GDPR Compliance Checklist: 16-Item Guide for Startups

TL;DR

GDPR applies if you have EU users. This 16-item checklist covers privacy documentation, consent mechanisms, and data subject rights. 5 critical items must be fixed before launch, 7 important items within the first week, and 4 recommended items when you can.

Quick Checklist (5 Critical Items)

Create a privacy policyDocument what data you collect, why, and how you protect it

Implement consent mechanismsGet explicit consent before collecting personal data

Add cookie consent bannerGet consent before setting non-essential cookies

Enable account and data deletionUsers must be able to request deletion of their data

Create breach notification processMust notify authorities within 72 hours of a breach

Privacy Documentation 4

Create a privacy policyExplain what data you collect, why you collect it, how you use it, and how long you keep it. Must be clear and accessible. How to write a privacy policy

Document your data inventoryList all personal data you process, where it is stored, why you have it, and retention periods. How to create a data inventory

Identify legal basis for processingFor each type of data, document your legal basis: consent, contract, legal obligation, or legitimate interest. How to identify legal basis

Document third-party processorsList all services that handle your users' data. Verify they are GDPR compliant and sign Data Processing Agreements. How to manage data processors

Consent and Collection 4

Implement consent mechanismsGet explicit consent before collecting personal data. Consent must be freely given, specific, and informed. How to implement GDPR consent

Make consent withdrawal easyUsers must be able to withdraw consent as easily as they gave it. Do not bury the option. How to implement consent withdrawal

Add cookie consent bannerGet consent before setting non-essential cookies. Users must be able to decline and still use your site. How to add cookie consent

Keep consent recordsDocument when and how consent was given. You may need to prove consent was obtained properly. How to track consent records

Data Subject Rights 4

Enable data access requestsUsers can request a copy of all data you hold about them. You have 30 days to respond. How to handle data access requests

Implement data portabilityUsers can export their data in a machine-readable format like JSON or CSV. How to implement data export

Enable account and data deletionUsers can request deletion of their data. Process must delete from active systems and backups. How to implement data deletion

Allow data correctionUsers can request correction of inaccurate personal data you hold about them. How to handle data correction requests

Security and Breach Response 4

Implement appropriate security measuresEncryption, access controls, and security practices appropriate for the data you handle. How to implement GDPR security

Create breach notification processMust notify supervisory authority within 72 hours of becoming aware of a breach. Document your process. How to set up breach notification

Plan user breach notificationIf breach likely results in high risk to individuals, you must also notify affected users without undue delay. How to notify users of a breach

Implement data minimizationOnly collect data you need. Delete data when you no longer need it. Less data means less risk. How to implement data minimization

GDPR Is About Respect for Users

GDPR is not just a compliance checkbox. It represents a shift toward treating user data with respect. Users have the right to know what data you have, why you have it, and to have it deleted when they ask.

For startups, the key is to build privacy into your product from the start. It is much easier to build with privacy in mind than to retrofit compliance later.

Does GDPR apply to my startup?

If you collect personal data from people in the EU, yes. GDPR applies regardless of where your company is based. If you have EU users, you need to comply.

What happens if I violate GDPR?

Fines can reach 4% of annual global revenue or 20 million euros, whichever is higher. However, regulators typically start with warnings for small companies making good-faith efforts at compliance.

Do I need a Data Protection Officer?

Most startups do not need a dedicated DPO. It is required only if your core activities involve large-scale processing of sensitive data or systematic monitoring of individuals. However, someone should be responsible for data protection.

TL;DR

Quick Checklist (5 Critical Items)

Privacy Documentation 4

Consent and Collection 4

Data Subject Rights 4

Security and Breach Response 4

GDPR Is About Respect for Users

Does GDPR apply to my startup?

What happens if I violate GDPR?

Do I need a Data Protection Officer?

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Incident Response Checklist

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GDPR Compliance Checklist: 16-Item Guide for Startups