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GDPR Preparation Project Plan NOTE: All tasks and resources assigned are approximations and will depend on the specifics of your project. If appointed, the Data Protection Officer may take the role of Project Lead. Ref.
Task 1
1.1 1.2 1.3 1.4 2 2.1 2.2 2.3 2.4 2.6 2.7 2.8
3 3.1 3.2 3.3 3.4 3.5 4 4.1 4.2 4.3 4.4 5 5.1 5.2 6 6.1 6.2 6.3 6.4 6.5 7 7.1 7.2 7.3 8 8.1 8.2 8.3 9 9.1 9.2 9.3 9.4 10 10.1 10.2 10.3
Main GDPR Reference
Effort (man-days)
Resource
Progress
Status
Project Manager, Project Lead Project Manager, Project Lead Project Manager Project Manager
0% 0% 0% 0%
Not started Not started Not started Not started
CHAPTER IV - Section 4 - Data protection officer CHAPTER IV - Section 4 - Data protection officer CHAPTER IV - Section 4 - Data protection officer CHAPTER IV - Section 4 - Data protection officer
Project Lead Project Lead, Senior Management Project Lead, Senior Management, Legal Senior Management Project Lead Project Lead Project Lead, Information Security Manager
0% 0% 0% 0% 0% 0% 0%
Not started Not started Not started Not started Not started Not started Not started
CHAPTER II - Principles CHAPTER II - Principles Article 6 - Lawfulness of processing Article 6 - Lawfulness of processing Article 30 - Records of processing activities
Project Lead Business Area Leads Business Area Leads, Legal Business Area Leads, Legal Project Lead
0% 0% 0% 0% 0%
Not started Not started Not started Not started Not started
Article 5 - Principles relating to processing of personal data Articles 13 and 14 - Information to be provided Article 7 - Conditions for consent Article 8 - Conditions applicable to child's consent
Project Lead, Business Area Leads, Legal Business Area Leads Business Area Leads Business Area Leads
0% 0% 0% 0%
Not started Not started Not started Not started
CHAPTER III - Rights of the data subject CHAPTER III - Rights of the data subject
Project Lead Data Subject Request Administrator
0% 0%
Not started Not started
CHAPTER IV - Section 1 - General obligations CHAPTER IV - Section 1 - General obligations CHAPTER IV - Section 1 - General obligations CHAPTER IV - Section 1 - General obligations CHAPTER IV - Section 1 - General obligations
Legal Legal Legal, IT Management Legal Human Resources
0% 0% 0% 0% 0%
Not started Not started Not started Not started Not started
CHAPTER IV - Section 3 - Data protection impact assessment CHAPTER IV - Section 3 - Data protection impact assessment CHAPTER IV - Section 3 - Data protection impact assessment
Project Lead Project Lead Business Area Leads
0% 0% 0%
Not started Not started Not started
CHAPTER V - Transfers of personal data to third countries CHAPTER V - Transfers of personal data to third countries Put in place agreements for international transfers of personal data (where required) CHAPTER V - Transfers of personal data to third countries Personal data breach management
Project Lead, Business Area Leads, Legal Legal Legal
0% 0% 0%
Not started Not started Not started
Create information security incident management procedure Create personal data breach notification procedure Conduct information security incident management training Test incident management and breach notification procedures
Project Lead, Information Security Manager Project Lead Project Lead, Information Security Manager Project Lead, Information Security Manager
0% 0% 0% 0%
Not started Not started Not started Not started
Project Manager, Project Lead Project Manager, Project Lead Project Manager, Project Lead, Business Area Leads, Legal, IT Management, Senior Management
0% 0% 0%
Not started Not started Not started
GDPR preparation project Perform gap assessment Gain senior management commitment Initiate project with appropriate resources and budget Establish document control
GDPR roles, awareness and training Conduct communication programme to suppliers and other stakeholders Define GDPR roles and responsibilities Identify lead Data Protection Supervisory Authority Appoint Data Protection Officer (if required) Conduct GDPR competence and training needs assessment Perform GDPR-related training and familiarisation Conduct GDPR and information security awareness training
Personal data mapping Conduct initial personal data information gathering exercise Perform audit of personal data by business area Identify lawful basis for processing personal data in each case Conduct legitimate interest assessments where required Identify record-keeping requirements and procedures
Privacy policies and notices Define personal data retention and protection policy Create or amend existing privacy notices Review and amend consent methods and procedures Address age-related consent and controls (children)
Rights of the data subject Create and implement data subject request procedures Start recording data subject requests
Controllers and processors Update contracts with processors to be GDPR compliant Distribute supplier questionnaires regarding personal data protection Provide information to controllers for whom we act as a processor Update contracts with controllers to be GDPR compliant Address employee confidentiality requirements
Data protection impact assessment Define data protection impact assessment process Conduct data protection impact assessment training Perform initial data protection impact assessment
International transfers Identify international transfers of personal data Assess legality of existing international transfers
CHAPTER IV - Section 2 - Security of personal data CHAPTER IV - Section 2 - Security of personal data CHAPTER IV - Section 2 - Security of personal data CHAPTER IV - Section 2 - Security of personal data
Project closure Repeat gap assessment to identify remaining non-compliant areas Address any remaining non-compliant areas Perform post-project review
Start Date
End Date