GDPR: Data Compliance Best Practices For 2025

By Aaron Bradshaw

Published on September 23, 2024

Introduction: What is the GDPR?

The purpose of the General Data Protection Regulation (GDPR) is to standardize data protection rules and protect individuals’ rights as they relate to personal information. To this end, it regulates how personal data is processed and transferred.

What’s the impact of the GDPR?

25th May 2025 marks seven years since the General Data Protection Regulation (GDPR) went live in the EU and European Economic Area. Since its implementation, the GDPR has had many impacts, including:

  • Data protection: Individuals have more control over how their personal data is collected and can more easily opt out of communications. 

  • Data security: The GDPR has led more companies to implement encryption, to protect personal data, improving data security.

  • Data governance: Mandates outlined in the GDPR have pushed more organizations to implement data governance frameworks, leading to more standardized data management practices and controls. 

  • Innovation: To meet the GDPR's demands, new software solutions, such as compliance management software, have entered the market.

  • Penalties: Companies that violate the GDPR have been fined and faced resulting reputational damage.

 Meta, Google, and Amazon are among the companies that have been hit with record-breaking fines as a result of GDPR violations. In that period, new global privacy regulations have also been launched, yet GDPR still stands as the flagship privacy regulation. Here, we discuss best practices to streamline compliance with the regulation.

What are the GDPR requirements and key principles?

Let’s revisit the principles of GDPR:

  • Lawfulness, fairness, and transparency

  • Purpose limitation

  • Data minimization

  • Accuracy

  • Storage limitation

  • Integrity and confidentiality (security)

  • Accountability

The main rights of the GDPR describe the rights of individuals (or data subjects); they are;

  • The right to be informed

  • The right of access

  • The right to rectification

  • The right to erasure

  • The right to restrict processing

  • The right to data portability, the right to object, and also rights around automated decision-making and profiling

In the following sections, we’ll discuss how implementing data governance and processing best practices can help you comply with these rights, particularly the right to erasure. 

Data governance best practices for GDPR complianceAdhering to governance best practices can streamline GDPR compliance efforts and mitigate risks. How can data leaders implement such a program? Follow these steps:

Establish clear data ownership and accountability

A cornerstone of successful data governance is defining clear roles and responsibilities. Under GDPR, organizations must demonstrate accountability for how they manage personal data. Assigning a Data Protection Officer (DPO) is often a legal requirement, and this role is crucial for overseeing data protection strategies and ensuring GDPR compliance.

Beyond the DPO, data stewards or data custodians should be appointed to manage specific data sets. These roles involve overseeing data handling, access, and decision-making processes. By assigning clear ownership, you not only streamline GDPR compliance but also enhance accountability, ensuring designated individuals are responsible for each stage of the data lifecycle.

Audit, inventory, and classify data

A comprehensive data inventory is essential for GDPR compliance. Knowing what data you hold, where it is stored, and how it is used is the first step in protecting personal information. Conduct a detailed audit to map all data assets, including any personal or sensitive data collected from individuals.

Next, classify your data according to its level of sensitivity. Personal data should be handled with care, but special categories of data—such as health information—require additional safeguards. Proper data classification enables you to enforce appropriate controls based on the GDPR’s principle of data minimization, ensuring you only process the data necessary for your specific purposes.

Implement data access controls

GDPR emphasizes the importance of securing personal data and limiting access to those who need it for legitimate purposes. To achieve this, establish role-based access controls (RBAC) that restrict who can view or process certain types of data. By doing so, you reduce the risk of unauthorized access or data breaches.

Technologies like multi-factor authentication, encryption, and access monitoring tools can help ensure that personal data is accessed only by authorized personnel. Regularly reviewing access permissions and monitoring usage patterns can also detect and prevent unauthorized activities before they become significant issues.

Ensure data lifecycle management defines data retention periods

Under GDPR, individuals have broadened rights to control their personal data, including the right to be forgotten. Effective data lifecycle management ensures that you collect, store, and delete data in compliance with these rights. Implement policies that define retention periods for various types of data, and automate data deletion once the retention period expires or when a data subject requests deletion.

Archiving data securely and ensuring that personal information is erased from both active systems and backups are essential steps to staying compliant with GDPR’s strict deletion requirements.

Ensure data quality and accuracy

Under GDPR, organizations are required to ensure that the personal data they hold is accurate and up to date. Data governance plays a critical role in maintaining data quality. Establish processes for regular data reviews to identify and correct inaccuracies. Consider integrating a data quality or observability tool to flag such inaccuracies.

For instance, you can set up automated tools that prompt users to verify their data periodically, ensuring that any outdated information is updated. By maintaining accurate records, you reduce the risk of non-compliance and enhance your organization’s overall data governance posture.

Develop a consent management framework

GDPR places strict conditions on obtaining and managing user consent. Consent must be freely given, informed, and documented. To comply, organizations need a robust consent management framework that tracks when and how consent was obtained, and allows individuals to withdraw it easily.

Tools like consent management platforms (CMPs) can streamline this process, enabling you to keep detailed records of consent for each data subject. This ensures that you respect individuals’ preferences and demonstrate compliance with GDPR's consent regulations.

Monitor and audit data practices regularly

Even with a solid data governance strategy in place, continuous monitoring is critical to staying compliant with GDPR. Implement regular audits to assess the effectiveness of your data governance practices and ensure compliance with the requirements. Automated monitoring tools can track data access, modifications, and potential breaches, providing you with the visibility needed to address issues proactively (see also the next section for specific examples of how to automate notifications that relate to changes in your data management processes, as required by the Requirements for Processing Activity or ROPA.)

Ensure cross-border data transfer compliance

If your organization transfers personal data outside the EU, GDPR imposes strict requirements. Ensure that Standard Contractual Clauses (SCCs) or Binding Corporate Rules (BCRs) are in place to legally transfer data internationally. Your data governance policies should include provisions for such transfers, outlining the necessary safeguards and documentation required to comply with GDPR regulations.

Create an incident response plan for breach notifications

In the event of a data breach, GDPR requires organizations to notify authorities within 72 hours. Your data governance framework should include a comprehensive incident response plan that details how to identify, report, and mitigate data breaches.

By having these procedures in place, your organization can react quickly, minimizing the impact of a breach and ensuring that you comply with GDPR’s strict reporting timelines.

Data processing best practices for GDPR compliance

One key component reflecting the right to be informed (and the principle of fairness and transparency) is Article 30, the requirement of a Record of Processing Activity (ROPA). This effectively asks every organization to create documentation that describes every process that uses individuals’ private data. This means that each controller and processor has to establish a record of each processing activity that concerns personal data to maintain compliance with the GDPR. 

The definition of processing activities corresponds with the definition of processing in Article 4(2) GDPR. The stipulation systematically goes hand in hand with the principles and obligations stated in Articles 5, 6, 12 GDPR.[1] Only when a record of processing activities exists can principles such as transparency, purpose, data minimization, accuracy, storage limitation, accountability, etc., be realized. It serves as a self-control mechanism to assess what kind of processing activities are at stake.[2]

To comply with the ROPA requirement, organizations must answer key questions, including:

  • What are the Data categories (name, address, data of birth, salary, card details, gender, race, etc.)?

  • What is the purpose of processing?

  • What is the location(s) of data?

  • What is the rationale for processing?

  • Who is the process owner?

  • Does data leave the EEA? When?

  • What is the security in place?

Data Protection Impact Assessments (DPIAs) are integral to the GDPR. A DPIA is a process that helps identify and reduce the risks of processing PII. Moreover, DPIAs are included in these records to legitimize the respective processing activity, in particular if there is a high risk for personal data. Therefore, technical and organizational measures also have to be mentioned in the record.

In 2017 and 2018, I remember teams of business analysts conducting numerous interviews to understand the hundreds of processes across departments. I then remember the ROPA document remaining static, without updates in the months that followed. Since then, thankfully, organizations have been proactively maintaining the ROPA. A theme that follows is that organizations with static ROPAs typically have more time-consuming manual processes to fulfill the other rights.

ROPA documentation: guidelines for audit preparation

Link your ROPA entries to actual data

As data catalogs continue to evolve, the ability to link documentation has advanced. For example, data catalog managers can link business metadata (like a ROPA), to technical metadata (tables & columns, like the data used in a process using personal data). This is increasingly becoming crucial to mitigate the risk of non-compliance and to create efficiencies in what has often become an onerous manual process.

This ability enables data leaders to proactively respond when changes occur and the ROPA requires updating. For example, if a table is deleted (and your ROPA links to real metadata), you can proactively inform people that a ROPA entry needs updating (to a new table), or deleting (as the process no longer happens). This not only streamlines the business process, it ensures ongoing ROPA compliance.

Proactively alert personal data not tied to a process  

If you can link the ROPA to actual data, and you have classified data to identify any PII, it is feasible to build an automated process that alerts users to any PII that isn’t linked to at least one ROPA entry. This captures any gaps in the ROPA (without this mechanism it will be difficult to identify missing processes) 

Link the DPIA to the data used in processes 

When a new process is added, or an existing process is changed, data leaders need the ability to review the DPIA used for that process.

 Again, the power here is to monitor proactively for any changes that could affect the nature (and risk) of the data in scope.

Utilize Your ROPA to facilitate compliance and mitigate risk

After investing so much time in your ROPA, aim to use it to the fullest. You can leverage your existing ROPA to fulfill other requirements outlined in the GDPR, including:

  • Fulfill DSARs (Data Subject Access Requests): When individuals ask to access their PII, you’ll need a process to enable this. Knowing which process uses which data and why will allow any DSAR to be responded to quicker and easier.

  • Address the right to be deleted/rectified/removed: With a ROPA in place, you can quickly locate the physical data of those seeking to delete, rectify or remove this data. 

You can also leverage your ROPA to mitigate risks by:

  • Linking to relevant DPIA (Data Protection Impact Assessment)

  • Linking to TIA/TRA(Transfer Impact Assessment/Transfer Risk Assessment): Mitigate risks for any data being transferred outside the European Economic Area (EEA.)

Conclusion

7 years after the launch of GDPR, we’ve seen that privacy regulations are showing no signs of stopping, and in the world of AI we’re seeing increased demand to automate and reduce manual burdens. Data privacy is no exception.

Hopefully, this blog has given privacy professionals the opportunity to utilize the work completed to complete GDPR Article 30 and tie it to as much other collateral as possible. The more you can automate, the lesser the risk of non-compliance, alongside the benefit of taking less time with SMEs maintaining documentation. It’s time active metadata management applied to privacy.

Curious to learn how you can leverage active metadata to safeguard privacy? Book a demo with us today to see how.

    Contents
  • Introduction: What is the GDPR?
  • What’s the impact of the GDPR?
  • What are the GDPR requirements and key principles?
  • Data processing best practices for GDPR compliance
  • ROPA documentation: guidelines for audit preparation
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