This document provides a checklist for auditing data as required by the General Data Protection Regulation (GDPR). The checklist contains 9 questions about the data a business holds, how it was obtained and is used, who is responsible for it, how it is stored and secured, who controls it, and how long it is retained. The questions prompt considering details like what types of data, why it is needed, collection methods, storage locations, access controls, data controller vs processor roles, and deletion processes. The goal is to understand a business's full data practices and compliance with GDPR requirements.
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GDPR Audit Checklist
This document provides a checklist for auditing data as required by the General Data Protection Regulation (GDPR). The checklist contains 9 questions about the data a business holds, how it was obtained and is used, who is responsible for it, how it is stored and secured, who controls it, and how long it is retained. The questions prompt considering details like what types of data, why it is needed, collection methods, storage locations, access controls, data controller vs processor roles, and deletion processes. The goal is to understand a business's full data practices and compliance with GDPR requirements.
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GDPR DATA Audit Checklist
Data Audit Checklist
Question Further points to consider in Answer answering the question
1 What data does your business Is the data:
hold? h Personal data;
h Special category data (sensitive personal data);
h Personal data belonging to under 13 year
olds? 2 Why does your business hold that Consider: data? h What your business does with the data? (Refer also to question 6 on this point.)
h Can you demonstrate how the data is used?
3 How did your business obtain that h Determine the methods used (including data? online and offline) to collect the data. (These may include online forms on your business website, third parties or telephone marketing.)
h Did your business make its privacy policy
available when it collected the data? 4 When did your business collect Can the date of collection of the data be identified? that data?
5 In general, who within your Consider:
business is responsible for the data h How is that person responsible for the data? identified at 1 above? h Do they manage the privacy policies and any data processing agreements that your business enters into? 6 What does your business do with Consider: the da ta? h How your business processed the data?
h Does your business send the data to third
parties for any reason?
h Can your business readily identify the reasons
why it needs the data?
1/2 GDPR DATA Audit Checklist
Question Further points to consider in Answer
answering the question
7 How does your business store the Consider:
data and is it kept secure? h Where the data is stored. h Whether the data is backed up and kept off-site or processed using a cloud-based application.
h Does your business have an agreement in
place with the storage facilities or providers used?
h Do the storage facilities or providers have
suitable data protection policies in place? (Have they carried out a data audit as part of their preparation as a data processor for the GDPR?)
h Who has access to the data both inside and
outside of your business? 8 Who controls the data (i.e. who h Consider whether your business is the data decides the purposes for which controller or the data processor? (A data and the way in which the data is processed?) controller determines the purposes for which and the way in which personal data is processed. A data processor is anyone who processes personal data on behalf of the data controller).
h If you are the data controller, do you instruct
a data processor to process the data? If so, do you have a data processing agreement in place?
h If you are the data processor, do you have a
data processing agreement in place with your data controllers? 9 How long does your business keep h Assess the periods of time that your business the data and how does it delete the holds data for and consider whether there is data when it is no longer needed? a process in place for establishing if it is still necessary to keep data. h Practically, how is data deleted when it is no longer needed?