If your company operates in the European Union or processes personal data of EU residents, complying with the GDPR is not optional. But knowing the regulation is one thing, implementing it correctly in day-to-day operations is another.
Whether you’re launching a startup or scaling fast, the key question is: How do we make the GDPR work in practice, not just on paper?
1. Start with a clear data inventory
You can’t protect what you don’t know. Effective GDPR implementation begins by identifying what personal data you collect, where it’s stored, who has access to it and for what purpose.
Map data flows across teams, tools and vendors. Pay special attention to shadow IT (those apps or tools teams use without going through IT). This visibility helps you apply principles like data minimisation and purpose limitation, and document your Records of Processing Activities (ROPA).
One of the tools the GDPR requires from controllers to demonstrate compliance is maintaining ROPA for the data they process under their responsibility and control, bearing in mind their duty to cooperate with the Supervisory Authority, including making these records available to support the oversight activities carried out under the powers granted to the authority by the GDPR.
2. Define your legal bases, don’t rely solely on consent
Many companies use consent as the default legal basis, but the GDPR provides six different bases. Consent is useful in certain cases but also the most fragile: easy to withdraw and hard to track.
Assess whether the processing can rely on contract performance, compliance with a legal obligation or legitimate interest. This makes your programme more robust and reduces dependence on unnecessary banners and forms.
3. Integrate privacy by design
Privacy shouldn’t be something you add at the end. Apply privacy by design and by default from the start of your projects. Involve your DPO or legal contact during the planning phase. Collect only the data you truly need and document the purpose behind every functionality.
Embed privacy into your sprint cycles and decision-making processes. This avoids rework, speeds up audits and improves user experience.
“Privacy by design costs less than fixing issues later.”
4. Train the whole team, not just Legal or IT
GDPR compliance isn’t just a Legal or IT responsibility. Every team handles personal data, from Sales to Support.
Provide training tailored to each role. In Spain, you can subsidise this training through FUNDAE. At PrivaLex, we not only deliver the sessions but also manage the entire FUNDAE process so you can recover the cost.
5. Manage your vendors properly
Your level of compliance also depends on your processors. Under the GDPR, you must ensure that any processor you work with provides adequate guarantees.
Review contracts, keep an updated list of vendors and require specific data protection clauses. A solid Data Processing Agreement (DPA) is essential.
6. Have a plan to respond to data subject requests
Individuals have the right to access, rectify, erase or port their data. But these rights only work if your company can respond within the deadline (usually 30 days).
Document a clear procedure, define who handles it and automate what you can. Don’t forget to anticipate complex cases, such as fraudulent requests or data belonging to former employees.
7. Review, improve and update
The GDPR isn’t a one-time project. Technology evolves, risks change and so does your business.
Conduct periodic reviews of policies, security measures and vendors. Assess new risks, document decisions and improve continuously.
An external DPO or privacy consultant can help keep your programme up to date without overwhelming your internal team.
In summary
Implementing the GDPR isn’t just about avoiding fines. It helps you build trust, offer stronger guarantees, professionalise your processes and prepare to grow securely.
At PrivaLex, we help you turn the GDPR into a competitive advantage, from audits and assessments to training and external DPO services.
