If your company processes personal data in the EU, whether as a controller or processor, it is subject to the General Data Protection Regulation (GDPR). But compliance is not just having a privacy policy on your website: it’s about being able to prove that you effectively protect personal data.
That’s where the GDPR audit comes in: a systematic review that helps identify risks, correct non-compliance and strengthen privacy management across the organisation.
What is a GDPR audit and when is it needed?
A GDPR audit is a structured assessment of an organisation’s level of compliance with GDPR obligations. It is not legally mandatory, but highly recommended in situations such as:
- Major changes in the business model or international expansion.
- Processing of sensitive or high-risk data.
- Periodic reviews (e.g., annually) to demonstrate proactive compliance.
“Complying with GDPR isn’t enough: you must be able to prove it, and the audit is your strongest tool.”
What should a complete GDPR audit include?
An effective audit must go beyond a legal checklist. It should examine every relevant aspect of the personal-data lifecycle in your company. Key elements include:
Record of processing activities (ROPA)
Do you have a complete and up-to-date record?
Does it include the lawful basis, purposes, retention periods and recipients?
Lawfulness and legal bases
Are you applying consent, contract, legitimate interest or legal obligation correctly?
Can you demonstrate this with documentation?
Information clauses and transparency
Is your privacy policy clear and accessible?
Do you provide the right information in forms, emails or apps?
Processor relationships
Do you have proper contracts with your providers? Do they offer adequate guarantees?
Do they include all mandatory Article 28 GDPR clauses?
International data transfers
Do you transfer data outside the EEA?
Do you use SCCs, BCRs or other valid post-Schrems II safeguards?
Data subject rights management
Do you have procedures to respond to access, rectification, erasure, objection, etc.? Do you respond on time?
Do you keep a record of these requests?
Security and technical and organisational measures (TOMs)
Have you assessed the risks?
Do you have proportional measures implemented and documented (encryption, access controls, backups, etc.)? Do you review them regularly?
Security breaches
Do you have an incident-response protocol? Do you know when to notify the DPA and the affected individuals?
Do you run drills or training?
Risk analysis, PIAs and impact reviews
Do you assess the impact before starting new high-risk processing?
Do you use validated templates and justify decisions? Do you mitigate the risks identified afterwards?
Training and awareness
Do you train your team in data protection?
Can you prove the training delivered and its frequency?
Who should conduct the audit?
The audit can be performed internally or externally, depending on resources and the company’s maturity level. However, having an external auditor or independent DPO provides objectivity, updated expertise and credibility with clients or authorities.
Growing companies often rely on specialised consultants or external DPO services to avoid overloading their legal or technical teams.
What are the benefits?
A well-executed audit not only supports GDPR compliance but also:
- Reduces the risk of sanctions and breaches.
- Increases trust among clients, investors and partners.
- Optimises internal data-related processes.
- Aligns privacy with business strategy.
“Privacy isn’t a barrier to business. A GDPR audit helps you grow with confidence.”
Conclusion
A GDPR audit is not an administrative burden, it is a strategic tool. It helps you understand where you stand, what you are missing, and how to demonstrate strong and proactive compliance.
At PrivaLex Partners, we help startups and digital companies audit their compliance clearly, efficiently and in a way that fits their business model. Whether as a step before certification or as part of your ongoing accountability, we can help you strengthen your position with clients, partners and regulators.