What is a GDPR Audit and Why Do UK SMEs Need One?
A GDPR audit is a comprehensive assessment of your organisation’s data protection practices to ensure compliance with UK GDPR regulations. Conduct an information audit to determine what information you process and who has access to it. Have a legal justification for your data processing activities.
As GDPR expert Keith Budden from Ensurety explains, regular GDPR audits are essential for SMEs to avoid potential ICO fines and maintain customer trust. Just like your car needs an MOT, your business needs regular GDPR health checks.
Pre-Audit Preparation
1. Assign GDPR Responsibility
* What to do: Designate a Data Protection Officer (DPO) or GDPR champion within your organisation
* Why it matters: Assign internal responsibility – having just one person in charge ensures accountability and consistent compliance management
* Action required: Document the appointment and define their responsibilities clearly
2. Establish Your Legal Basis for Processing
* What to do: Identify and document the legal basis for each type of data processing activity
* Why it matters: Without a valid legal basis, all data processing is unlawful under UK GDPR
* Action required: Map each processing activity to one of the six legal bases (consent, contract, legal obligation, vital interests, public task, or legitimate interests)
Core GDPR Audit Areas
3. Data Mapping and Inventory
* What to do: List the categories of data subjects and any personal data you collect. For example, current employee data, past employee data, customer information
* Why it matters: You cannot protect what you don’t know you have
* Action required: Create a comprehensive data inventory including:
▪What personal data you collect
▪Where it comes from
▪Who you share it with
▪How long you keep it
▪Where it’s stored
4. Privacy Notices and Transparency
* What to do: Review and update all privacy notices across your organisation
* Why it matters: Individuals have the right to know how their data is being used
* Action required: Ensure privacy notices are:
▪Clear and easy to understand
▪Easily accessible
▪Regularly updated
▪Compliant with Article 13/14 requirements
5. Consent Management
* What to do: Audit your consent collection and management processes
* Why it matters: Invalid consent is one of the most common GDPR violations
* Action required: Verify that consent is:
▪Freely given
▪Specific and informed
▪Clearly distinguishable from other matters
▪Easily withdrawable
6. Individual Rights Compliance
* What to do: Establish procedures for handling data subject requests
* Why it matters: Includes the rights of individuals, handling requests for personal data, consent, data breaches
* Action required: Create processes for:
6. Individual Rights Compliance
* What to do: Establish procedures for handling data subject requests
* Why it matters: Includes the rights of individuals, handling requests for personal data, consent, data breaches
* Action required: Create processes for:
▪Right of access (Subject Access Requests)
▪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
7. Data Security and Technical Measures
* What to do: Assess your technical and organisational security measures
* Why it matters: Article 32 requires appropriate security measures
* Action required: Implement:
▪Encryption of personal data
▪Regular security testing
▪Access controls and user management
▪Secure data backup and recovery procedures
▪Staff security training
8. Third-Party and Processor Management
* What to do: Review all relationships with data processors and third parties
* Why it matters: You remain liable for your processors’ compliance
* Action required: Ensure:
▪Valid Data Processing Agreements (DPAs) are in place
▪Processors provide sufficient guarantees
▪Regular processor audits are conducted
▪International transfer safeguards are implemented
9. Data Breach Procedures
* What to do: Establish and test data breach response procedures
* Why it matters: Breaches must be reported to the ICO within 72 hours
* Action required: Create:
▪Breach detection procedures
▪Assessment and notification processes
▪Incident response team
▪Communication templates
▪Regular testing and updates
10. Staff Training and Awareness
* What to do: Implement comprehensive GDPR training programmes
* Why it matters: Building up the training provisions for team members on data protection and their awareness
* Action required: Provide:
▪Initial GDPR training for all staff
▪Role-specific training
▪Regular refresher sessions
▪Documented training records
11. Data Protection Impact Assessments (DPIAs)
* What to do: Identify processing activities that require DPIAs
* Why it matters: data protection impact assessments under the General Data Protection Regulations are mandatory for high-risk processing
* Action required: Conduct DPIAs for:
▪New technologies
▪Large-scale processing
▪Systematic monitoring
▪Processing of special category data
12. Record Keeping and Documentation
* What to do: Maintain comprehensive records of processing activities
* Why it matters: Article 30 requires detailed processing records
* Action required: Document:
▪Purposes of processing
▪Categories of data subjects and personal data
▪Recipients of personal data
▪Retention periods
▪Security measures
Advanced Compliance Areas
13.International Data Transfers
* What to do: Audit all international data transfers
* Why it matters: Transfers outside the UK require appropriate safeguards
* Action required: Implement:
▪Adequacy decision verification
▪Standard Contractual Clauses (SCCs)
▪Transfer Impact Assessments (TIAs)
▪Binding Corporate Rules (where applicable)
14.Marketing and Communications Compliance
* What to do: Review all marketing activities and communications
* Why it matters: GDPR intersects with PECR and marketing regulations
* Action required: Ensure:
▪Valid consent for electronic marketing • Opt-out mechanisms are available
▪Suppression lists are maintained
▪Cookie compliance
15. Website and Digital Compliance
* What to do: Audit your website and digital platforms
* Why it matters: Online data collection requires specific compliance measures
* Action required: Review:
▪Cookie policies and consent mechanisms
▪Contact forms and data collection
▪Analytics and tracking
▪Third-party integrations
Continuous Monitoring and Improvement
16. Regular Compliance Reviews
* What to do: Establish ongoing monitoring procedures
* Why it matters: GDPR compliance is not a one-time activity
* Action required: Schedule:
▪Annual comprehensive audits
▪Quarterly policy reviews
▪Monthly security assessments
▪Ongoing staff training
17. Incident Management and Learning
* What to do: Learn from incidents and near-misses
* Why it matters: Continuous improvement reduces future risks
* Action required: Implement:
▪Post-incident reviews
▪Policy updates based on lessons learned
▪Sharing best practices across the organisation
