The General Data Protection Regulation (GDPR) is a landmark EU legislation that protects the personal data of EU citizens and grants them greater rights over how that data is collected, used, and shared.

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As a comprehensive regulation, GDPR has many rigorous and evolving requirements to address emerging threats. These updates create the need for regular compliance audits, which can become costly and time-consuming without a structured approach.

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In this article, we’ll show you how to conduct a GDPR compliance audit in eight simple steps. We’ll also discuss:

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• The importance of GDPR compliance audits
• Potential challenges to anticipate

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What is a GDPR compliance audit?

A GDPR compliance audit is a formal evaluation of an organization’s adherence to the data security and privacy requirements set out by the regulation. Its purpose is to review your existing policies, procedures, and safeguards to identify potential compliance gaps.

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While GDPR compliance is an ongoing effort, it’s considered best practice to conduct comprehensive internal assessments at least once a year. This enables you to identify areas for improvement and gain greater assurance that your organization is aligned with the regulation.

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Who can conduct a GDPR audit?

GDPR does not mention any formal certification for auditors. Technically, anyone with enough knowledge and access to evaluate compliance can conduct the GDPR audit.

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In practice, organizations conduct the audit internally or bring in a qualified auditor or GDPR consultant to oversee the process, depending on their needs and resources. The key stakeholders in a GDPR compliance audit include:

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• Data protection officer (DPO)
• Security and compliance teams
• Legal team
• Senior leadership
• Teams handling in-scope processing activities

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Organizations may also be subject to data protection audits and investigations by the GDPR data protection authority in the relevant EU Member State. In essence, the investigations function like audits. The authorities have the power to review your operations and impose fines and corrective actions, if necessary.

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{{cta_withimage14="/cta-blocks"}} | GDPR compliance checklist

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Are GDPR compliance audits mandatory?

GDPR doesn’t explicitly require internal or external audits, but they’re widely recognized as best practice and a core part of ongoing compliance.

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Regular audits help you stay on top of any changes to the regulation, minimizing the risk of non-compliance, and the resulting financial penalties or corrective actions from supervisory authorities. They also serve as an effective way to demonstrate your dedication to data security, which may translate into a competitive advantage in industries where data protection matters most.

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Data protection authorities (DPAs) also encourage regular audits as an efficient way for organizations to maintain readiness for inspections and external assessments.

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How to conduct a GDPR compliance audit in 8 steps

The approach to conducting your audit will vary depending on your organization’s location, size, sector, and the types of data you typically process. However, most GDPR compliance audits follow these eight general steps:

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1. Establish the scope for the audit
2. Map organizational data flows and processing activities
3. Assess legal bases for data processing
4. Evaluate compliance with data subject rights
5. Audit data safeguards
6. Verify third-party compliance
7. Remediate identified gaps
8. Document the process and findings

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Step 1: Establish the scope for the audit

The first step is to determine the scope of your GDPR compliance audit. In practice, this means identifying and documenting the key compliance areas and processing activities you’ll cover in your audit.

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One of the key reasons for this scoping exercise is purpose limitation: data subject consent and lawful bases are only valid for a specific purpose unless specified differently. If you’re relying on the same basis for multiple purposes, you need to treat each of them as a separate processing activity and conduct individual audits.

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Although it may not be a key factor, you should also consider your organization’s role. If you’re a data controller, your audits will cover more evaluation parameters due to the greater compliance obligations you have under Article 24.

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When defining your audit scope, make sure to include:

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• Data sets
• Systems
• Networks
• Processing activities
• Cross-border transfers
• Personnel

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Being thorough during scoping is essential. This step informs the rest of the audit process, and overlooking certain assets can lead to incomplete findings and potential non-compliance. You may also have to re-establish the scope, which can significantly drive up costs.

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It’s important for organizations to understand the essence of their obligations under GDPR and not overcomplicate and overdocument required mechanisms. This may lead to convoluted and improper implementation of requirements, potentially resulting in compliance gaps. Leveraging consistent processes and templates for mechanisms required under GDPR, such as the RoPA and DPIA, will lead to a more efficient compliance effort and audit.”

Ethan Heller

GRC Subject Matter Expert, Vanta

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LinkedIn

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Step 2: Map organizational data flows and processing activities

Once you have a clearly established scope, the next step is to pinpoint where personal data enters your organization. Usual entry points include websites, apps, online forms, and any other tools that collect personal information.

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Mapping these entry points lets you trace the full data lifecycle and touchpoints, revealing how information flows through your systems and shaping the audit process.

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While mapping, it’s essential to document:

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• Stage-specific processing activities: How data is collected, stored, used, and disposed of
• Storage locations: Databases, backups, cloud storage, and any physical archives

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Step 3: Assess legal bases for data processing

With a clear overview of your data flows, you can now review your legal basis for processing sensitive information.

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Under the GDPR, you can only store and process personal data if you have a legitimate, documented reason to do so. This ensures that your activities are justified and align with the regulation’s intent to protect data subject rights.

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The GDPR defines six legal bases:

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1. Data subject consent
2. Contractual requirements
3. Legal obligations
4. Vital interest
5. Public interest
6. Legitimate interest

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As part of evaluating your legal basis, consider the principle of data minimization (Article 5). You should only collect and store the minimum amount of data necessary for the processing purpose you’ve identified.

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You should also review any sensitive data you already store to confirm it’s necessary for your stated purpose. If you identify data that’s not needed anymore, safely dispose of or anonymize it to minimize risk and maintain GDPR compliance.

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Step 4: Evaluate compliance with data subject rights

The eight data subject rights are key provisions of the GDPR, designed to give EU citizens greater control over their personal information and the ability to hold organizations accountable for how their data is handled. Some of the most relevant rights include:

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• Right to be informed
• Right of rectification
• Right to be forgotten
• Right to data portability

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As part of your audit, you’ll need to review the procedures that help you honor these rights.  That includes evaluating your privacy notices and updates, information disposal processes, and data transfer policies.

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Step 5: Audit data safeguards

Next, you need to audit your existing security controls. Many of the GDPR’s requirements are shaped by the seven data protection principles, so you must align your controls with them to ensure compliance.

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In this step, you’ll need to review:

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• Access controls: Who can access sensitive information and under what conditions
• Firewalls: Safeguards against unauthorized access and network threats
• Encryption: Protection of sensitive data at rest and in transit
• Incident response plans: Protocols for identifying, mitigating, and reporting security incidents within the required time frame

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If your processing activities pose a high risk to the freedoms and rights of individuals, you should also conduct a data protection impact assessment (DPIA). This evaluation should be conducted before and during your processing activities so you can proactively identify and mitigate risks to personal data.

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{{cta_withimage11="/cta-blocks"}}| The US data privacy checklist

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Step 6: Verify third-party compliance

Building on the previous step, evaluate your vendors as part of ongoing GDPR compliance. Confirm they have GDPR-compliant policies and data protection measures in place.

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This step involves the following activities:

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• Reviewing your data processing agreements: Verify that contracts clearly define processing obligations, breach notification requirements, and liability for incidents
• Evaluating the vendor’s data storage and processing infrastructure: Assess how the vendor collects, stores, and processes personal data, and whether it implements measures such as access controls and disaster recovery plans
• Assessing the vendor’s compliance documentation: Check attestations, audit reports, certifications, and other relevant documentation that demonstrate GDPR compliance

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Depending on your organization’s processing activities, you should maintain records of which vendors (processors and subprocessors) have access to personal data so you can perform adequate security assessments on them. Vendors working with particularly sensitive information or high volumes of data may require a higher review cadence.

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Step 7: Remediate identified gaps

Once you’ve completed your assessments and third-party evaluations, use the findings to remediate any identified gaps. The remediation plan may include various tasks, such as:

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• Updating personal information
• Disposing of unnecessary information
• Creating new security policies and procedures
• Introducing new technologies
• Developing data subject rights workflows

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Focus your efforts on the highest-risk, highest-impact gaps first to maximize your remediation outcomes. Assign clear roles and responsibilities in this step, so stakeholders understand their duties and can meet timelines easily.

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You should also establish continuous monitoring procedures to track the effectiveness of your newly updated workflows and maintain GDPR compliance in the long run.

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Step 8: Document the process and findings

The GDPR emphasizes accountability as a core principle. Maintaining thorough documentation is an effective way to demonstrate compliance to data subjects, auditors, and potential partners.

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You should collect, review, and update all documentation relevant to the processing activities you’re auditing, which includes:

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• Access logs
• Records of Processing Activities (RoPAs)
• Data protection policies
• Breach notification procedures
• Privacy notices

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Maintaining detailed documentation can streamline future audit efforts by providing a roadmap you can use to evaluate resource allocation early in the audit process.

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Present your audit results in a format that clearly highlights uncovered risks, compliance gaps, and remediation actions. This helps your stakeholders quickly grasp priorities and make informed decisions about ongoing GDPR compliance efforts.

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{{cta_withimage14="/cta-blocks"}} | GDPR compliance checklist

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Challenges of GDPR compliance audits

Conducting GDPR compliance audits can be complex due to the regulation’s comprehensive scope and the number of workflows involved. The most common challenges organizations face in this process include:

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• Managing third-party risks: Gaining thorough insights into vendor security and risk posture requires significant effort and investment
• Meeting data subject rights: Handling data subject requests for access, deletion, or rectification can be challenging when the information is scattered across systems
• Monitoring controls and their effectiveness: Security and privacy controls need to be regularly tested and validated
• Keeping inventory up-to-date: Ensuring that RoPAs, access logs, and privacy policies are up to date becomes increasingly harder as the audit scope evolves
• Collecting necessary documentation: Conducting audits requires access logs, training completion reports, and processing agreements, which may be stored in different departments
• Maintaining the desired audit cadence: Each processing activity requires a separate audit, making a fixed audit frequency difficult to maintain without disrupting growth

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You can mitigate some of these challenges with dedicated automation software like Vanta that centralizes documentation, enables real-time insights, and ensures a consistent audit process.

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Prepare for audits efficiently with Vanta

Vanta is a leading trust management platform that helps organizations streamline GDPR compliance by operationalizing obligations and automating up to 50% of required workflows. It offers built-in guidance for GDPR’s seven protection principles, helping teams save time and resources while ensuring audit readiness.

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The platform offers a dedicated GDPR product that comes with numerous helpful features, such as:

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• Automated evidence collection powered by 400+ integrations
• Pre-built policy templates with a built-in customization tool
• Continuous monitoring and instant report generation
• Security and awareness training materials
• Inventory management in a centralized dashboard

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If you’ve already achieved or are pursuing compliance with standards such as SOC 2 or ISO 27001, you can make use of Vanta’s cross-mapping feature. It lets you reuse existing controls and speed up compliance processes.

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See firsthand how Vanta streamlines GDPR compliance by scheduling a custom demo.

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{{cta_simple19="/cta-blocks"}} | GDPR product page

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Frequently asked questions

What are examples of special category data?

This is particularly sensitive information, such as an individual’s political opinions, ethnic origins, genetic or biometric data, and trade union membership.

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How often should a GDPR compliance audit be conducted?

There isn’t a specified cadence, but industry best practices suggest conducting an audit at least annually. You should also perform audits after any major updates to the regulation or your operations, or following any security incidents.

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Does GDPR legally require an internal audit?

The GDPR doesn’t explicitly require internal audits. However, the regulation receives regular updates, making audits necessary to keep up with the changes.

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What is the ultimate outcome of a GDPR audit?

A GDPR audit conducted internally or externally typically results in one or more of the following:

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1. An assessment report that summarizes the key findings, compliance gaps, and potential risks
2. Remediation recommendations, usually with a roadmap for strengthening data protection practices
3. An assurance statement (or informal certification) to demonstrate that your organization has achieved or is maintaining GDPR compliance

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If you’re undergoing a regulatory investigation, the relevant authority may impose corrective measures or appropriate fines and penalties in case of an infringement.

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‍A note from Vanta: Vanta is not a law firm, and this article does not constitute or contain legal advice or create an attorney-client relationship. When determining your obligations and compliance with respect to relevant laws and regulations, you should consult a licensed attorney.