GDPR Readiness Checklist for SaaS Companies

Getting ready for GDPR can feel overwhelming, especially for startups or growing SaaS businesses. This checklist breaks down the key areas you need to focus on to become GDPR-ready and demonstrate accountability if audited.

While GDPR is a legal framework, much of the work comes down to clear data practices, risk reduction, and transparency with users.

1. Data Inventory and Mapping

  • Identify all personal data your company collects (e.g., email, name, IP address)
  • Map data flows — where data comes from, where it’s stored, and where it goes
  • Document all third-party tools that process personal data (e.g., CRMs, analytics, cloud providers)

2. Lawful Basis for Processing

  • Define the legal basis for each data processing activity (e.g., consent, contract, legal obligation)
  • Ensure consent is freely given, specific, informed, and unambiguous
  • Maintain records of consent collection and allow easy withdrawal

3. Privacy Notices and Transparency

  • Update your Privacy Policy to clearly explain:
    • What data you collect
    • Why you collect it
    • Who you share it with
    • How long you keep it
    • Users’ rights under GDPR
  • Make the policy easy to find and accessible in all relevant languages

4. Data Subject Rights Handling

  • Set up a process to respond to Data Subject Requests (DSRs) within 30 days
  • Enable users to:
    • Access their data
    • Correct inaccurate data
    • Request deletion
    • Object to processing
    • Export data (data portability)

5. Security Measures

  • Implement appropriate technical and organizational security controls (e.g., encryption, access management)
  • Maintain an up-to-date incident response plan
  • Run regular security training for employees

6. Data Processing Agreements (DPAs)

  • Sign a DPA with each third-party processor that handles personal data
  • Ensure the DPA covers:
    • Purpose of processing
    • Data protection obligations
    • Sub-processors
    • International transfers

7. International Data Transfers

  • Verify if you’re transferring data outside the EU or EEA
  • Use Standard Contractual Clauses (SCCs) or other approved mechanisms
  • Monitor updates from the European Data Protection Board (EDPB) on cross-border transfers

8. Records of Processing Activities (RoPA)

  • Maintain an internal record of:
    • Categories of data subjects and personal data
    • Processing purposes
    • Data recipients
    • Retention schedules
    • Security measures in place

9. Appointing a Data Protection Officer (DPO)

  • Determine if you’re legally required to appoint a DPO
  • If not required, designate a privacy lead or responsible team
  • Ensure they’re involved in privacy reviews and decisions

10. Breach Response

  • Create a process for identifying and reporting personal data breaches
  • Notify authorities within 72 hours if the breach risks individual rights
  • Communicate clearly with affected individuals if necessary

11. Vendor Management

  • Assess the privacy practices of vendors handling personal data
  • Regularly review vendor compliance and terminate risky partnerships
  • Track sub-processors used by your vendors

12. Continuous Monitoring

  • Run regular GDPR audits or privacy reviews
  • Update policies and processes as your product or business evolves
  • Train teams on privacy best practices and legal obligations

Final Thoughts

Becoming GDPR-compliant is not a one-time task—it’s a mindset and a continuous commitment. Startups that build privacy into their products and culture early save time and reduce risk later.

Looking to automate parts of this process? Tools like Vanta, Drata, and Secfix can help monitor data flows, enforce controls, and centralize evidence. If you’re a smaller team based in the EU and want expert help without complexity or steep pricing, Secfix offers a strong starting point.