Artifact GuideEU

EU GDPR Checklist

Check whether a product, service, vendor, dataset, or workflow has the GDPR basics covered: scope, role, lawful basis, transparency, rights, DPIA, RoPA, contracts, transfers, breach response, retention, security, and accountability evidence.

Built from official EU text and regulator guidance; designed for privacy, legal, product, security, procurement, support, HR, marketing, and data governance teams.

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Author

Sorena AI

Published

May 9, 2026

Updated

May 9, 2026

Sections

Structured answer sets in this page tree.

Primary sources

Cited legal and guidance references.

Publication metadata

Sorena AI

Published May 9, 2026

Updated May 9, 2026

Overview

Use this checklist before launching or materially changing processing of personal data. It does not supersede legal interpretation guidance, but it gives teams a concrete GDPR control record: what was checked, which owner approved it, which evidence exists, and what must be reopened when the processing changes.

Section 1

Scope, role, lawful basis, and transparency

Start by proving that the activity is or is not GDPR processing. Record the personal data, data subjects, processing operations, controller or processor role, establishment or EU-targeting facts, and whether any special category or criminal-offence data is involved.

For each purpose, assign one Article 6 lawful basis before collection or use. If consent is used, keep the consent wording, capture event, withdrawal route, and evidence that consent was freely given, specific, informed, and unambiguous. If legitimate interests is used, keep the interest, necessity analysis, balancing outcome, and objection route.

Scope check: identify whether personal data is processed by automated means or in a filing system, and document any Article 2 or Article 3 reason the GDPR does or does not apply.
Role check: name the controller, joint controller, processor, or sub-processor and record who determines purposes and means.
Lawful-basis check: map every processing purpose to Article 6; add Article 9 or Article 10 handling where special category or criminal-offence data is present.
Transparency check: ensure Articles 13 and 14 notices state controller identity, DPO contact where applicable, purposes, legal basis, recipients, transfers, storage period or criteria, rights, complaint route, and automated decision-making details where relevant.
Design check: confirm data minimisation, purpose limitation, accuracy, storage limitation, integrity, confidentiality, and accountability controls are reflected in product requirements and operational runbooks.

Sources for this answer

Regulation (EU) 2016/679 (GDPR)

Supports the checklist items for material and territorial scope, definitions, Article 5 principles, Article 6 lawful bases, Article 9 special-category conditions, and Articles 13-14 transparency content.

Section 2

Rights, DSARs, retention, erasure, and RoPA

Create a rights workflow that can receive, verify, triage, fulfil, refuse, or extend requests without relying on ad hoc inbox searches. The access workflow should cover confirmation of processing, the personal data itself, required processing information, transfer safeguards, and a copy of the data where required.

Keep the RoPA close to the actual processing inventory. A useful RoPA is not a policy pointer; it lists processing activities, owners, data subject categories, personal data categories, recipients, transfers, erasure time limits where possible, and security measures where possible.

DSAR intake: record request channel, receipt date, requester identity check, requested right, systems to search, response owner, and deadline; Article 12 generally requires action without undue delay and within one month, with a possible two-month extension for complex or numerous requests.
Access response: include confirmation whether processing occurs, purposes, data categories, recipients, storage period or criteria, rights, complaint route, source information where data was not collected from the requester, automated decision-making information where relevant, and Article 46 safeguards for third-country transfers.
Erasure and restriction: check whether Article 17 erasure grounds apply, whether another legal basis or retention duty prevents deletion, and whether recipients must be told about rectification, erasure, or restriction.
Retention: tie each data category to a purpose and erasure time limit or criteria; do not keep data because a future use might appear later.
RoPA: maintain controller and processor records in writing, including electronic form, and make sure they are self-contained enough to be provided to a supervisory authority on request.

Sources for this answer

Regulation (EU) 2016/679 (GDPR)

Supports Article 12 request timing and modalities, Article 15 access content, Article 17 erasure grounds, Article 19 recipient notification, Article 30 records, and storage limitation under Article 5.

Irish DPC - Records of Processing Activities under Article 30 GDPR

Supports the RoPA checklist, including granular business-function records, retention detail, security-measure descriptions, update discipline, and self-contained records.

Section 3

DPIA, processors, transfers, and breach response

Treat DPIA, vendor, transfer, and incident checks as launch gates. They should be complete before high-risk processing begins, before a processor receives data, before a third-country transfer starts, and before incident teams need to make 72-hour notification decisions.

Do not treat SCCs as a signature-only exercise. The transfer record should identify the exporter, importer, countries, data, transfer tool, SCC module and annexes, safeguards, and review trigger for legal or technical changes that could affect the transfer.

DPIA trigger: run a DPIA before processing likely to result in high risk; document processing description, necessity and proportionality, risks to rights and freedoms, safeguards, DPO advice where applicable, data-subject views where appropriate, sign-off, and review triggers.
Processor contract: before a processor starts, check sufficient guarantees, documented instructions, confidentiality, Article 32 security, sub-processor authorisation and flow-down, rights assistance, breach assistance, return or deletion at service end, audit cooperation, and written or electronic contract form.
Transfer check: identify all third-country access, including remote support and cloud access; verify adequacy or another Chapter V transfer tool; for SCC transfers, keep the signed clauses, module selection, annexes, transfer description, safeguards, and review trigger.
Breach workflow: detect and escalate security incidents quickly, decide whether a personal data breach occurred, assess risk to individuals, notify the supervisory authority without undue delay and where feasible within 72 hours unless unlikely to result in risk, and communicate to individuals without undue delay when high risk is likely.
Breach record: document all personal data breaches, including facts, effects, remedial action, risk assessment, notification decision, reasons for delay if applicable, and controller or processor hand-offs.

Sources for this answer

Regulation (EU) 2016/679 (GDPR)

Supports Article 28 processor contracts, Article 32 security, Articles 33-34 breach notification and communication, Article 35 DPIA requirements, and Chapter V transfer rules.

Irish DPC - Data Protection Impact Assessments

Supports operational DPIA checks, including early project-stage assessment, stakeholder input, DPO advice, processor assistance, sign-off, and review of residual risk.

European Commission - Standard Contractual Clauses

Supports the SCC transfer-tool checklist and Commission resources for international data-transfer clauses.

Section 4

Security, accountability, and evidence to keep

Close the checklist only when the evidence shows both compliance design and operating reality. For each processing activity, keep the source citation, control owner, approval, implementation proof, and reopening trigger together.

Security evidence should be risk-based. Article 32 points to measures such as pseudonymisation, encryption, confidentiality, integrity, availability, resilience, restoration capability, and regular testing, but the selected controls must fit the nature, scope, context, purposes, and risk of the processing.

Minimum evidence pack: processing map, role analysis, lawful-basis record, notice text, DSAR procedure, RoPA row, DPIA screening or DPIA report, processor contract review, transfer assessment, breach runbook, retention schedule, and security-control mapping.
Security proof: record access controls, encryption or pseudonymisation decisions, logging, backup and restoration tests, vulnerability or control testing, incident escalation, staff confidentiality and training, and processor security evidence.
Accountability proof: keep approvals by privacy, legal, product, security, vendor, and business owners; record exceptions with rationale, compensating controls, expiry date, and escalation owner.
Reopen triggers: new purpose, new data category, special-category data, new recipient, new processor or sub-processor, new third-country access, high-risk processing change, incident, DSAR failure, retention change, or material security-control change.
Quality check: every checklist item should answer who owns the control, what source supports it, what evidence proves it, where the evidence is stored, and when the item must be reviewed.

Sources for this answer

Regulation (EU) 2016/679 (GDPR)

Supports accountability under Article 5(2), controller responsibility under Article 24, data protection by design and default under Article 25, and security of processing under Article 32.

ENISA - Handbook on Security of Personal Data Processing

Supports risk-based security checks for confidentiality, integrity, availability, and technical and organisational measures.

Irish DPC - Records of Processing Activities under Article 30 GDPR

Supports keeping RoPA evidence granular, current, self-explanatory, and ready to provide on request.

Recommended next step

Use the checklist to assign owners and close evidence gaps

Sorena can turn the GDPR checks on this page into cited tasks, owner assignments, evidence requests, and reusable review records for privacy, product, security, vendor, and support teams.

Research workflow

Open Research Copilot for EU GDPR

Ask source-linked questions about GDPR scope, lawful basis, DSARs, DPIAs, RoPA, processors, transfers, breach handling, and evidence using the cited sources on this page.

Explore next step

Talk to Sorena

Talk through implementation

Review your GDPR checklist owners, source support, transfer records, processor contracts, and evidence gaps with Sorena.

Explore next step

Primary sources

References and citations

ENISA - Handbook on Security of Personal Data Processing

enisa.europa.eu

Referenced sections

Supports risk-based security checks for confidentiality, integrity, availability, and technical and organisational measures.

"confidentiality, integrity and availability"

European Commission - Standard Contractual Clauses

commission.europa.eu

Referenced sections

Supports the SCC transfer-tool checklist and Commission resources for international data-transfer clauses.

"Standard Contractual Clauses"

Irish DPC - Data Protection Impact Assessments

dataprotection.ie

Referenced sections

Supports operational DPIA checks, including early project-stage assessment, stakeholder input, DPO advice, processor assistance, sign-off, and review of residual risk.

"high risk processing projects"

Irish DPC - Records of Processing Activities under Article 30 GDPR

dataprotection.ie

Referenced sections

Supports keeping RoPA evidence granular, current, self-explanatory, and ready to provide on request.

"living and dynamic document"

Regulation (EU) 2016/679 (GDPR)

eur-lex.europa.eu

Referenced sections

Supports accountability under Article 5(2), controller responsibility under Article 24, data protection by design and default under Article 25, and security of processing under Article 32.