You should document what personal data you hold, where it came from and who you share it with. You may need to organise an information audit across the organisation or within particular business areas.

You should review your current privacy notices and put a plan in place for making any necessary changes in time for GDPR implementation.

You should check your procedures to ensure they cover all the rights individuals have, including how you would delete personal data or provide data electronically and in a commonly used format.

You should update your procedures and plan how you will handle requests to take account of the new rules.

You should identify the lawful basis for your processing activity in the GDPR, document it and update your privacy notice to explain it.

You should review how you seek, record and manage consent and whether you need to make any changes. Refresh existing consents now if they don’t meet the GDPR standard.

You should start thinking now about whether you need to put systems in place to verify individuals’ ages and to obtain parental or guardian consent for any data processing activity.

You should make sure you have the right procedures in place to detect, report and investigate a personal data breach.

It has always been good practice to adopt a privacy by design approach and to carry out a Privacy Impact Assessment (PIA) as part of this. However, the GDPR makes privacy by design an express legal requirement, under the term ‘data protection by design and by default’. It also makes PIAs – referred to as ‘Data Protection Impact Assessments’ or DPIAs – mandatory in certain circumstances.

You should designate someone to take responsibility for data protection compliance and assess where this role will sit within your organisation’s structure and governance arrangements.

If your organisation operates in more than one EU member state, you should determine your lead data protection supervisory authority and document this.