CDMP Fundamentals • 100 Questions • 90 Minutes
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☑ GDPR Compliance Checklist

A comprehensive checklist covering all major GDPR requirement areas. Use this to assess compliance status, prioritize remediation, and track progress. Each check references the relevant GDPR article and includes a priority level and beginner tip.

Lawfulness, Fairness & Transparency

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A lawful basis is identified and documented for EVERY processing activity

Art. 6 Critical

💡 Create a register mapping each processing activity to one of the six lawful bases. No lawful basis = illegal processing.

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For special category data, an Article 9 condition is also identified and documented

Art. 9 Critical

💡 Special categories (health, race, religion, etc.) need BOTH an Article 6 basis AND an Article 9 condition.

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Privacy notices are provided at all data collection points

Art. 13-14 Critical

💡 Every form, app screen, or process that collects personal data needs an accessible privacy notice.

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Privacy notices contain ALL required information (identity, purposes, lawful basis, recipients, transfers, retention, rights)

Art. 13-14 Critical

💡 Use the Article 13 list as a checklist — missing any element makes the notice non-compliant.

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Privacy notices are written in clear, plain language appropriate to the audience

Art. 12 High

💡 Test readability with someone outside the legal/privacy team. If they cannot understand it, rewrite it.

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Processing is fair — individuals would reasonably expect the processing given the context

Art. 5(1)(a) High

💡 Ask yourself: if the data subject knew exactly what we do with their data, would they be surprised or concerned?

Consent Management

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Where consent is the lawful basis, it meets all GDPR requirements (freely given, specific, informed, unambiguous)

Art. 7 Critical

💡 GDPR consent is a high bar. Pre-ticked boxes, passive acceptance, and bundled consent are all invalid.

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Consent is obtained through a clear affirmative action (opt-in, not opt-out)

Art. 4(11) Critical

💡 The user must DO something active: check a box, click a button, toggle a switch. Silence or inactivity is never consent.

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Separate consent is obtained for each distinct processing purpose

Art. 7 High

💡 One checkbox per purpose. Do not bundle email marketing consent with terms of service acceptance.

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Consent can be withdrawn as easily as it was given

Art. 7(3) Critical

💡 If consent was given with one click, withdrawal must also be one click. Do not hide the unsubscribe option.

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Records of consent are maintained (who, when, what, how)

Art. 7(1) High

💡 You must be able to demonstrate that consent was given. Keep a consent ledger with timestamps and versions.

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A cookie consent mechanism is in place that blocks non-essential cookies until consent is obtained

ePrivacy + Art. 7 High

💡 Cookie banners that only inform but do not block cookies are not compliant. Non-essential cookies must not fire until the user actively consents.

Data Subject Rights

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A documented process exists for handling each of the 8 data subject rights

Art. 12-22 Critical

💡 Create a Standard Operating Procedure (SOP) for each right. Test each process with a mock request before going live.

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Data subject requests are responded to within one calendar month

Art. 12(3) Critical

💡 30 calendar days from receipt, not 30 business days. Weekends and holidays count.

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Identity verification is performed before fulfilling rights requests

Art. 12(6) High

💡 Verify identity proportionately. Do not require more ID than necessary, but do not hand data to the wrong person.

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A tracking system is in place with deadline alerts for all rights requests

Art. 12(3) High

💡 Use a ticketing system with automated reminders at 14 days and 25 days to prevent deadline breaches.

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Staff who interact with data subjects are trained to recognize and escalate rights requests

Art. 12 High

💡 Customer service, reception, and HR staff should know that a request like 'show me my data' or 'delete my account' is a formal GDPR right.

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Responses include all supplementary information required (purposes, recipients, retention, rights)

Art. 15 Medium

💡 A DSAR response is not just the data itself — you must also tell them why you have it, who you shared it with, and how long you keep it.

Data Security (Article 32)

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Personal data is encrypted at rest in databases and file storage

Art. 32(1)(a) Critical

💡 Use AES-256 encryption for data at rest. Most modern databases and cloud storage support this natively.

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Personal data is encrypted in transit using TLS 1.2 or higher

Art. 32(1)(a) Critical

💡 All web traffic should use HTTPS. All API connections should use TLS. No exceptions for internal traffic.

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Access to personal data is controlled on a need-to-know basis (least privilege)

Art. 32(1)(b) Critical

💡 Not everyone needs access to all personal data. Implement role-based access control and review permissions quarterly.

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Audit logging is enabled for access to personal data

Art. 32 High

💡 You need to know who accessed what personal data and when. This is essential for breach investigation and accountability.

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Regular vulnerability scanning and penetration testing is conducted

Art. 32(1)(d) High

💡 Test your defenses regularly. Annual penetration tests and monthly vulnerability scans are a good baseline.

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Backup and disaster recovery procedures are in place and tested

Art. 32(1)(c) High

💡 Can you restore personal data if a system fails? Test your backups regularly. Also remember: backup data is in scope for DSARs and erasure.

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Pseudonymization is used where feasible to reduce risk

Art. 32(1)(a) Medium

💡 Where you can replace direct identifiers with tokens or pseudonyms (especially in analytics and testing), do so. It reduces risk significantly.

Data Breach Management

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A documented data breach response plan exists with named roles and responsibilities

Art. 33-34 Critical

💡 Do not wait for a breach to figure out what to do. Have a plan, have named people, have templates ready.

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Breaches are assessed and reported to the supervisory authority within 72 hours when required

Art. 33(1) Critical

💡 The 72 hours starts when you BECOME AWARE of the breach. Have an on-call process for weekends and holidays.

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High-risk breaches are communicated to affected individuals without undue delay

Art. 34 Critical

💡 If the breach is likely to result in high risk to individuals, you must tell them directly — not just notify the regulator.

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A breach register is maintained documenting all incidents regardless of notification decision

Art. 33(5) High

💡 Document EVERY breach, even ones that do not require notification. The regulator may ask to see this register.

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Breach response tabletop exercises are conducted at least annually

Best Practice Medium

💡 Practice makes prepared. Simulate a breach scenario annually and walk through the response with all involved teams.

Records and Accountability

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A complete Record of Processing Activities (ROPA) is maintained per Article 30

Art. 30 Critical

💡 The ROPA is your master inventory of all personal data processing. Keep it current and review it at least every 6 months.

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The ROPA includes all mandatory fields: purposes, data categories, recipients, transfers, retention, security measures

Art. 30(1) Critical

💡 Article 30 lists exactly what must be in the ROPA. Use it as a column-by-column checklist.

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Data Protection Impact Assessments are conducted for high-risk processing

Art. 35 Critical

💡 If processing involves new tech, profiling, large-scale special data, or systematic monitoring, a DPIA is mandatory BEFORE processing starts.

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A Data Protection Officer is appointed where required

Art. 37 Critical

💡 Public authorities, large-scale monitoring, and large-scale special data processing ALL require a DPO. When in doubt, appoint one.

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Policies, procedures, and compliance evidence are documented and version-controlled

Art. 5(2) High

💡 GDPR accountability principle means you must be able to DEMONSTRATE compliance. If it is not documented, it did not happen.

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Staff training on GDPR is delivered, documented, and refreshed regularly

Art. 39(1)(b) High

💡 Train all staff on GDPR basics at onboarding and refresh annually. Track completion rates as evidence of compliance.

Data Minimization and Retention

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Only personal data that is necessary for the stated purpose is collected

Art. 5(1)(c) High

💡 For every data field you collect, ask: do we actually NEED this? If not, do not collect it.

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A data retention schedule is defined and documented for all categories of personal data

Art. 5(1)(e) High

💡 Every type of personal data should have a defined retention period with a legal or business justification.

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Technical controls enforce retention periods (automated deletion or archival)

Art. 5(1)(e) Medium

💡 A policy that says 'delete after 3 years' is useless without technical enforcement. Automate where possible.

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Legacy data with no current purpose has been identified and scheduled for deletion

Art. 5(1)(e) Medium

💡 Many organizations have years of accumulated data with no current purpose. This is a liability, not an asset. Identify and dispose of it.

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Test and development environments do not contain real personal data (or it is pseudonymized)

Art. 5(1)(c) Medium

💡 Using production personal data in test/dev is a common but risky practice. Use synthetic or pseudonymized data instead.

International Data Transfers

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All cross-border data transfers are identified and documented

Art. 44-49 Critical

💡 Map every data flow that crosses EU/EEA borders — including cloud storage, remote access, vendor processing, and intra-group transfers.

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A valid transfer mechanism is in place for each cross-border transfer (adequacy, SCCs, BCRs, derogation)

Art. 46 Critical

💡 Every transfer outside the EU/EEA needs a legal mechanism. No mechanism = illegal transfer.

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Transfer Impact Assessments (TIAs) have been conducted for transfers relying on SCCs or BCRs

Schrems II High

💡 After the Schrems II ruling, SCCs alone are not always enough. You must assess whether the laws of the destination country undermine the protections.

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The privacy notice discloses international transfers and the mechanisms used

Art. 13(1)(f) High

💡 Individuals have the right to know if their data goes outside the EU/EEA and what protections are in place.

Vendor and Processor Management

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All data processors are identified and recorded in a processor register

Art. 28 Critical

💡 Every SaaS tool, cloud provider, and outsourced service that handles personal data on your behalf is a processor.

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Article 28-compliant Data Processing Agreements are in place with ALL processors

Art. 28(3) Critical

💡 No DPA = non-compliant processing. Check every vendor. Most large vendors have standard DPAs available.

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Sub-processor arrangements are documented and consented to

Art. 28(2) High

💡 Your processors may use their own sub-processors. You need to know who they are and ensure they are also bound by appropriate terms.

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New vendor onboarding includes a privacy and security assessment

Art. 28(1) High

💡 Assess vendor privacy practices BEFORE signing the contract and sharing data. Integrate into procurement.

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Processor compliance is reviewed at least annually for high-risk processors

Art. 28(3)(h) Medium

💡 DPAs give you audit rights. Use them — at minimum, send an annual compliance questionnaire to your key processors.