GDPR Compliance Audit Checklist Template

Quarterly at minimum, and after any significant product change that affects personal data processing (new features, new third-party integrations, new markets). Schedule the audit as a recurring calendar event with the same cross-functional team.

A DPO is mandatory if your core activity involves regular and systematic monitoring of data subjects at scale, or large-scale processing of special category data (health, biometric, etc.). Most B2B SaaS companies processing standard personal data do not legally require a DPO, but appointing one (even part-time) is a strong signal to regulators and customers.

The controller determines why and how personal data is processed. The processor processes data on behalf of the controller. Most SaaS products are processors for their customers' data and controllers for their own user account data. This dual role means you need both a privacy policy (controller obligations) and DPAs with your customers (processor obligations).

Build a self-service data export feature in your product. This eliminates manual effort for the majority of DSARs. For requests that require manual handling, create a DSAR playbook with step-by-step instructions, templates, and SLAs. The [privacy impact assessment template](/templates/privacy-impact-assessment-template) can help you map where personal data lives across your systems.

Document the gap, assess the risk level (likelihood of regulatory scrutiny multiplied by potential impact), and create a remediation plan with an owner and deadline. Minor gaps (e.g., outdated privacy policy language) should be fixed within 2 weeks. Major gaps (e.g., no lawful basis documented) should be escalated to legal and fixed within 30 days. ---