Essential Guide to Complying with Personal Data Protection Inspections

Every organization is familiar with data protection laws, yet few fully meet their requirements. Here, we share expert insights from Igor Lukanin, head of the 'Contour.Personal Data' service, to help you navigate compliance confidently.

Step 1: Understand What Constitutes Personal Data

Personal data encompasses any information linked to an individual — phone numbers, salary details, political views, social media photos, or even recent online shopping history.

Step 2: Confirm the Law Applies to Your Organization

This legislation covers every business and individual entrepreneur handling personal data. Whether you collect employee information or client details, the law applies as soon as personal data enters your forms, files, or digital systems.

For instance, internal employee posts sharing personal beliefs also count as personal data under the regulation.

Step 3: Assess Your Data Inventory and Remove Unnecessary Information

Identify whose personal data you hold — employees, contractors, job applicants, or customers. List the types of data collected (e.g., full names, birthdates, salaries for employees; names, emails, and addresses for customers).

Determine where and how this data is stored across your company’s systems and devices. If any information is no longer necessary for business purposes, confidently delete it to minimize risk.

Step 4: Obtain Explicit Consent for Data Use

Sharing personal data with third parties or making it public requires the individual’s consent. Examples include processing payroll through banks or delivering orders via courier services.

Special categories of data, such as ethnicity, political or religious beliefs, health, or intimate life details, demand written consent.

Transferring data internationally also calls for written permission unless the recipient country is on an approved list. For example, tourism companies sending clients’ information abroad should secure such consent.

Marketing communications require prior consent to avoid regulatory penalties. Always collect consent when gathering contact details through websites or paper forms.

Step 5: Develop Internal Policies on Personal Data Processing

Document your data handling practices in a comprehensive internal policy. Legislation mandates companies to establish, communicate, and make this policy accessible to employees and clients.

Publishing the policy on your website and displaying it on informational boards can effectively meet these requirements.

During inspections, authorities may request multiple internal documents. While there’s no exhaustive list, leveraging online resources or professional consultants can help you prepare appropriate documentation.

Step 6: Review Your Website’s Compliance

If your website collects personal data, it must prominently display your data processing policy. Even if it does not collect data, publishing the policy enhances trust and demonstrates compliance.

Ensure that data collection forms include clear references to the policy and require users to consent, such as through checkbox confirmations.

Step 7: Notify the Regulatory Authority

It’s advisable to notify the relevant data protection authority that your company processes personal data. Although certain exceptions exist, it’s safer to submit a notification to avoid misunderstandings.

Notifications can be submitted online via the authority’s website or government portals, followed by mailing a physical copy. Include your company details and relevant policy information. Guidance is often available on the regulatory body’s website.

Following these steps prepares your organization for inspections or compliance inquiries. While no approach guarantees success, proactive measures today will safeguard your company’s reputation and minimize legal risks—especially as regulatory penalties are expected to increase.

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