Implementing GDPR (General Data Protection Regulation) compliance for our system is essential as our primary clientele is based in the UK. Our GDPR development and implementation technical plan is comprised of the following key phases:
1. Assess the Current Situation:
Data Audit: Identify what personal data is currently stored in the CRM. Determine where it’s sourced from, how it’s processed, and if and where it’s shared.
Risk Assessment: Assess the risks associated with the current data handling processes.
2. Define GDPR-compliant Objectives:
Data minimization, accuracy, and storage limitation.
3. Data Protection by Design:
Integrate data protection into the CRM system development process.
Ensure encryption is used for data in transit and at rest.
Implement pseudonymization techniques where applicable.
4. Data Subject Rights:
Access: Ensure data subjects can view their data.
Rectification: Allow data subjects to correct inaccurate data.
Erasure (Right to be forgotten): Allow data subjects to request deletion of their data.
Data Portability: Ensure data can be exported in a machine-readable format.
Consent Management: Implement mechanisms to capture and store user consent. Make sure consent withdrawal is as easy as giving consent.
5. Vendor Management:
Review and vet third-party vendors (e.g., cloud providers) for GDPR compliance.
Update contracts with GDPR compliant clauses regarding data processing and protection.
6. Data Breach Protocols:
Develop procedures for detecting, reporting, and investigating personal data breaches.
Ensure notification mechanisms are in place to inform affected individuals and authorities within 72 hours of a breach.
7. Training and Awareness:
Train all employees accessing the CRM about GDPR principles, data rights, and their responsibilities.
Periodically refresh this training.
8. Data Protection Impact Assessment (DPIA):
Conduct a DPIA for high-risk processing activities to evaluate and minimize risks.
9. Appoint a Data Protection Officer (DPO):
Designate a DPO to oversee GDPR strategy and implementation if required based on the scale and nature of data processing.
10. Regular Audits & Reviews:
Periodically audit the CRM data and related processes to ensure GDPR compliance.
Address any identified non-compliance issues promptly.
11. Backup & Disaster Recovery:
Ensure regular backups of CRM data.
Develop a robust disaster recovery plan to restore data in case of any losses.
12. Integration & APIs:
Ensure any integration or APIs that allow data transfer in/out of the CRM are GDPR compliant.
Maintain clear documentation of these data flows.
In particular, develop and maintain the GDPR impact assessment and risk management policy for Linkedin data integration.
13. Ongoing Monitoring and Maintenance:
Monitor evolving GDPR interpretations and case law. Adjust CRM processes as needed to remain compliant.
14. Documentation:
Maintain detailed documentation on GDPR compliance processes, including DPIAs, consent records, data processing activities, and data breach incidents.
