How to conduct a GDPR compliance audit? If your organisation processes personal data, a GDPR audit isn’t just a good idea — it’s essential. A well-executed audit provides clarity, mitigates risk, and ensures you’re aligned with regulatory expectations. But while it’s possible to attempt an internal audit, many businesses quickly realise the value of bringing in outside expertise.
At Compliance Direct Solutions, we specialise in data protection and cyber security consultancy for businesses across the UK. One of our flagship services is the Data Protection Audit — a detailed, impartial review of your current compliance posture, followed by hands-on support to close any gaps.In this article, I’ll show you how to conduct your own GDPR audit, the key elements to include, and why working with a specialist agency like ours can make all the difference.
How to Conduct a GDPR Compliance Audit
What Is a GDPR Compliance Audit?
A GDPR compliance audit is a structured review of your organisation’s data protection practices. Its goal is to assess whether your processing of personal data aligns with the UK GDPR or EU GDPR — depending on where you operate.
But more than just a checkbox exercise, a good audit gives you:
- A clear picture of what personal data you hold
- Insight into whether your practices are lawful, fair, and secure
- An action plan for addressing any risks or weaknesses
Think of it as a health check for your organisation’s privacy framework.
Can You Conduct a GDPR Audit Yourself?
Yes — in theory. If you have a strong understanding of data protection law, internal access to systems and documentation, and the time to dedicate to it, a self-audit can be a good start.
But be aware of the pitfalls:
- Bias: Internal teams may unintentionally overlook problems.
- Blind spots: Without expert knowledge, critical gaps might go undetected.
- No remediation: Identifying problems is one thing — fixing them is another.
That’s why we always recommend an independent audit at least annually, even if you carry out internal reviews in between.
How to Conduct a GDPR Compliance Audit
DIY GDPR Audit: Key Steps & Checklist
If you’re going to attempt your own GDPR audit, here’s a step-by-step guide to help:
1. Create a Personal Data Inventory
Map and document all the personal data you collect, store, and process:
- What type of data is it?
- Who are the data subjects?
- Where is it stored?
- Who has access?
This step is vital. Without knowing what you have, you can’t protect it.
2. Understand the Purpose and Legal Basis
For each data processing activity:
- Is the purpose clearly defined?
- What is the lawful basis (e.g. consent, legitimate interest, contract)?
- Have you documented this?
3. Assess Security Measures
Evaluate both technical and organisational security:
- Are systems patched and monitored?
- Is access restricted on a need-to-know basis?
- Do you use encryption, MFA, or backups?
4. Review Third-Party Sharing
- Who do you share data with?
- Are there Data Processing Agreements in place?
- Have you assessed their compliance posture?
5. Check Policies and Training
- Do you have up-to-date privacy notices, retention policies, breach response plans?
- Are staff regularly trained on data protection responsibilities?
6. Review Data Subject Rights Processes
Can your business:
- Respond to Subject Access Requests (SARs)?
- Honour requests for erasure or restriction?
- Demonstrate transparency?
7. Conduct a Gap Analysis
Once you’ve reviewed everything, identify:
- Where you are compliant
- Where you have partial compliance
- Where risks or breaches exist
How to Conduct a GDPR Compliance Audit
Why DIY Audits Often Fall Short
Even with a checklist, it’s easy to:
- Miss areas like hidden third-party integrations, marketing compliance, or legacy systems
- Underestimate how regulators interpret terms like “adequate” or “reasonable”
- Delay or deprioritise remediation work due to internal resource constraints
This is where Compliance Direct Solutions adds real value.
Why Work with a Specialist Agency Like Ours?
We don’t just hand over a checklist. Our Data Protection Audit service provides:
- Independent oversight — We deliver impartial findings without internal bias.
- Depth of knowledge — We bring expertise from across sectors, including high-risk and highly regulated industries.
- Actionable reporting — We don’t just say what’s wrong — we show you how to fix it.
- Remediation support — Need help drafting new policies, training staff, or overhauling contracts? We do it for you.
- Regulatory alignment — We make sure your practices meet the expectations of the ICO and European regulators.
Our audits can also help prepare your organisation for:
- Data subject complaints
- Regulator investigations
- Vendor due diligence processes
- Mergers and acquisitions
How Often Should a GDPR Audit Be Done?
At a minimum, annually. But more frequently if:
- You introduce new technology or services
- You process large volumes of sensitive data
- You’ve had a recent breach or near miss
- You operate in multiple jurisdictions
How to Conduct a GDPR Compliance Audit
The Real Value: Beyond Compliance
Ultimately, a GDPR audit isn’t just about avoiding fines. It’s about:
- Building trust with your customers and stakeholders
- Demonstrating corporate responsibility
- Reducing the risk of data breaches and reputational damage
- Future proofing your business
Ready for a Real GDPR Audit?
You’ve now got a good foundation for understanding how to approach a GDPR audit — but when the stakes are high, experience matters.
Let us take the pressure off. At Compliance Direct Solutions, we help businesses not only understand their data risks — but take control of them.
Book a free consultation to find out how our audit and remediation support can protect your business, your customers, and your reputation.
FAQ — GDPR Audits Demystified
Who can conduct a GDPR audit?
Technically, anyone can attempt to conduct a GDPR audit — but the question is: should they?
Internal teams often lack the impartiality and up-to-date expertise required to spot hidden risks.
A truly effective audit should be independent, structured, and delivered by professionals who live and breathe data protection.
That’s why regulators and clients alike give far more weight to audits carried out by specialist consultancies like Compliance Direct Solutions.
What does a Data Protection Audit include?
Our audits are tailored to your business size, sector, and risk profile, but typically cover:
- 🔍 Personal data discovery & mapping – Where is personal data stored, and why?
- 🔐 Security & access controls review – Who has access, and is it justified?
- 🤝 Third-party & processor analysis – Are your suppliers compliant too?
- 📄 Policies & procedures assessment – Are they up to date and fit for purpose?
- 🧠 Staff training & awareness review – Is your team handling data correctly?
- ⚖️ Data subject rights compliance – Can you handle SARs, deletions, and portability requests lawfully and on time?
- 🔧 Gap analysis & remediation roadmap – A prioritised, actionable plan to fix compliance issues
We don’t just identify the risks — we help solve them.
Is a Data Protection Officer (DPO) required?
Not every business needs a DPO under the UK GDPR or EU GDPR.
However, if your organisation carries out large-scale monitoring, processes special category data, or acts as a public authority, then a DPO is likely mandatory.
Even if not legally required, many organisations benefit from having a DPO-like role in place to oversee compliance and reduce risk.
Our audits include a DPO necessity assessment — and if needed, we offer DPO-as-a-Service, giving you access to a qualified expert without the cost of a full-time hire.
How often should we conduct a GDPR audit?
As a general rule, at least once a year — but there’s no one-size-fits-all answer.
You should also review your compliance whenever:
- 🆕 You launch a new product or service
- 🤝 You start working with a new supplier or data processor
- ⚠️ A data breach or near miss occurs
- ⚖️ There’s a change in the law, guidance, or regulatory expectations
For high-risk sectors like health, finance, or recruitment, we recommend quarterly reviews.
Our team can help you define the right audit frequency based on your risk appetite and regulatory exposure.
What are the risks of not doing a GDPR audit?
Failing to audit your data protection practices can lead to:
- ⚠️ Unlawful processing of data you didn’t know you had
- 🧾 Inadequate documentation (which regulators do expect)
- 💸 Fines and penalties – up to £17.5M or 4% of global turnover
- 🧑⚖️ Compensation claims from affected data subjects
- 🔍 Enforcement action after a complaint or data breach
- 💔 Loss of trust from customers, partners, and staff
An audit is not just a tick-box exercise — it’s a safety net that protects your brand and your bottom line.
Is it possible to do the audit ourselves using templates?
You can find checklists and templates online — in fact, we’ve even written our own guides to help businesses get started.
But be aware: DIY audits only go so far.
They can miss:
- Contextual risks unique to your sector
- Gaps in technical controls or third-party contracts
- Hidden problems in consent mechanisms, cookies, or marketing
Templates don’t interpret law, identify real-world risk, or recommend practical fixes.
That’s where we come in — combining expert analysis with real-world support to ensure you’re not just “trying” to comply, but actually doing it right.
What does a GDPR audit cost?
Our audits are competitively priced based on:
- 🏢 Your organisation size
- 📊 The complexity and volume of data you process
- 🌍 The number of locations, systems, and suppliers in scope
We offer fixed-fee packages for SMEs and custom pricing for larger or multi-national organisations.
Better still? We include remediation support — so you’re not just paying for advice, but for a partner who helps you implement the changes too.
Contact us for a free scoping call — no obligation, just a chat to see what you need.
Can we help you if you have had a data breach?
Yes — and we recommend acting immediately if you suspect a breach.
Our expert team can:
- 📞 Help you assess whether the breach is reportable to the ICO or other supervisory authorities
- 🛠️ Contain and investigate the incident
- 🧾 Draft breach notifications to affected individuals
- 🗂️ Document the incident for accountability purposes
- 🔄 Conduct a post-incident audit and update your policies and training
We also offer ongoing incident response support and breach readiness training so your team knows how to respond under pressure.
How to Conduct a GDPR Compliance Audit
A GDPR audit isn’t just a regulatory requirement — it’s a business-critical tool for identifying risk, building trust, and avoiding costly mistakes. Whether you’re preparing for an ICO investigation, responding to a customer request, or simply want peace of mind that your data protection practices are robust, we’re here to help.
At Compliance Direct Solutions, we don’t just tick boxes. We:
- Conduct independent, in-depth audits tailored to your business
- Deliver clear, actionable reports (no jargon, no fluff)
- Provide full remediation support to close any compliance gaps
- Offer ongoing consultancy to keep you aligned as regulations evolve
Let’s talk. Book a free, no-obligation call with one of our data protection experts today and take the first step toward full GDPR confidence.