GDPR Compliance: A New CISO’s Step-by-Step Guide to Avoiding Fines
Just Took Over as CISO? Here’s How to Verify GDPR Compliance Before Regulators or Hackers Come Knocking
Congratulations - you’re the new CISO!
Your first big challenge?
Making sure your company is GDPR compliant. Because here’s the reality:
Fines for GDPR violations are skyrocketing.
Regulators are getting stricter.
Customers expect airtight data protection.
Let’s face it:
GDPR fines have exceeded €4 billion since 2018. The biggest penalties aren’t for breaches but for failing to follow GDPR rules. Non-compliance means fines up to €20M or 4% of global revenue - whichever is higher. If GDPR isn’t a priority, your company is at serious risk.
But don’t panic.
Let’s break down how to verify GDPR compliance as a new CISO - step by step.
1) Find Out If Your Company Even Falls Under GDPR
Not sure if GDPR applies? Assume it does.
Your company must comply if:
You operate in the EU.
You offer products or services to EU citizens - even if you’re not based in Europe.
You process personal data of EU residents.
Examples of personal data under GDPR:
Customer names, emails, phone numbers
Employee records
Payment information
IP addresses and online identifiers
If your company collects any EU personal data, you must comply with GDPR - even if you’re based outside the EU.
2) Check If You Have a Data Protection Officer (DPO)
Some companies are legally required to have a DPO. You need a DPO if:
Your company processes large amounts of personal data.
You monitor individuals on a large scale (e.g., tracking user behavior).
You handle sensitive data (health records, financial info, biometric data).
If you don’t have a DPO and need one, you’re already in violation.
What you need to fix as soon as possible:
Appoint a qualified DPO (can be internal or external) and make sure the role reports directly to leadership. Also, ensure they oversee GDPR compliance - not just legal, but also security.
The DPO should be your go-to expert on GDPR policies, audits, and regulator interactions.
3) Identify What Personal Data You Collect and Where It’s Stored
Most GDPR violations happen because companies don’t know what data they have.
Your first task as CISO? Map your company’s data.
What personal data do we collect?
Where is it stored? (Cloud, databases, third-party apps?)
Who has access to it?
How long do we keep it?
How to fix this?
Perform a Data Mapping Exercise - Create an inventory of all personal data. Ensure proper access controls - Limit who can access sensitive information.
Furthermore, check data retention policies - Are you keeping data longer than necessary?
If you don’t know where personal data is stored, you can’t protect it.
4) Verify Consent and Data Collection Practices
If your company collects data without proper consent, it’s a GDPR violation.
Check these immediately:
Are we collecting only necessary data? (No excessive data collection).
Do we have clear opt-ins for users? (No pre-checked boxes.)
Can users easily withdraw consent? (No confusing opt-out processes.)
What you should review immediately:
Review your company’s consent mechanisms. Ensure privacy policies are clear and GDPR-compliant and finally:
Make it easy for users to access, edit, or delete their data.
If you don’t have proof of consent for the data you collect, you’re already non-compliant.
5) Secure Personal Data Against Breaches
Under GDPR, poor security = non-compliance.
Common security failures that lead to GDPR fines:
Weak access controls - Unprotected customer data in cloud storage.
Lack of encryption - Personal data exposed in plaintext.
Unpatched vulnerabilities - Hackers exploiting old security holes.
How to verify your security posture:
Encrypt sensitive data - At rest and in transit.
Enforce Multi-Factor Authentication (MFA) - Reduce account takeovers.
Apply the Principle of Least Privilege (PoLP) - Limit access to personal data.
Patch all critical vulnerabilities - No excuses for delayed security updates.
If a breach happens and you didn’t take security seriously, expect heavy fines.
6) Make Sure You Can Detect and Report Breaches in 72 Hours
GDPR requires you to report data breaches within 72 hours.
Here’s the reality Check:
Many companies don’t detect breaches for months.
If you miss the 72-hour window, you’re in violation - even if the breach wasn’t your fault.
Check if your company is ready to report a breach:
Do we have real-time threat detection?
Is there a clear process for reporting incidents?
Can we notify regulators and affected individuals within 72 hours?
So what are recommended steps to become compliant?
Run a breach response simulation.
Ensure automated alerting for security incidents.
Pre-draft regulatory notification templates (so you’re not scrambling during an attack).
If your company can’t detect and report breaches in time, regulators will penalize you.
7) Audit Third-Party Vendors (Because Their Mistakes Are Your Problem)
GDPR holds you responsible for vendor security.
If a third-party vendor mishandles data, your company still gets fined.
What to check immediately:
Which vendors process personal data for us?
Do we have GDPR-compliant contracts with them?
Are they using strong security measures?
Fix it now:
A good approach to fix this is to audit vendors annually. Also, you might ask for security certifications like ISO 27001, SOC 2 and so on. You also should include breach notification clauses in contracts. Generally speaking:
If a vendor isn’t secure, you aren’t secure.
The Bottom Line
GDPR isn’t just about avoiding fines - it’s about customer trust.
If customers don’t trust you with their data, they won’t do business with you.
If regulators catch you off-guard, the fines will be brutal.
If you wait until there’s a breach to fix security, it’s already too late.
As a new CISO, your job is to make GDPR compliance airtight.
What to do first?
Verify if GDPR applies to your company. Ensure data is mapped, secured, and encrypted. Check if breach response is fast and compliant. Audit vendors to make sure they’re not your weakest link.
If you can confidently answer “YES” to these steps, you’re ahead of most companies.
If not, it’s time to act - before regulators force you to.