GDPR Art.5.2: Accountability

Set up a clear governance structure. Appoint a DPO where Article 37 requires it, or designate a senior person responsible for data protection oversight. Define data protection responsibilities at every level - board, management, and individual data handlers. Everyone should know their role. Build and maintain your Records of Processing Activities (RoPA) as required by Article 30. Document the purposes, data categories, recipients, international transfers, retention periods, and security measures for each processing activity. Review and update these records whenever processing changes - a stale RoPA is nearly as bad as no RoPA. Put a Data Protection Impact Assessment (DPIA) process in place per Article 35. Define clear criteria for when a DPIA is triggered, create practical templates, and keep records of every assessment along with the decisions that followed. Embed this into your project and change management workflows so it happens automatically, not as an afterthought. Write a comprehensive set of data protection policies covering data subject requests, breach notification, international transfers, retention, and data sharing. Get senior management sign-off, communicate them to all staff, and review at least annually. Policies that nobody reads or follows are a liability, not an asset. Monitor and audit continuously. Run regular internal audits of your processing activities against your documented policies. Track compliance metrics, report to senior management, and when you find gaps, create corrective action plans with clear ownership and deadlines. The goal is a living compliance programme, not a folder of documents gathering dust.