In today’s digital-first world, personal data is at the heart of almost every business transaction. The UK General Data Protection Regulation (GDPR) sets out a framework for how organisations must handle personal data, with the aim of protecting individuals’ rights and ensuring transparency. For UK businesses, GDPR compliance is not just a legal requirement - it’s a vital part of building trust with clients, partners and employees.

Navigating GDPR can seem daunting, especially for those just starting out, but with a clear action plan, you can lay strong foundations, reduce your risk and set your business up for long-term success.

Our Data Protection team has created a practical checklist to help you focus on the basics. This checklist is not exhaustive, but it covers the key actions you should consider. For tailored advice, please get in touch with the team.

Your GDPR compliance checklist: the essentials

1. Secure stakeholder buy-in

GDPR compliance starts at the top of the organisation. Senior management must understand the importance of data protection and commit to supporting compliance efforts. This means allocating sufficient resources - both financial and personnel - to drive the process. Without leadership buy-in, it’s difficult to embed a culture of privacy across the organisation.

Tip: Align with a senior stakeholder with board-level responsibility.

2. Assign responsibility

GDPR requires some organisations to appoint a Data Protection Officer (DPO), especially if you process large volumes of sensitive data or monitor individuals systematically. Even if you’re not legally required to have a DPO, it’s good practice to designate someone responsible for data protection, or to set up a working group.

If your business operates outside the UK or in Europe, you may need to appoint representatives in those jurisdictions to ensure compliance.

Tip: Clearly define roles and responsibilities, and ensure your data protection lead has the authority to drive change and has a seat at a senior stakeholder level.

3. Map your data flows

Before you can protect personal data, you need to know what you have, where it’s stored, how it’s used and who has access. Data mapping is the foundation for all other compliance steps, helping you identify risks, streamline processes and ensure you’re meeting GDPR requirements.

Action points:

  • List all sources of personal data (e.g., website forms, HR records, customer databases)
  • Document how data moves through your organisation
  • Identify any third parties who process data on your behalf
  • Understand what data is being used for

4. Record processing activities

Maintaining a record of all personal data processing activities is a legal requirement under GDPR. This record should include details such as the types of data processed, the purposes of processing and any third-party recipients.

Action points:

  • Use your data mapping exercise to inform your record
  • Update the record regularly as your business evolves
  • Make the record available to regulators if requested

5. Review legal basis for processing

For each activity involving personal data, you must identify and document the legal basis for processing. These are set out in GDPR and include contract, legal obligation, legitimate interests and consent. Avoid relying solely on consent unless absolutely necessary and keep evidence of consent where used.

If you use “legitimate interests” as a basis, conduct a legitimate interest assessment to document your rationale.

For special category data, you will need an additional lawful basis.

Tip: Review your data processing activities regularly to ensure the legal basis remains valid.

6. Create policies and privacy notices

Your data protection policy should provide an overview of GDPR requirements relevant to your business. Privacy notices must be clear, accessible and tailored for different data subjects, and they should cover all required information under GDPR Article 13, including the purposes of processing, data retention periods and individuals’ rights.

Action points:

  • Create general policies and update them as needed
  • Create processes to operationalise specific areas (e.g., data retention, data breach escalation)
  • Ensure privacy notices are accurate, complete, contain all the mandatory information and are easy to find and understand

7. Prepare for data subject rights

Individuals have the right to access, rectify, erase and restrict the processing of their personal data. Establish procedures for handling these requests, and train staff to recognise and respond promptly.

Action points:

  • Ensure you have tools to isolate data pertaining to a specific individual
  • Train employees to spot and action requests
  • Know who in the business (or externally) will be able to action and respond to requests

8. Plan for data breaches

Data breaches can happen to any organisation at any time. GDPR requires that organisations report breaches that have a risk to individuals and requires reporting to individuals if there is a high risk.

Action points:

  • Create a data breach response team
  • Document breach notification procedures
  • Train staff to understand what a breach is and how to report a breach
  • Run simulations to practice how to respond to a breach
  • Consider insurance

Read our recent article to learn more about incident response planning, how to manage a breach and what your reporting duties are under GDPR.

9. Assess third party contracts

GDPR requires a minimum set of mandatory clauses to be included in contracts with suppliers and service providers who process personal data on your behalf. You should conduct due diligence to assess whether your processors meet GDPR standards.

Action points:

  • Use questionnaires to streamline the diligence process
  • Use template processor clauses in your contracts

10. Train and raise awareness

Staff need to understand their data protection responsibilities in order for the organisation to comply with its obligations. Without this awareness, data could be accessed and shared inappropriately, breaches may not be reported and individuals will not be able to exercise their rights.

Action points:

  • Provide regular training tailored to different roles
  • Run awareness campaigns with simple do's and don'ts
  • Schedule annual refresher courses

11. Consider marketing and children’s data

Review how you obtain consent for marketing communications and ensure previous consents meet GDPR standards. Update consent wording if necessary.

If you process children’s data, assess compliance with the Age Appropriate Design Code and implement additional safeguards.

Tip: Regularly audit your marketing lists and consent records.

Common pitfalls to avoid

  • Failing to keep records up to date
  • Overlooking third-party risks
  • Neglecting staff training
  • Relying on outdated policies or privacy notices

Next steps to achieve GDPR compliance

GDPR compliance is a journey, not a one-off task. By focusing on these basics, you’ll build a strong foundation and reduce your risk. However, every organisation is unique, and the stakes are high.

Ready to take action? For expert guidance tailored to your business, contact our Data Protection team. We can help you navigate the complexities, avoid common pitfalls and ensure your compliance programme is robust and future-proof.