Maintaining GDPR Compliance: Ongoing Requirements

Key Takeaways

Point	Summary
No certification	GDPR is continuous obligation, not a one-time certification
Daily operations	Monitor DSAR inbox, handle consent withdrawals, track data retention
Periodic reviews	Annual privacy policy review, vendor DPA review, training refresh
Change triggers	New products, new vendors, new markets, organizational changes require compliance updates
Documentation	Maintain audit trail of decisions, assessments, and compliance activities

Quick Answer: GDPR compliance is ongoing, not a project. Daily: handle data subject requests. Quarterly: review processing activities. Annually: update policies, refresh training, review vendor DPAs. Document everything to demonstrate accountability.

GDPR Compliance is Continuous

Unlike some certifications with defined audit cycles, GDPR compliance is ongoing:

GDPR Compliance Reality:

Not a One-Time Project:

• No "GDPR certified" status
• No periodic recertification
• Continuous obligations
• Always subject to investigation

Ongoing Requirements:

• Respond to data subject requests
• Report breaches within 72 hours
• Maintain current documentation
• Monitor regulatory changes
• Adapt to business changes

Daily Operations

Routine Privacy Activities

Activity	Frequency	Owner
Monitor DSAR inbox	Daily	Privacy/Support
Check breach alerts	Daily	Security
Review access requests	Daily	IT
Process consent changes	As needed	Marketing
Handle privacy inquiries	As needed	Privacy/Support

Embedded Privacy Practices

Process	Privacy Integration
User Registration	Consent collection, privacy notice
Customer Support	Identity verification, data access
Marketing Campaigns	Consent check, list hygiene
Product Development	Privacy by design review
Vendor Onboarding	DPA requirement
Employee Offboarding	Access removal, data handling

Weekly and Monthly Tasks

Weekly Activities

Activity	Owner	Details
DSAR status review	Privacy Lead	Track open requests
Consent metrics	Marketing	Opt-in/opt-out rates
Security alerts review	Security	Identify potential issues
New vendor check	Operations	Any new tools added?

Monthly Activities

Activity	Owner	Details
ROPA review	Privacy Lead	Any new processing?
Privacy policy check	Legal/Privacy	Still accurate?
Consent records audit	Marketing	Storage and validity
Access rights review	IT	Appropriate access?
Training completion	HR	New employee completion
Vendor DPA status	Operations	Any gaps?

Quarterly Reviews

Q1, Q2, Q3, Q4 Activities

Quarterly Compliance Review:

Documentation Review:

• ROPA accuracy check
• Privacy policy updates needed?
• Cookie policy current?
• DPAs up to date?

Process Review:

• DSAR process working effectively?
• Consent mechanisms functioning?
• Breach response tested?
• Training completion rates?

Technical Review:

• Security measures effective?
• Access controls appropriate?
• Data retention enforced?
• International transfers documented?

Vendor Review:

• New vendors assessed?
• Existing vendor changes?
• Sub-processor updates reviewed?
• DPA renewals needed?

Annual Compliance Activities

Annual Review Checklist

Activity	Timing	Owner
Full ROPA update	Q1	Privacy Lead
Privacy policy comprehensive review	Q1	Legal/Privacy
Security assessment	Q2	Security
Vendor audit	Q2	Operations
DPIA review (if applicable)	Q3	Privacy Lead
Training refresh	Q3	HR
International transfer review	Q4	Legal/Privacy
Compliance self-assessment	Q4	Privacy Lead

Annual Documentation Updates

Document	Review Activities
ROPA	Verify all processing, update as needed
Privacy Policy	Check against current practices
Cookie Policy	Audit cookies, update list
Data Retention Schedule	Verify periods, update for new data
Security Policies	Review effectiveness, update
Incident Response Plan	Test and update
Training Materials	Update for changes

Managing Change

Privacy Impact in Change Management

Every business change should include privacy consideration:

Change Impact Assessment:

New Feature/Product:

• What personal data involved?
• What's the legal basis?
• Privacy policy update needed?
• DPIA required?
• New processing in ROPA?

New Vendor/Tool:

• Does it process personal data?
• DPA required?
• Security adequate?
• International transfers?
• Added to vendor register?

Organizational Change:

• Access rights updates?
• Privacy responsibility changes?
• Training requirements?
• Policy updates needed?

New Market/Region:

• Additional requirements?
• Local representative needed?
• Transfers properly protected?
• Local privacy policy version?

DPIA Triggers

Conduct Data Protection Impact Assessment when:

Trigger	Example
New Processing	Launching new product feature
High Risk Processing	Processing special category data
Large Scale	Significantly expanding user base
Systematic Monitoring	Implementing user tracking
New Technology	Using AI/ML on personal data
Vulnerable Groups	Processing children's data
Cross-Referencing	Combining datasets
Automated Decisions	Implementing algorithmic decisions

Staying Current with Regulations

Regulatory Monitoring

Source	What to Watch
EU Commission	New adequacy decisions, regulation updates
EDPB	Guidelines, binding decisions
National DPAs	Country-specific guidance, enforcement
Industry Groups	Sector-specific interpretations
Legal Updates	Case law developments

Adapting to Changes

Regulatory Change Response:

Monitor:

• Subscribe to DPA newsletters
• Follow legal updates
• Track industry developments
• Monitor enforcement trends

Assess:

• Does change affect us?
• What's the compliance deadline?
• What changes are needed?
• What's the priority?

Implement:

• Update policies/procedures
• Modify technical controls
• Train staff on changes
• Document compliance

Verify:

• Test implementation
• Audit compliance
• Update documentation
• Continue monitoring

Compliance Metrics and KPIs

Key Performance Indicators

Metric	Target	Frequency
DSAR response time	<one month	Per request
DSAR completion rate	100%	Monthly
Training completion	100%	Monthly
Consent rate	Benchmark	Weekly
Privacy complaints	Trending down	Monthly
Breach response time	<72 hours	Per incident
Vendor DPA coverage	100%	Quarterly
ROPA accuracy	Current	Quarterly

Compliance Dashboard

GDPR Compliance Dashboard:

Overall Status: ✓ Compliant

Metric	Status
DSARs (one month)	✓ 100%
Training	✓ 98%
Vendor DPAs	✓ 100%
ROPA Current	✓ Yes
Breaches	✓ 0 open
Cookie Consent	✓ Compliant
Policy Review	Due: 45 days
Security Assess	✓ Complete
Privacy Inquiries	✓ 0 pending

Upcoming Tasks:

• Q4 vendor audit (Oct 15)
• Annual training refresh (Nov 1)
• Privacy policy annual review (Dec 1)

Common Maintenance Challenges

Challenge 1: Documentation Drift

Problem: Documentation becomes outdated as practices change.

Solution:

• Integrate updates into change management
• Regular scheduled reviews
• Single source of truth
• Clear ownership

Challenge 2: Staff Turnover

Problem: Knowledge loss when employees leave.

Solution:

• Document processes thoroughly
• Cross-train team members
• Regular refresher training
• Clear handoff procedures

Challenge 3: Vendor Proliferation

Problem: New tools added without privacy review.

Solution:

• Procurement process includes privacy
• Vendor inventory management
• Regular audits
• Clear approval process

Challenge 4: Feature Creep

Problem: New features launched without privacy consideration.

Solution:

• Privacy by design in development process
• Privacy review in release checklist
• Developer training
• Clear escalation path

Challenge 5: Regulatory Changes

Problem: Hard to track and adapt to regulatory updates.

Solution:

• Monitoring system in place
• Regular legal updates
• Dedicated responsibility
• Flexible policies

Building a Compliance Culture

Elements of Privacy Culture

Element	Implementation
Leadership Commitment	Visible executive support
Clear Responsibility	Defined roles and accountability
Training	Regular awareness programs
Communication	Regular privacy updates
Integration	Privacy in daily workflows
Recognition	Acknowledge privacy champions
Feedback	Easy to report concerns

Making Privacy Everyone's Job

Role	Privacy Responsibilities
Executives	Set tone, provide resources
Product	Privacy by design, impact assessment
Engineering	Secure development, data protection
Marketing	Consent management, list hygiene
Sales	Privacy in customer conversations
Support	DSAR handling, data access
HR	Employee data protection, training
All Staff	Follow policies, report issues

How Bastion Helps

Maintaining GDPR compliance is an ongoing commitment that benefits from experienced support. Working with partners who understand both the regulatory requirements and practical implementation helps ensure compliance remains sustainable as your business grows.

Challenge	How We Help
Continuous Monitoring	Tracking compliance status and surfacing issues before they become problems
Documentation Updates	Support for keeping policies and records current as practices evolve
Regulatory Changes	Guidance on regulatory updates and their implications for your business
Staff Training	Awareness programs that keep privacy top of mind across your organization
Vendor Management	DPA tracking, renewal reminders, and sub-processor change monitoring
Expert Support	Access to experienced guidance when questions or incidents arise

Ongoing Support Model

Service	Description
Quarterly Reviews	Regular compliance health checks to catch drift early
Change Support	Privacy review when launching new products, vendors, or markets
Incident Support	Expert guidance during breaches or regulatory inquiries
Training	Ongoing staff awareness programs with periodic refreshers
Documentation	Help keeping policies and procedures current

Having ongoing support means you're not starting from scratch each time a compliance question arises—and that expertise is available when time-sensitive situations occur.

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