Start Your Engines: We Have To Deal With GDPR, What Now?

Back in January, we posted about the circumstances in which your company, even if based in the US, must comply with the EU General Data Protection Regulation (GDPR), taking effect in May 2018. Now we get down to business. If your organization is covered, how do you start the process of preparing for compliance? There appear to be so many moving pieces, where to begin? Here we will provide a high level checklist to help you start down the path of GDPR readiness. As usual, this is not legal advice, just information based on the resources available from the EU authorities thus far designed to help you get your ducks in a row and start planning.

First, a reminder. Due to the extraterritorial jurisdiction provisions of the GDPR, your company is covered by the law even if you have no establishment in the EU if you process personal data of data subjects in the EU and that processing relates to (a) the offering of goods or services to those data subjects, irrespective of