Ignoring the Principle of Accountability
Posted: Sun Jun 01, 2025 3:28 am
The principle of accountability, articulated in Article 5(2) of GDPR, means that organizations must not only comply with GDPR but also be able to demonstrate that compliance. A major mistake is failing to maintain comprehensive records of processing activities, privacy policies, consent records, DPIAs, and data breach notifications. Without proper documentation, an organization cannot demonstrate compliance when challenged by a supervisory authority or a data subject. This extends beyond simple record-keeping to having a culture of accountability where data protection is embedded into organizational processes and procedures, with clear roles and responsibilities assigned.
Lack of Regular Training and Awareness
GDPR compliance is not solely the responsibility of the DPO or legal team; it's a collective effort across the entire organization. A frequent mistake is neglecting to provide regular and comprehensive data protection training to all employees who handle personal data. Even well-designed databases can be compromised by shop human error, such as phishing attacks, misconfigured settings, or improper data handling by staff. Lack of awareness about data privacy risks, individual responsibilities, and company policies can lead to inadvertent breaches or non-compliance. Ongoing training ensures that employees understand their role in protecting personal data and can identify and report potential issues.
Outdated Privacy Policies and Notices
A privacy policy is a cornerstone of transparency under GDPR. A common mistake is having an outdated, generic, or incomplete privacy policy and data protection notices that do not accurately reflect current data processing activities. Privacy policies must be easily accessible, concise, transparent, intelligible, and in plain language. They must detail who is processing the data, why it's being processed, the lawful basis, data retention periods, data subject rights, and mechanisms for exercising those rights. Failing to keep these documents updated to reflect changes in data collection, processing, or sharing is a clear violation of the transparency principle.
Lack of Regular Training and Awareness
GDPR compliance is not solely the responsibility of the DPO or legal team; it's a collective effort across the entire organization. A frequent mistake is neglecting to provide regular and comprehensive data protection training to all employees who handle personal data. Even well-designed databases can be compromised by shop human error, such as phishing attacks, misconfigured settings, or improper data handling by staff. Lack of awareness about data privacy risks, individual responsibilities, and company policies can lead to inadvertent breaches or non-compliance. Ongoing training ensures that employees understand their role in protecting personal data and can identify and report potential issues.
Outdated Privacy Policies and Notices
A privacy policy is a cornerstone of transparency under GDPR. A common mistake is having an outdated, generic, or incomplete privacy policy and data protection notices that do not accurately reflect current data processing activities. Privacy policies must be easily accessible, concise, transparent, intelligible, and in plain language. They must detail who is processing the data, why it's being processed, the lawful basis, data retention periods, data subject rights, and mechanisms for exercising those rights. Failing to keep these documents updated to reflect changes in data collection, processing, or sharing is a clear violation of the transparency principle.