Individual skill

conducting-gdpr-compliance-assessment

Conduct comprehensive GDPR compliance assessments by evaluating data processing activities against EU Regulation 2016/679, including Article 30 records of processing, lawful basis validation, data subject rights implementation, Data Protection Impact Assessments (DPIAs) under Article 35, breach notification procedures, international transfer safeguards (SCCs, adequacy decisions), and technical/organizational measures under Article 32. Use when processing personal data of EU residents, preparing for supervisory authority audits, implementing privacy-by-design for new systems, scoping compliance gaps for M&A due diligence, assessing third-party processors, or responding to data subject access requests at scale. Incorporates 2026 guidance from ICO, EDPB, and post-Data (Use and Access) Act 2025 UK-GDPR considerations. Do not use for implementing specific Article 32 controls — use implementing-gdpr-data-protection-controls; or for DSAR automation — use implementing-gdpr-data-subject-access-request.

skills/conducting-gdpr-compliance-assessment/SKILL.md

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# Conducting GDPR Compliance Assessment

> **Effective Date**: August 2026  
> **Legal Basis**: EU Regulation 2016/679 (GDPR), UK GDPR as amended by Data Protection Act 2018 and Data (Use and Access) Act 2025 (ukpga/2025/18)  
> **Pending Changes**: Digital Omnibus proposal (COM(2025) 837) would change Article 30(5) threshold from 250 to 750 employees and Article 33 breach notification from 72h to 96h. Still in proposal stage; current requirements remain in force.

## When to Use

- When an organization **processes personal data of EU residents** (Article 3 territorial scope applies)
- When preparing for a **supervisory authority audit** (ICO, CNIL, BfDI) or responding to formal inquiry
- When implementing **privacy-by-design** requirements (Article 25) for new systems or data flows
- When **scoping compliance gaps** before M&A due diligence or contract negotiations with EU entities
- When responding to **data subject access requests (DSARs)** and discovering gaps in data inventory
- When assessing **third-party processors** for GDPR compliance before signing Data Processing Agreements (DPAs)
- After **data breach incidents** to verify notification procedures meet 72-hour requirement (Article 33)
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