Gdpr doc 01 3 gdpr preparation project plan

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GDPR Preparation Project Plan NOTE: All tasks and resources assigned are approximations and will depend on the specifics of your project. If appointed, the Data Protection Officer may take the role of Project Lead. Ref.

Task 1

1.1 1.2 1.3 1.4 2 2.1 2.2 2.3 2.4 2.6 2.7 2.8

3 3.1 3.2 3.3 3.4 3.5 4 4.1 4.2 4.3 4.4 5 5.1 5.2 6 6.1 6.2 6.3 6.4 6.5 7 7.1 7.2 7.3 8 8.1 8.2 8.3 9 9.1 9.2 9.3 9.4 10 10.1 10.2 10.3

Effort (man-days)

Resource

Status

GDPR preparation project Perform gap assessment Gain senior management commitment Initiate project with appropriate resources and budget Establish document control

Project Manager, Project Lead Project Manager, Project Lead Project Manager Project Manager

Not started Not started Not started Not started

Project Lead Project Lead, Senior Management Project Lead, Senior Management, Legal Senior Management Project Lead Project Lead Project Lead, Information Security Manager

Not started Not started Not started Not started Not started Not started Not started

Project Lead Business Area Leads Business Area Leads, Legal Business Area Leads, Legal Project Lead

Not started Not started Not started Not started Not started

Project Lead, Business Area Leads, Legal Business Area Leads Business Area Leads Business Area Leads

Not started Not started Not started Not started

Project Lead Data Subject Request Administrator

Not started Not started

Legal Legal Legal, IT Management Legal Human Resources

Not started Not started Not started Not started Not started

Project Lead Project Lead Business Area Leads

Not started Not started Not started

Project Lead, Business Area Leads, Legal Legal Legal

Not started Not started Not started

Project Lead, Information Security Manager Project Lead Project Lead, Information Security Manager Project Lead, Information Security Manager

Not started Not started Not started Not started

Project Manager, Project Lead Project Manager, Project Lead Project Manager, Project Lead, Business Area Leads, Legal, IT Management, Senior Management

Not started Not started Not started

GDPR roles, awareness and training Conduct communication programme to suppliers and other stakeholders Define GDPR roles and responsibilities Identify lead Data Protection Supervisory Authority Appoint Data Protection Officer (if required) Conduct GDPR competence and training needs assessment Perform GDPR-related training and familiarisation Conduct GDPR and information security awareness training

Personal data mapping Conduct initial personal data information gathering exercise Perform audit of personal data by business area Identify lawful basis for processing personal data in each case Conduct legitimate interest assessments where required Identify record-keeping requirements and procedures

Privacy policies and notices Define personal data retention and protection policy Create or amend existing privacy notices Review and amend consent methods and procedures Address age-related consent and controls (children)

Rights of the data subject Create and implement data subject request procedures Start recording data subject requests

Controllers and processors Update contracts with processors to be GDPR compliant Distribute supplier questionnaires regarding personal data protection Provide information to controllers for whom we act as a processor Update contracts with controllers to be GDPR compliant Address employee confidentiality requirements

Data protection impact assessment Define data protection impact assessment process Conduct data protection impact assessment training Perform initial data protection impact assessment

International transfers Identify international transfers of personal data Assess legality of existing international transfers Put in place agreements for international transfers of personal data (where required)

Personal data breach management Create information security incident management procedure Create personal data breach notification procedure Conduct information security incident management training Test incident management and breach notification procedures

Project closure Repeat gap assessment to identify remaining non-compliant areas Address any remaining non-compliant areas Perform post-project review

GDPR becomes law

Start Date

End Date


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