5 Steps to Conduct an Effective GDPR Risk Assessment in 2024

As businesses increasingly depend on data, strong data privacy practices are essential. The General Data Protection Regulation (GDPR) mandates stringent requirements for protecting personal data and upholding data subjects’ rights. A core part of GDPR compliance is conducting a GDPR risk assessment, which helps businesses pinpoint vulnerabilities in data processing and apply effective mitigation strategies to minimise compliance risks.

 A GDPR risk assessment systematically identifies, analyses, and addresses risks to personal data, providing valuable insights beyond regulatory needs. This guide covers the steps to conduct a GDPR risk assessment in 2024, ensuring your organisation maintains compliance and safeguards its reputation.

Here’s why GDPR risk assessments are essential for any business handling personal data:

• GDPR compliance: The GDPR mandates data protection impact assessments (DPIAs) and requires regular risk assessments to uphold data privacy standards. Businesses demonstrate accountability and commitment to GDPR compliance by identifying risks and implementing safeguards.
• Risk management: Assessing potential risks helps businesses prepare for threats, including data breaches, data loss, and unauthorised access. GDPR risk assessments reduce the likelihood of high-risk situations and ensure better protection of user rights.
• Enhanced data security: GDPR compliance goes hand-in-hand with data security. Through risk assessments, businesses can evaluate the effectiveness of their security measures and prevent potential data breaches.
• Reputation protection: Non-compliance or data security issues can damage a brand’s reputation. Conducting regular assessments shows stakeholders and customers that your organisation takes data protection seriously, enhancing trust.

A GDPR risk assessment is a structured process that involves identifying data, evaluating threats, analysing risks, implementing safeguards, and documenting compliance efforts. Here’s a step-by-step breakdown of each phase.

Step 1: Data mapping and inventory

The first step in conducting a GDPR risk assessment is data mapping and inventory. This process establishes a clear understanding of all personal data in your organisation’s processes, enabling you to identify where data is collected, stored, transferred, and shared.

• Determine what types of GDPR personal data are collected, from names and contact information to biometric and financial data.
• Record how personal data is collected, processed, and stored across departments and third-party processors. This includes understanding the purposes of the processing and identifying high-risk processing activities.
• Track the movement of data within and outside the organisation. This includes identifying data transfers to third-party vendors and data processors ensuring each step complies with GDPR requirements.

By thoroughly mapping data, you create a solid foundation for assessing risks associated with data processing operations.

Step 2: Identifying threats and vulnerabilities

Once you’ve mapped your data, the next step is identifying potential threats and vulnerabilities in your data processing activities. Under GDPR, threats can include both external and internal risks:

• Cyberattacks, data breaches, and unauthorised access pose significant risks to personal data. 
• Risks such as employee errors, weak access controls, or insufficient safeguards within IT systems must also be addressed. 

Identifying these risks involves systematically assessing each stage in data handling, from data collection to storage. This allows your organisation to pinpoint potential vulnerabilities and ensure appropriate protections are in place.

Step 3: Conducting risk and impact analysis

After identifying threats, conduct a risk and impact analysis. This process involves assessing the severity and likelihood of each identified risk, allowing you to prioritise actions based on the level of risk.

• Impact assessment: Assess the potential consequences of each risk, considering factors like data sensitivity, regulatory fines, and damage to brand reputation. High-impact risks require immediate mitigation strategies.
• Likelihood assessment: Determine the likelihood of each risk occurring. This evaluation helps prioritise risks, ensuring that high-risk areas are managed promptly.
• Risk tolerance: Define your organisation’s risk tolerance, i.e. the level of risk your business is willing to accept.

By thoroughly evaluating both impact and likelihood, your organisation can develop an actionable risk management plan that protects personal data while allocating resources effectively.

Step 4: Implementing security and mitigation measures

Based on the risk analysis, the next step is implementing data security measures to manage identified risks, including:

• Technical safeguards: These include encryption, data anonymisation, access controls, and data segmentation. Implementing these measures ensures that sensitive data remains secure and minimises the risk of data breaches.
• Organisational measures: Training employees on GDPR requirements, creating strict access protocols, and regularly auditing data processing activities help strengthen data security. Ensuring data protection by design within all systems reinforces compliance.

Preparing for potential data breaches or security incidents is essential. An effective incident response plan, combined with regular monitoring, helps organisations address vulnerabilities quickly, minimising potential harm.

Mitigation measures should be tailored to address specific risks identified in the assessment, and they should align with GDPR’s data security standards.

Step 5: Documentation and compliance reporting

Thorough documentation is critical for demonstrating GDPR compliance. This final step involves creating and maintaining detailed records of the risk assessment process, including all findings, implemented safeguards, and compliance actions.

For high-risk processing activities, a Data Protection Impact Assessment (DPIA) is often required. A DPIA records the impact of specific data processing operations on individuals’ privacy, fulfilling GDPR’s “data protection by design and by default” requirements.

Keep records of compliance measures and regular audits. Documenting your GDPR efforts demonstrates accountability and prepares your organisation for potential inquiries from supervisory authorities.

Various tools can assist in streamlining GDPR risk assessments, making compliance management more efficient:

• Data mapping software: Tools that help create data inventories and visualise data flows make the data mapping process straightforward.
• DPIA templates guide organisations through DPIAs for high-risk data processing activities, ensuring consistent risk analysis.
• Consent management platforms: Managing and documenting user consent is essential for GDPR compliance. They can help maintain consent logs, support audits, and streamline compliance reporting.

• Certifications: Getting trained and certified for international standards for security, such as ISO 27001, provides a structured methodology for conducting risk assessments, aligning with GDPR standards for information security.

Leveraging these tools can improve accuracy, reduce human error, and ensure a comprehensive approach to GDPR compliance.

GDPR compliance requires ongoing monitoring and adaptation. Regularly reviewing and updating your GDPR risk assessment ensures it remains effective as new risks emerge and regulations evolve. By embracing a proactive approach to risk management, your organisation can maintain compliance and enhance its overall data protection posture.