The General Data Protection Regulation – Top 10 Considerations



Despite the European Commission’s original goal of lessening the compliance burden for businesses, by harmonizing EU privacy law, the GDPR expands obligations for both Controllers and Processors, creates new rights for individual data subjects, and allows Member States to enhance obligations in certain circumstances.

The GDPR not only applies to companies that are established in the EU, its reach is much broader, ensnaring companies outside the EU if they provide goods or services to EU data subjects or monitor their behavior (for example, through online tracking), regardless of where the data is processed or stored. Therefore, all companies with any EU interests must understand and anticipate their GDPR compliance obligations.

Because every business is different, there is no one-size-fits-all GDPR readiness strategy. Preparations may vary depending on such factors as the sector, type of data processed (e.g. sensitive data like health or biometric data, which are subject to enhanced requirements), and what policies, procedures and programs a company already has in place. The following checklist tied to key provisions of the GDPR can be used as a reference. 

The GDPR requires businesses to be transparent and accountable for their handling of personal data, including by maintaining records of data processing activities. It is therefore essential that businesses have a solid understanding of the data lifecycle by conducting an inventory of and mapping all data holdings.

Data classification should be reviewed against the GDPR’s expanded definition of personal data, which can include location data and online identifiers.

Data mapping will help determine whether cross-border transfer mechanisms are required, or whether data should be stored in-country (for instance where data is subject to localization requirements, e.g., Russia or China).

Practical tip: At a minimum, assess the following:

On the basis of the inventory and data map, businesses should assess what privacy compliance measures are already in place and perform a gap analysis to identify the areas requiring changes to comply with the GDPR. This exercise would require a cross-functional collaboration with buy-in from stakeholders across all departments.

Practical tip: Due to the breadth of the new requirements, it is essential, depending on the maturity of your business’s privacy program, to prioritize the GDPR’s requirements in light of the nature of your business and the types of data processing activities performed. For example, businesses in the midst of launching new products or technologies (e.g., involving the use of fingerprint and face recognition to access services) should conduct a Privacy Impact Assessment. Life science businesses processing large volumes of health data should be thinking about who to appoint as a Data Protection Officer. Setting priorities will also help businesses allocate appropriate resources for GDPR compliance.

The GDPR calls for enhanced transparency in privacy notices, including explaining:

Practical tip: Businesses should review their public-facing privacy policies, online forms or other notices and update them to ensure GDPR compliance.

As with the current framework, the GDPR requires that companies have a “legal basis” to process personal data.  Examples of a legal basis include individual consent, necessity to perform a contract, or the “legitimate interest” of the Controller or a third party.

The GDPR significantly tightens the rules for obtaining consent. Consent must be “unambiguous,” which requires an affirmative indication by the data subjects that they agree to their personal data being processed. Silence, inactivity or pre-ticked boxes are invalid. For sensitive data and other processing activities (e.g., automated decision-making), consent must be “explicit” – while explicit consent is not defined in the GDPR, it will likely require to be affirmed in a clear statement (whether oral or written) rather than by any other positive action. Moreover, individuals must be able to withdraw consent as easily as they give it.

Practical tip: Where consent has previously been relied upon to justify processing activities, businesses will need to carefully assess whether existing consents meet the GDPR’s conditions and, if they do not, fresh consent will need to be obtained from individuals (unless another legal basis for processing can be established).

The GDPR significantly enhances the rights of individuals, including requiring strengthened rights to erasure (“right to be forgotten”); restricting “automated decision-making” (e.g., automatic refusal of an online credit application) and profiling (e.g., using personal data to evaluate or predict a person’s health, economic condition, interests, location or other aspects); and introduces a new right to “data portability” (the right to move one’s data to another service provider in a commonly used format).

The GDPR also makes it easier to claim damages resulting from infringement of the GDPR and expressly authorizes data subjects to mandate consumer groups to enforce rights on their behalf.

Practical tip: Businesses should review their internal processes, staff training and IT systems and make any necessary changes to satisfy these new individuals’ rights.

Businesses who engage service providers to process personal data on their behalf (e.g., outsourcing payroll processing, assisting with marketing campaigns, or engaging a cloud service provider), may be familiar with the current requirement for Controller-Processor data processing agreements. The GDPR is much more prescriptive about the content of these clauses.

Moreover, the GDPR now requires Controller consent for sub-processing and requires Processors to contractually bind sub-processors to the Controller’s instructions in the Controller-Processor agreement. It also places direct legal obligations on Processors, including with respect to security measures, record-keeping obligations and cooperation with DPAs.

Practical tip: Vendor and sub-processing agreements extending beyond May 2018 should be reviewed for compliance with the GDPR’s new contractual requirements for third-party vendors. Businesses should also assess whether liability and indemnity terms associated with data protection and insurance policies are adequate in light of the GDPR’s additional requirements and potential for substantial fines.

Businesses should also keep watch for potential instances of “joint” controllership, which occurs when multiple businesses jointly determine purposes or means of the data processing (for example, in connection with the set-up of a common platform or in an intra-group context). 

The GDPR requires Controllers to notify DPAs of certain “personal data breaches” within 72 hours after having become aware of the breach, unless they can show the risk to individuals is unlikely. Likewise, affected individuals must be notified without “undue delay” if the breach is likely to result in a “high risk” to their rights and freedoms. Processors are required to notify Controllers without undue delay after becoming aware of a breach.

Practical tip: Businesses should assess their internal policies and processes to ensure that appropriate procedures are in place to detect, investigate, report and document data breaches and to manage the fall-out from such reporting.

The GDPR introduces a new concept -- “lead DPA.” The lead DPA will supervise GDPR-compliance and will coordinate enforcement actions with other DPAs for companies operating in several EU States. The lead DPA is determined by the place of a company’s “main” EU establishment, i.e., where decisions over purposes/means of the data processing are made (for Controllers) or where main processing activities are carried out (for Processors). Businesses may not “forum shop” to designate the lead DPA in the jurisdiction with requirements that are perceived to be more business friendly, and they will have to be able to provide DPAs with evidence of their main establishment.

Businesses with no establishment in the EU and nonetheless subject to the GDPR will not be able to designate a lead DPA. These businesses could potentially be subject to the jurisdiction of all Member State DPAs.

Practical tip: Businesses should try and identify their “main establishment” and lead DPA now. Consider in which jurisdiction your data processing decisions are taking place or your main processing activities are carried out.  If your business has particular organizational or operational links to a specific Member State, it makes sense to ensure that the main establishment and corresponding lead DPA for your business correlates to that. 

The GDPR, like the Privacy Directive, restricts data transfers to countries outside the EU that do not ensure an adequate level of data protection unless a valid transfer mechanism is used. The current transfer mechanisms (Privacy Shield, model clauses), remain broadly in place, with some changes. For example, the GDPR explicitly recognizes the use of Binding Corporate Rules as a means of legitimizing intra-group data transfers. Approved codes of conduct and certification mechanisms may also be used in the future.

Practical tip: Companies should pay close attention to the pending legal challenges to the EU-US Privacy Shield and model clauses, as well as to the impact of Brexit on EU-UK data transfers, and be ready to revise their strategy for cross-border transfers accordingly.  Companies may also want to consider whether and to what extent they may eventually be able to utilize industry self-regulatory codes to accomplish these transfers in lieu of current mechanisms.

Conclusions: The GDPR’s enhanced harmonization of Member State data protection laws may theoretically make it easier for businesses with global operations to adopt a more uniform approach to data privacy and governance. The GDPR also presents an opportunity for businesses to strategically leverage data privacy compliance as a means to distinguish themselves from competitors.

At the same time, there will still be significant national variations in some areas, particularly regarding the processing of employee data. Businesses should keep track of Member State laws that modify or enhance the GDPR’s obligations and pay close attention to the existing and forthcoming DPAs’ guidance on key aspects of the GDPR.

Finally, by holding Controllers accountable for the noncompliance of their Processors and subjecting Processors to fines, the GDPR offers significant incentives for Processors to live up to their GDPR obligations or else lose business to competitors. We anticipate an uptick in DPA audits of Processors, through which DPAs can identify potential noncompliance of multiple Controllers, which will likely result in greater efficiency for the DPAs.

  1. Data Mapping And Data Inventory
    • How your business obtains personal data
    • The legal basis for the processing (e.g., consent; performance of a contract)
    • With whom your business shares personal data and why
    • How and where your business stores personal data (e.g., in-house systems; end users devices; the cloud), and in which countries
    • How your business secures personal data
    • How long your business retains personal data
    • To which non-EU countries your business transfers personal data and what, if any, transfer mechanism is required and used (e.g., model clauses, Privacy Shield)
  2. Benchmarking Existing Practices To The GDPR
  3. Reviewing Privacy Notices

    • The legal basis for processing the data
    • Whether the data will be subject to automated decision-making, the logic used and consequences for individuals
    • Data retention periods
    • Transfer of data outside the EU
    • Individuals’ rights, including to lodge a complaint with the Data Protection Authority (DPA)
  4. Review The Legal Bases For Data Processing
  5. Review Procedures And Policies To Comply With Individuals’ Rights
  6. Review Third-Party Agreements And Processor Obligations
  7. Implementing Accountability

    The GDPR includes several enhanced accountability requirements, including:

    Data Protection Officer (DPO)

    Controllers and Processors must appoint a DPO in specified circumstances (e.g., where they undertake large-scale, regular and systematic monitoring of individuals, such as in the context of monitoring geolocation or in connection with behavioral advertising, or large-scale processing of sensitive data). The DPO must be a staff member or an external service provider with expert knowledge of data protection law and practices, whose job will include monitoring internal compliance with the GDPR.

    Practical tip: Unless it is obvious that designation of a DPO is not required, companies should document the internal analysis carried out to determine whether or not a DPO must be appointed. If you have already hired a DPO you should review the job functions of the position and compare them to the GDPR’s requirements (e.g., expertise and independence), and adapt the functions as warranted.

    Privacy Impact Assessment (PIA)

    In many EU Member States, conducting a PIA is a recommended good practice. The GDPR requires Controllers to conduct a PIA when the processing is “likely” to result in a “high risk” for individuals (e.g., large-scale processing of sensitive data or certain forms of automated-decision making). If the PIA indicates that the processing is high risk that cannot be mitigated, Controllers will need to consult the DPA prior to starting the processing.

    Practical Tip: Companies should identify products early in the development process that are likely to pose a high privacy risk and conduct a PIA.  Developing a PIA questionnaire for use by project leaders and having it at the ready can facilitate meeting this requirement with minimal disruption to the product development team.

    Privacy By Design; Privacy By Default

    Controllers must implement appropriate security measures, such as pseudonymization, in order to integrate data protection principles into data processing activities (“Privacy by Design”). They must also ensure that, by default, only personal data that is necessary for each specific purpose is processed (“Privacy by Default”).

    Practical tip: Businesses should ensure that their privacy programs, products and business processes address the GDPR’s Privacy By Design and Privacy By Default requirements.


    In exchange for eliminating the current requirement in some Member States that businesses register their data processing activities with a DPA, the GDPR now requires businesses to keep detailed records of data processing. Records must be provided to DPAs upon request. The GDPR is prescriptive and lists minimum information to be included in these records.

    Practical tip: Businesses should create and maintain records of their processing activities. Businesses could use information in their existing data protection notifications or registrations in Member States, if any, as a reference to fill in their GDPR records.

  8. Preparing Data Breach Procedures
  9. Identifying The Lead DPA
  10. Identify International Data Transfers And Review Mechanisms

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

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Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

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Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

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We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

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How is your information shared?

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How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at

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Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
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    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
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You can make a request to exercise any of these rights by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at:

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

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There are different types of cookies and other technologies used our Website, notably:

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JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

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If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

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