Use this as a starting list. Tick an item only when you can show evidence for it.
1. Know your data
- Inventory of personal data, systems, owners and purposes.
- Lawful ground recorded for each activity (consent or a specific legitimate use).
2. Notice and consent
- Itemised notice at each collection point, in plain language.
- Unticked, purpose-specific consent boxes where consent is the ground.
- Consent records: who, when, how, for what, which notice version.
- Withdrawal as easy as giving consent.
3. Rights and grievances
- Intake, identity verification and response process for access, correction, erasure and nomination.
- Published grievance and data-protection contact with response commitments.
4. Retention and erasure
- Retention schedule with legal holds identified.
- Process to erase (and cause processors to erase) when the purpose is served or consent is withdrawn.
5. Security and breaches
- Access control, encryption, logging, backups.
- Written breach plan, roles, notification approval path, rehearsal.
6. Vendors
- Register of processors and contracts covering security and deletion.
7. Special cases
- Children: age check, verifiable parental consent, no tracking or targeted ads.
- Cross-border flows mapped.
- Significant Data Fiduciary duties if notified.
Relevant provisions
- Section 5Rule 3 · pending verificationPrivacy notice at or before collection
- Section 6(1)-(3)Valid consent for processing
- Section 8(1)Fiduciary accountability, incl. processors
- Section 8(5)Rule 6 · pending verificationReasonable security safeguards
- Section 8(6)Rule 7 · pending verificationPersonal data breach intimation
- Section 8(7)Rule 8 · pending verificationErasure when purpose is served or consent withdrawn
- Section 8(10), Section 13Rule 14 · pending verificationGrievance redressal mechanism
Official sources
Legal reviewPending legal review · drafted 19 Oct 2026
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