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.
Consent and Tracking Implementation
0/5Enforce Opt-In for Non-Essential Cookies
criticalBlock 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
criticalEnsure 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
recommendedStore 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
recommendedIf 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
recommendedProvide 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
0/5Automated Deletion Workflow
criticalCreate 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
criticalProvide a machine-readable export (JSON or CSV) of all personal data stored about a user, accessible via their account settings.
Backup Retention Alignment
recommendedEnsure 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
recommendedConfigure webhooks to trigger data deletion in integrated third-party tools (e.g., Intercom, Stripe, Postmark) when a user deletes their account.
Manual Verification Procedure
criticalDocument 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
0/5Set EU Data Residency
criticalConfigure 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
criticalVerify that AES-256 encryption is enabled for all database volumes, backups, and cloud storage buckets.
TLS 1.3 Enforcement
criticalDisable legacy SSL/TLS versions; configure load balancers to only accept TLS 1.2 or 1.3 for data in transit.
Staging Data Anonymization
recommendedImplement a pipeline to scrub or mask PII (emails, names, IPs) when syncing production data to staging or development environments.
Network Isolation
recommendedDeploy databases in private subnets with no public IP addresses, accessible only via a VPN or an internal application gateway.
Logging and Monitoring
0/5PII Scrubbing in Logs
criticalConfigure application loggers to redact email addresses, passwords, and authorization headers before they are sent to external logging services.
Log Retention Policy
recommendedSet a TTL (Time To Live) on application and access logs to automatically delete data older than 30-90 days.
IP Address Anonymization
recommendedTruncate or hash the last octet of user IP addresses in server access logs unless specifically required for security forensics.
Admin Access Audit Logs
criticalMaintain a non-mutable log of every instance where an internal employee accesses a user's personal data via an admin panel.
Breach Notification Alerting
recommendedConfigure automated alerts for unusual spikes in data egress or multiple failed login attempts to detect potential breaches early.
Vendor and Sub-processor Management
0/5Inventory of Sub-processors
criticalMaintain a public-facing list of all third-party services that process user data, including their location and purpose.
DPA Execution
criticalVerify 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
criticalFor US-based vendors, ensure Standard Contractual Clauses (SCCs) are included in the DPA to address Schrems II requirements.
SDK Privacy Audit
recommendedAudit 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
criticalEnsure that 'Unsubscribe' actions in marketing emails immediately sync to the user's status in the primary application database.