10-Step Checklist: How to Become Compliant with GDPR

Quick summary: To become GDPR-compliant, follow these 10 steps: (1) conduct a data audit, (2) establish a lawful basis for processing, (3) update privacy policies, (4) implement data protection measures, (5) appoint a DPO, (6) provide staff training, (7) obtain and manage consent, (8) enable data subject rights, (9) prepare a data breach response plan, and (10) conduct regular audits. With cumulative GDPR fines reaching €7.1 billion as of January 2026 and the EU AI Act approaching full enforcement in August 2026, compliance is more urgent than ever.

GDPR has been the backbone of data protection in Europe since 2018, and enforcement is only getting stricter. In 2025 alone, European supervisory authorities issued approximately €1.2 billion in fines, including a €530 million penalty against TikTok for unlawful data transfers to China and a €310 million fine against LinkedIn for processing personal data without a proper legal basis. The cumulative total now stands at €7.1 billion across over 2,500 recorded penalties, according to DLA Piper's January 2026 survey.

For organisations handling personal data of EU residents – whether you're based in the EU or not – achieving and maintaining GDPR compliance isn't optional. But it doesn't need to be overwhelming either. This guide breaks it down into 10 practical steps, with clear actions for each.

Table of contents

1. Pain points of achieving GDPR compliance
2. A 10-step GDPR compliance checklist
3. Tips for compliance
4. Digital Samba’s commitment to security and GDPR compliance
5. Frequently asked questions

Pain points of achieving GDPR compliance

While GDPR compliance protects your organisation and your users, the journey to full compliance comes with real challenges. Here are the most common ones:

1. Understanding GDPR requirements

The regulation is complex, and legal terminology can be difficult to interpret without expert guidance. Organisations must understand core principles such as data minimisation, purpose limitation, and accountability. Identifying which data processing activities fall under GDPR's jurisdiction can be particularly tricky for multinational companies handling data across borders.

The complexity is increasing, too. The European Commission's proposed GDPR Omnibus amendments (published November 2025) would adjust how personal data is defined and introduce AI-specific provisions – meaning the rules themselves are evolving alongside the technology. Keeping up with these changes requires ongoing attention.

2. Implementing necessary data protection measures

After gaining an understanding of GDPR, the next challenge is putting the right data protection measures in place. This involves conducting data protection impact assessments (DPIAs), establishing lawful bases for data processing, and ensuring adequate security measures protect data from breaches.

For small and medium-sized enterprises (SMEs), the cost and effort required can be significant. New technologies, staff training, and policy creation all strain resources and require long-term commitment.

3. Ensuring ongoing compliance

Achieving compliance is not a one-time effort. GDPR requires continuous monitoring, audits, and updates to data protection practices. This includes keeping records of processing activities, regularly assessing risks, and responding to new regulatory developments – such as the EU AI Act's requirements for high-risk AI systems, which reach full enforcement in August 2026.

Businesses must also manage third-party vendors and partners who handle personal data on their behalf. Many organisations struggle with sustaining compliance due to competing priorities or a lack of internal expertise.

4. Avoiding hefty fines

Under GDPR, organisations face fines of up to €20 million or 4% of global annual turnover, whichever is higher. The scale of recent enforcement makes this real: Meta's €1.2 billion fine (2023), TikTok's €530 million fine (2025), and LinkedIn's €310 million fine (2024) show that regulators are willing to impose serious penalties, not just against Big Tech but increasingly across healthcare, finance, and the public sector.

Beyond monetary fines, businesses risk reputational damage, loss of customer trust, and legal disputes. Quick and transparent responses to potential incidents can help reduce the risk of severe penalties.

A 10-step GDPR compliance checklist

Understanding the significance of GDPR compliance is important for businesses operating in a data-driven world. Compliance protects organisations from severe financial penalties and builds trust by demonstrating a commitment to data privacy. Here is a practical 10-step checklist to guide your business through GDPR compliance:

Step 1: Conduct a data audit

Identify and categorise all personal data your organisation processes. Map out where data is stored, how it is collected, who has access to it, and how long it is retained. This process helps uncover potential risks, redundant data, and non-compliant practices, giving your business a clear view of its data ecosystem.

Step 2: Establish a lawful basis for data processing

Determine the legal grounds for processing personal data, such as consent, contractual necessity, or legitimate interest. Ensure that each data processing activity has a documented lawful basis, as required by GDPR. In cases where consent is used, establish procedures to obtain and manage consent in a clear and verifiable manner.

Step 3: Update privacy policies

Ensure your privacy policy clearly communicates how personal data is collected, used, and stored. The policy should cover key areas such as data subject rights, retention periods, and the organisation's legal obligations. Regularly review and update this document to reflect any changes in your data practices or regulatory requirements.

Step 4: Implement data protection measures

Adopt strong security measures to safeguard personal data against unauthorised access, breaches, and loss. These measures may include data encryption, secure access controls, and regular vulnerability assessments. A solid data protection framework reduces the risk of data breaches and demonstrates accountability.

If your organisation uses AI systems that process personal data, note that the EU AI Act (fully applicable from August 2026) will require additional safeguards for high-risk AI, including conformity assessments, documentation, and human oversight. Preparing for this now avoids a last-minute compliance scramble. For more on the intersection of AI and data privacy, see our detailed guide.

Step 5: Appoint a DPO

If required by GDPR, designate a Data Protection Officer to oversee compliance efforts. The DPO's responsibilities include monitoring data protection practices, advising on regulatory obligations, and serving as a point of contact for data protection authorities. Smaller businesses may appoint an external DPO to fulfil this role.

Step 6: Provide staff training

Educate employees on GDPR principles, data handling procedures, and the importance of protecting personal data. Tailored training sessions can help different departments understand their specific responsibilities, reducing the likelihood of human error leading to non-compliance. Continuous training ensures awareness remains high across the organisation.

Step 7: Obtain and manage consent

Implement processes to obtain explicit, informed consent from data subjects where necessary. Your consent mechanisms should provide clear options for users to agree or decline data processing activities. Ensure that consent can be easily withdrawn and that records of consent are securely maintained.

Be aware that consent manipulation – such as making it harder to reject than accept, or using pre-ticked boxes – is now a frontline enforcement priority. France's CNIL has fined Google €325 million and SHEIN €150 million specifically for cookie consent violations. Design your consent interfaces to be genuinely fair, not just technically compliant.

Step 8: Enable data subject rights

Establish mechanisms to handle data subject requests efficiently. GDPR grants individuals various rights, such as the right to access, correct, or delete their personal data. Your organisation should have documented procedures to verify, process, and respond to these requests within the legally mandated timeframe.

The right to erasure (Article 17) has become an enforcement focus for the European Data Protection Board in 2025-2026. Expect closer scrutiny of how erasure requests are assessed, exceptions applied, and responses documented.

Step 9: Prepare a data breach response plan

Develop a data breach response plan that outlines the steps your organisation will take in the event of a breach. This plan should include procedures for detecting, reporting, and mitigating breaches. GDPR requires reporting to the relevant authorities within 72 hours. Timely reporting to authorities and affected individuals can help reduce regulatory penalties and reputational damage.

For context on how breaches are classified under GDPR – including integrity, confidentiality, and availability breaches – see our guide on GDPR data breaches in video conferencing.

Step 10: Conduct regular audits

Perform regular internal audits to assess your organisation's compliance with GDPR. Audits should evaluate the effectiveness of data protection measures, identify areas for improvement, and ensure that policies remain up to date. Regular audits are a proactive way to maintain long-term compliance and prevent compliance gaps from emerging.

With the regulatory landscape expanding – GDPR Omnibus amendments under debate, the EU AI Act approaching full enforcement, and cross-border data transfers under ongoing scrutiny through the EU-US Data Privacy Framework – regular audits are more important than ever. Consider whether your audit programme also covers EU data hosting requirements and data privacy trends that might affect your operations.

Tips for compliance

• Use GDPR compliance tools: Automated tools can handle complex tasks such as data audits, consent management, and request handling. These tools save time and reduce the risk of human error.
• Stay informed: Regularly consult official guidelines from regulatory bodies like the European Data Protection Board (EDPB) to stay aware of updates and emerging requirements.
• Consult legal experts: Partnering with legal professionals provides tailored advice, helping your organisation handle risks and avoid potential pitfalls specific to your business sector.
• Develop a compliance roadmap: Break down the compliance process into clear milestones with achievable deadlines. A well-structured roadmap ensures consistent progress and reduces the likelihood of compliance gaps.

By following this checklist, your organisation can build a solid foundation for GDPR compliance, reducing risks and demonstrating a commitment to data protection.

Digital Samba's commitment to security and GDPR compliance

Digital Samba is dedicated to delivering a secure, GDPR-compliant video conferencing platform. But we don't just build compliance into the product – we live it. Our team follows GDPR protocols through continuous training on GDPR-related topics, clear compliance roadmaps, and strict procedures around data protection and security.

Here's how the platform supports GDPR compliance:

• Data protection by design: Privacy and security measures are integrated from the outset – data minimisation, encryption, and secure user authentication are built into every feature.
• End-to-end encryption: Video calls, audio, and personal information are encrypted both in transit and at rest.
• Regular audits and risk assessments: Internal and external audits evaluate compliance and data protection measures. Risk assessments identify vulnerabilities for timely improvements.
• Data subject rights management: Mechanisms for handling access, rectification, and deletion requests, in compliance with GDPR.
• Training and awareness: Ongoing team training on GDPR principles and data protection best practices.
• Vendor and partner compliance: Third-party vendors and partners adhere to GDPR through stringent contracts and regular compliance checks.

How Digital Samba's API supports GDPR compliance

Digital Samba's video conferencing API is designed to help businesses achieve and maintain GDPR compliance through built-in data protection features:

1. Secure data transmission: End-to-end encryption for video, audio, and shared data in transit and at rest.
2. Role-based access control: Manage data access through permissions based on roles and responsibilities, supporting data minimisation.
3. Data subject rights management: Tools to handle access, rectification, and erasure requests.
4. Consent management: Features for obtaining and managing user consent, with verifiable consent recording.
5. Real-time monitoring and incident response: Logging and anomaly detection to support GDPR's breach notification requirements.
6. Customisable data retention policies: Configure how long personal data is stored, aligning with purpose limitation principles.
7. Data Processing Agreements (DPAs): Transparency and accountability in how data is handled.
8. Continuous security updates: Ongoing improvements to address new threats and regulatory changes.

All of this runs on EU-owned infrastructure, hosted entirely within Europe, with no US hyperscaler dependencies. For organisations where data sovereignty is a requirement, this matters.

Contact our sales team to find out how Digital Samba can support your GDPR compliance efforts, or request a demo to see the platform's data-agnostic structure and built-in security protocols in action.

Frequently asked questions

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