GDPR Compliance Checklist for Application Security

Data Protection by Design

GDPR Article: Art. 25 – Controller shall implement technical & organizational measures for data protection by design and default.

How to Implement: Integrate privacy & security requirements from outset: threat modelling, minimize data collected, default minimal access, embed encryption, logging, anonymization.

Security of Processing

GDPR Article: Art. 32 – Controller & processor must implement appropriate technical & organizational measures: pseudonymization, encryption, restore availability, regularly assess.

How to Implement: Encrypt personal data at rest and in transit, use strong authentication/authorization (MFA, password complexity), use secure development lifecycle (SDLC), conduct regular vulnerability testing, ensure incident response & backup for availability.

Lawfulness / Purpose Limitation / Data Minimizations

GDPR Article: Art. 5 (1 – b/c/e) – Personal data shall be collected for specified legitimate purposes, adequate, relevant & limited.

How to Implement: Define and enforce data collection scopes, restrict fields to what is needed, show purpose in UI, implement validation rejecting unnecessary fields, revoke access when not needed.

Accuracy of Data

GDPR Article: Art. 5 (1-d) – Personal data shall be accurate and kept up to date

How to Implement: Provide UI for users to update/correct their data, perform regular data quality checks, implement processes for flagging stale data, audit logs for modifications.

Storage Limitation/Retention

GDPR Article: Art. 5 (1-e) – data kept in identifiable form no longer than necessary; and Art. 17 – Right to erasure/”right to be forgotten”.

How to Implement: Implement retention policies such as archiving/deletion workflows. Ensure UI or automated capability is provided to delete data. Anonymize rather than keep identifiably long log deletion events.

Integrity & Confidentiality

GDPR Article: Art. 5 (1-f) – Data processing shall be done in a manner that ensures appropriate security; and & Art. 32– Security of processing.

How to Implement: Use secure coding standards, protect against OWASP Top 10, enforce encryption, role-based access control, audit trails, monitor for unauthorized access, regular penetration tests.

Accountability & Demonstrability

GDPR Article: Art. 24 – Responsibility of controller; and Art. 30 – Records of processing activities.

How to Implement: During development, maintain documentation of processing operations such as data flow diagrams, data inventories, integrate logging/metrics, version control of design, evidence of security/privacy reviews, compliance checklists.

Processor & Third-Party Responsibility

GDPR Article: Art. 28 – Processor; and Art. 32 – Security.

How to Implement: When using third-party services or APIs, conduct vendor security assessment, ensure contract mandates GDPR compliance, ensure data flows secure, monitor third-party access, define deletion/return of data.

Transfers to Third Countries

GDPR Article: Art. 44-50 – Transfers of personal data to third countries or international organizations.

How to Implement: Ensure any data exported outside EU has adequate safeguards (standard contractual clauses), encrypt data in transit, design architecture so EU data stays within region where required, log/monitor cross-border flows.

Data Subject Rights (Access, Portability, Erasure, Restriction)

GDPR Article: Art. 12-23 – Rights of the data subject.

How to Implement: The web application must have a feature that allows users to access to their data (view, download), correct, delete, restrict processing; expose APIs for data portability; audit requests; consent management.