of the GDPR. The privacy policy of the organization must be clear, comprehensive and fully comply with the imperatives of the GDPR.
- Assessment of data processing steps: during the audit, it is worth making sure that each data processing activity has a valid legal basis in accordance with the GDPR.
- Evaluation of the procedure for processing requests: an audit of the procedure for processing requests from data subjects will make it possible to understand that requests from data subjects are considered in a timely manner.
- Analysis of technical and organizational security measures and response to incidents: will allow to assess the effectiveness of already implemented technical security measures in the organization, and employees know how to respond to incidents.
- Familiarity with the breach response procedure: the organization must have a data breach response plan. In order for the response plan to be adapted to the life of the company, it is possible to conduct trainings among employees with the discussion of real cases related to data protection.
Detailed audit of your current situation
Conducting a detailed audit of a company in accordance with GDPR regulations involves a systematic and systematic review of data protection practices, policies and procedures implemented in the company. Among such integral audit measures, the following can be distinguished:
- Determination of the amount of data to be analyzed in order to identify gaps in compliance with data protection in the company.
- Organization of an audit group to analyze the situation in the company:
such auditors may include both company employees and third-party specialists who provide a wide range of GDPR consultancy services.
- Collection of existing policies and procedures implemented in the company for processing, data protection impact assessment (DPIA).
- Inventory of sources of personal data in the organization: this measure will allow to understand what personal data is collected, processed, stored and to whom and for what purpose it is provided.
- Assessment of data processing activities: this measure is carried out with the aim of identifying a valid legal basis – legal grounds and purposes in accordance with the GDPR regulations directed to data processing
- Analysis of the privacy policy and procedures implemented in the company: analysis of documents and their content will allow to assess the internal policy and procedures of data protection for compliance with GDPR requirements.
- Review and assessment of the procedures of the rights of data subjects: will ensure that the requests of data subjects are considered within certain periods.
- Verification of security measures and response to incidents: will allow to understand what technical and organizational measures are implemented in the company and how their presence affects data protection.
- Data Protection Impact Assessment (DPIA): will ensure that the DPIA identifies and mitigates privacy risks.
- Conducting trainings of awareness programs regarding the specifics of the GDPR: such measures will make it possible to inform employees about the requirements of the GDPR in order to avoid negative consequences due to non-compliance with such regulatory requirements.
- Regulatory monitoring of legislation and improvement of existing policies and procedures: the ability to timely implement the latest GDPR changes into the company’s work processes helps to avoid potential fines and also strengthens the authority among potential customers and partners.
Identification of risks and vulnerabilities
Identifying risks and vulnerabilities is certainly one important component of a GDPR compliance audit. To understand how risks and vulnerabilities are determined, it is worth familiarizing yourself with the following components of this process:
- Data inventory: search for sources in the company that relate to personal data in a certain way.
- Classification of data with regard to the sensitivity and criticality of such data: the determined type of data will help to understand what measures are necessary to protect it.
- The assessment of data processing activities makes it clear whether the company that performs data processing really has an appropriate legal basis in accordance with the GDPR and this legal basis has been brought to the attention of data subjects.
- The availability of technical data in the company: an implemented password policy, as well as the presence of multi-factor authentication, intrusion detection/prevention systems and network segmentation is an important element during data processing and protection.
- Organizational security measures in the company: conducting an assessment of implemented security policies covering data protection, incident response and acceptable use.
- Continuous training of the company’s employees: the company’s employees, who are related to personal data, must constantly undergo training in the part related to data processing, detected incidents and response to such incidents.
- Carrying out a risk assessment of third parties and auditing of such persons: verification of counterparties for their compliance with GDPR provisions before continuing cooperation.
- Data protection impact assessment (DPIA): will determine processing actions that may lead to high risks for the rights and freedoms of data subjects.
- Creating an incident response and breach management plan: will assess steps to detect, report and mitigate data breaches.
- Constant monitoring of changes and improvement of breach response policies: introduction of automated tools for constant monitoring of data processing for compliance with GDPR requirements.
- Continuous audits: conducting continuous audits will allow to assess the effectiveness of data protection measures and GDPR compliance.
- Audit: keep detailed records of audit results, corrective actions, and follow-up actions.
- Risk assessment and their documentation: documenting the results of risk assessment and measures will make it possible to assess how and in what way it is necessary to act during data processin Identifying risks and vulnerabilities is a systematic process for further data protection.
Develop GDPR compliance strategies
- Inventory of data and documentation of potential gaps in processes and technologies implemented in the company.
- Taking measures to protect customer data, which include encryption, de-identification and pseudonymization of data.
- The implementation of a notification system in the company will automate the interaction of all parties, including data, subject, controller, processor and regulator.
- Maintaining an audit trail to track all activities from data collection, consent, and even decisions made using that data.
- Constantly monitoring changes in policies related to personal data.
Creating customized solutions for your business
Creating customized GDPR solutions for businesses involves tailoring compliance strategies based on the type of business the company operates. Such solutions include the following:
- Analysis of the business model and comparison of data that is collected and processed by the company.
- The definition of regulations for the protection of personal data will allow us to determine additional data protection rules applicable to the company’s activities.
- A risk assessment and data protection impact assessment (DPIA) will identify the risks associated with a company’s data processing activities, including the potential impact on data subjects.
- Carrying out DPIA for processing that may result in high risks to the rights and freedoms of data subjects.
- Tailoring data protection policies and procedures that clearly describe the company’s data processing practices, tailored to the specific types of data that the company collects and processes.
- Implementation of data security controls to limit access to personal data depending on job functions.
- Managing the rights of data subjects through procedures to effectively process data subject requests, followed by maintaining records of consent and implementing a mechanism to allow data subjects to easily withdraw consent.
- Risk assessment when collaborating with third party service providers to assess their compliance with the GDPR before interaction.
- Implementation of an incident response plan will allow you to respond to incidents based on data processing and risk profile.
- Establishing a notification procedure to promptly and accurately notify regulators and affected data subjects of breaches.
- Continuous monitoring and improvement of data processing activities for compliance with GDPR requirements.
Staff training and process implementation
Ensuring GDPR compliance through staff training and processes is essential to protecting personal data and reducing risk.
- Personnel training: involves assessing who and what employees need GDPR training, based on their functionality and responsibilities.
- Development of a training program adapted to various positions in the organization.
- Define training methods for hands-on training and interaction for specific departments, focusing on their data processing responsibilities.
- Certification: obtaining certificates will confirm that staff have certain knowledge and skills in the field of GDPR.
- Constant monitoring of changes in legislation related to data protection.
Post-implementation support and maintenance
- Regular internal audits to review data processing activities and ensure compliance with GDPR requirements.
- Implementation of automatic monitoring to carry out data processing activities for compliance with requirements.
- Update data protection policies and procedures to ensure they are current and effective.
- Effective change management to detect and evaluate changes in data processing activities.
- Implement a Data Protection Officer (DPO) to monitor GDPR compliance by providing guidance and support.
- Data subject rights management to process data subject requests.
- Regular training of employees to reinforce the principles of GDPR and data protection methods.
- Constant monitoring of changes in legislation related to the processing and storage of data.
Ongoing compliance
Ensuring compliance with the provisions of the GDPR involves the continuous implementation of a set of measures aimed at tracking what data is sent and stored, to whom and for what purpose.
Such measures include the following:
- Creation of a compliance structure: appointment of a data protection specialist (DPO), if necessary, or engagement of gdpr compliance support in the form of first-class lawyers of FINTECH HARBOR CONSULTING for GDPR compliance. In addition, we recommend having a dedicated specialist to oversee and coordinate the compliance measures implemented in the enterprise.
- Creating and adapting data protection compliance policies: developing and maintaining a comprehensive data protection policy that covers all aspects of the GDPR.
- Continuous training and raising the awareness of personnel about GDPR requirements, existing practices, and the negative consequences of violating such imperatives in the field of data protection. Special training, the result of which is a certificate or a corresponding diploma, will allow you to delve into the field of GDPR in detail.
- Conducting audits and assessing data protection risks in the company: it is worth conducting regular internal audits to assess compliance with GDPR policies and identify areas for improvement.
- Conducting an audit by experts in the field of gdpr compliance: the involvement of third parties – professionals in the field of GDPR will allow a critical look at how company departments comply with certain provisions in the field of GDPR, and how non-compliance with such requirements affects the company or may affect it in the future. There is a power-strengthening of gdpr consultancy services. Therefore, in order to understand exactly what services your company needs, you should first turn to specialists in the field of compliance, who will help you navigate the “weak spots” of the customer company.
- Building a clear mechanism for processing and managing requests in the company: implement clear procedures for processing requests from data subjects, such as access, correction, erasure, restriction and transfer of data. Requests must be considered within clearly established terms. Such deadlines will make it possible to systematize the approach to processing requests, as well as to determine who is contacting the company and for what purpose.
- Data Protection Impact Assessment (DPIA), high-risk processing: Carry out a DPIA for any processing activities that may result in high risks to the rights and freedoms of data subjects.
To do this, standard DPIA templates can be used to ensure consistency and thoroughness of assessment. Regularly review and update the DPIA to avoid possible risks. - Introduction of technical means of control: use of reliable encryption and anonymization mechanisms to protect personal data.
- Creating an incident response procedure and plan: creating a clear complex plan will allow company employees to take consistent actions in the event of a data breach incident.
- Due diligence of performers and providers of services/works: verification of third-party providers will be necessary to ensure that they meet the requirements of the GDPR, and the agreements concluded with such persons have special provisions on data protection.
- Constant monitoring of regulatory changes: legislation is changing, the European Data Protection Board (EDPB) and national data protection authorities (DPAs) are constantly reviewing cases related to data breaches or introducing appropriate changes.
Adapting to regulatory changes
Keeping up with compliance demands requires a proactive approach. Among the most popular ways of adapting to regulatory changes, the following can be distinguished:
- Investing in technology: the world does not stand still. The constant development of technologies increases the number of violations in the field of privacy. Therefore, companies must invest in advanced software to detect changes as they occur and automate all company processes accordingly.
- Personnel training: the company must introduce a principle according to which compliance with regulatory requirements will become the duty of everyone corresponding to his work duties. It is worth conducting periodic trainings with the staff, involving gdpr experts who could familiarize the company’s staff in detail with new approaches and standards in the field of gdpr compliance in the company. It is very important to simulate certain situations during such trainings, so that in the future it can be used in the company, but already as a practical guide.
- Organization of cooperation with third-party gdpr experts: such cooperation provides a better understanding of regulatory changes.
- Creation of a reliable management structure for possible compliance risks: the more flexible the risk management system, the faster the company adapts to changes as they occur.