Checklists

GDPR Compliance implementation checklist

This production-readiness checklist covers the technical and operational requirements for SaaS applications handling EU citizen data under GDPR. It focuses on engineering implementation, data lifecycle management, and infrastructure configuration to ensure compliance before going live.

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Consent and Tracking Implementation

0/5
  • Enforce Opt-In for Non-Essential Cookies

    critical

    Block all non-essential scripts (marketing, tracking, non-anonymized analytics) from loading until the user explicitly clicks 'Accept' on the consent banner.

  • Implement 'Reject All' Parity

    critical

    Ensure the 'Reject All' button is visually identical in prominence, size, and color to the 'Accept All' button to avoid dark patterns.

  • Log Consent State and Version

    recommended

    Store a timestamped record of the user's consent choice and the specific version of the privacy policy they agreed to in a tamper-evident log.

  • Verify Privacy-First Analytics Configuration

    recommended

    If using Plausible or Fathom, verify that IP hashing is enabled and that no persistent cookies are being dropped on the client side.

  • Granular Consent Controls

    recommended

    Provide users with a toggle menu to enable or disable specific categories of data processing (e.g., functional vs. marketing) independently.

Data Subject Rights (DSAR) & Erasure

0/5
  • Automated Deletion Workflow

    critical

    Create a script or background job that identifies and deletes all database records associated with a user_id across all tables, including metadata.

  • Data Portability Export Tool

    critical

    Provide a machine-readable export (JSON or CSV) of all personal data stored about a user, accessible via their account settings.

  • Backup Retention Alignment

    recommended

    Ensure that data deleted from production is also purged from database backups within 30 days, or implement a process to skip restoring deleted IDs.

  • Third-Party Deletion Propagation

    recommended

    Configure webhooks to trigger data deletion in integrated third-party tools (e.g., Intercom, Stripe, Postmark) when a user deletes their account.

  • Manual Verification Procedure

    critical

    Document a standard operating procedure for verifying the identity of a user making a manual data request via email before releasing data.

Infrastructure and Data Residency

0/5
  • Set EU Data Residency

    critical

    Configure cloud provider regions to store primary databases and object storage (S3) within the European Economic Area (e.g., eu-central-1).

  • Enable Encryption at Rest

    critical

    Verify that AES-256 encryption is enabled for all database volumes, backups, and cloud storage buckets.

  • TLS 1.3 Enforcement

    critical

    Disable legacy SSL/TLS versions; configure load balancers to only accept TLS 1.2 or 1.3 for data in transit.

  • Staging Data Anonymization

    recommended

    Implement a pipeline to scrub or mask PII (emails, names, IPs) when syncing production data to staging or development environments.

  • Network Isolation

    recommended

    Deploy databases in private subnets with no public IP addresses, accessible only via a VPN or an internal application gateway.

Logging and Monitoring

0/5
  • PII Scrubbing in Logs

    critical

    Configure application loggers to redact email addresses, passwords, and authorization headers before they are sent to external logging services.

  • Log Retention Policy

    recommended

    Set a TTL (Time To Live) on application and access logs to automatically delete data older than 30-90 days.

  • IP Address Anonymization

    recommended

    Truncate or hash the last octet of user IP addresses in server access logs unless specifically required for security forensics.

  • Admin Access Audit Logs

    critical

    Maintain a non-mutable log of every instance where an internal employee accesses a user's personal data via an admin panel.

  • Breach Notification Alerting

    recommended

    Configure automated alerts for unusual spikes in data egress or multiple failed login attempts to detect potential breaches early.

Vendor and Sub-processor Management

0/5
  • Inventory of Sub-processors

    critical

    Maintain a public-facing list of all third-party services that process user data, including their location and purpose.

  • DPA Execution

    critical

    Verify that a Data Processing Agreement (DPA) is signed and on file for every third-party service in the stack (e.g., AWS, Supabase, Postmark).

  • SCC Verification for US Vendors

    critical

    For US-based vendors, ensure Standard Contractual Clauses (SCCs) are included in the DPA to address Schrems II requirements.

  • SDK Privacy Audit

    recommended

    Audit all client-side SDKs to ensure they do not automatically collect device identifiers or location data without explicit user consent.

  • Email Marketing Opt-out Sync

    critical

    Ensure that 'Unsubscribe' actions in marketing emails immediately sync to the user's status in the primary application database.