Last Updated on September 26, 2025 by Narendra Sahoo
A staggering 90% of people won’t support companies that ignore data privacy. With GDPR Requirements, businesses can’t afford to be careless — compliance isn’t just about avoiding fines, it’s about building digital trust.
The stakes are high when it comes to how businesses handle personal data. If you don’t understand the GDPR regulation, you could be breaking data protection rules. But here’s the good news: GDPR builds digital trust between you and your customers. By showing care for their data, you foster loyalty.
GDPR is more than avoiding fines; it’s about building trust. In this post, we’ll guide you through 10 key GDPR requirements. By the end, you’ll know how GDPR compliance protects your business.
Essential Key GDPR Requirements:
1.Lawful, Fair and Transparent Processing
One of the cornerstones of GDPR Requirements is that data must be handled lawfully, fairly, and transparently. In practice, this means you can’t just collect personal information because it’s convenient—you must have a valid reason, communicate it clearly, and respect individual rights.
- Lawful: Organizations need a legal basis for processing data. This could be explicit consent, fulfilling a contract, complying with a legal obligation, protecting vital interests, carrying out a public task, or pursuing legitimate interests.
- Fair: Data processing must not cause harm, create unexpected consequences, or mislead individuals. It’s about ensuring people aren’t taken advantage of.
- Transparent: Be open and honest about how data is collected, used, and stored. The most common way is through a clear, accessible privacy policy.
For example, when Apple introduced its App Tracking Transparency framework, it put transparency at the forefront. Users could see exactly what data apps wanted to track and make an informed choice—a move that aligns closely with GDPR Requirements.
This principle ensures respectful handling of personal data, which in turn builds credibility and trust between your business and its customers.
2.Purpose, Data and Storage Limitation
GDPR Requirements also make it clear that organizations should collect data with discipline and restraint. Every piece of information must have a purpose, and that purpose should be explained to the individual from the start. Holding on to unnecessary or outdated data not only increases your compliance risks but also weakens customer confidence.
- Purpose Limitation:Personal data should only be collected for a specific, legitimate reason—and it must not be repurposed later without consent.
- Data Minimization: Gather only what you genuinely need. The more information you store, the higher your responsibility and risk in case of a breach.
- Storage Limitation: Retain personal data only for as long as it serves its purpose. Once that purpose is fulfilled, data should be securely deleted.
A practical example: if someone subscribes to your newsletter, you only need their email address—maybe their name at most. Asking for birth dates, postal addresses, or phone numbers adds no real value and violates the principle of minimization.
Following these GDPR Requirements doesn’t just keep you compliant; it also signals to your customers that you respect their boundaries and value only the information truly necessary for your service.
3.Data Subject Rights
One of the most powerful elements of GDPR Requirements is the set of rights it grants to individuals over their personal data. These rights shift the balance of power, ensuring that people—not organizations—remain in control of their information. For businesses, this means building systems and processes that can quickly respond to such requests.
- Right of Access: Individuals must be able to see what personal data you hold about them and understand how it’s being used.
- Right to Rectification: If data is incorrect or incomplete, you need to correct it promptly.
- Right to Erasure: Also known as the “right to be forgotten,” this requires you to delete personal data when there’s no legal reason to keep it—such as when consent is withdrawn.
- Right to Restriction of Processing: Individuals can request that their data be restricted in specific situations, limiting how you use it
- Right to Data Portability: People should be able to transfer their personal data from one service provider to another in a structured, machine-readable format.
- Right to Object:People should be able to transfer their personal data from one service provider to another in a structured, machine-readable format.
A real-world illustration: In 2018, Google faced complaints under GDPR because users found it nearly impossible to exercise their rights around consent and transparency. The French regulator (CNIL) fined Google €50 million—the largest GDPR fine at the time—because those rights were not made practical or accessible.
By embedding these rights into your operations, you not only comply with GDPR Requirements but also demonstrate that your organization respects individual choice and autonomy. That, in today’s trust-driven digital economy, is a competitive advantage.
4.Consent
Consent is one of the most talked-about aspects of GDPR Requirements, but also one of the most misunderstood. It isn’t about a box ticked once and forgotten—it’s about giving individuals a genuine choice and maintaining their control over personal data throughout the relationship.
- Freely Given: Consent cannot be bundled with unrelated terms, hidden in lengthy contracts, or made a condition for receiving a service. People must feel free to say yes—or no—without pressure.
- Specific: You must tie consent to specific purposes. Blanket consent for wide-ranging processing is not valid.
- Informed: You must give individuals clear information about what they are consenting to, including who the controller is, and how you will use their data.
- Undeniable: You need clear affirmative action (e.g., ticking a box, signing a form) for consent. Silence or inactivity do not suffice.
- Revocable: You must allow individuals to withdraw consent at any time and make this withdrawal as easy as initially giving consent.
A telling example came in 2020 when Twitter was fined €450,000 for failing to meet GDPR obligations on user consent related to tracking and advertising. The issue wasn’t just about compliance—it was about ignoring users’ right to say no.
Handled correctly, consent transforms into more than a legal requirement—it becomes an opportunity to build digital trust. When customers see that you respect their decisions, they are more likely to remain loyal and engaged with your brand.
5.Personal Data Breaches:
No matter how strong your defenses are, data breaches remain a real possibility. GDPR Requirements recognize this and demand that organizations be prepared—not just to prevent breaches, but to detect, respond, and recover when they occur. A misstep here can turn a technical issue into a full-blown reputational crisis.
- Detect and Assess: You need robust monitoring systems to spot breaches quickly and determine the potential impact on individuals.
- Notify Authority: If breach risks individuals’ rights, inform the authority within 72 hours (about 3 days) unless risk is unlikely.
- Notify Individuals: If high risk to individuals, notify them promptly.
- Contain and Mitigate: Immediately stop the breach and minimize impact.
- Document: Keep records of breaches, actions, and decisions.
The 2018 Marriott breach is a stark example. Hackers accessed the records of around 339 million guests worldwide, including passport numbers and payment details. Under GDPR, Marriott faced a proposed £99 million fine from the UK ICO—not just for the breach itself, but for failing to have adequate safeguards and timely response protocols.
By treating breach readiness as an ongoing discipline rather than a checkbox, you demonstrate that GDPR Requirements are woven into your security culture. Customers take notice when organizations respond with speed, transparency, and accountability.
6.Privacy by Design and by Default:
The GDPR requires you to embed data protection into your processes and technologies from the start through the core principles of Privacy by Design and Privacy by Default.
- Privacy by Design: You must proactively build privacy in at every stage when designing new products, services, or business practices – not reactively.
- Privacy by Default: You must ensure user-friendly privacy settings are the default. You should only collect and process the minimum necessary personal data for a defined purpose.
A strong example is seen in messaging apps like Signal, which are designed with end-to-end encryption as a default setting. Users don’t have to enable privacy—it’s already built into the system. That’s exactly what GDPR Requirements are aiming for.
When organizations adopt this proactive approach, they not only minimize regulatory risk but also send a clear signal: customer privacy isn’t an afterthought, it’s a design principle. Over time, this strengthens brand trust and differentiates you from competitors who treat privacy as an add-on.
7.Data Protection Impact Assessments (DPIAs):
You must conduct a DPIA, which is a systematic process designed to help you identify and minimize data protection risks associated with new projects or processing activities.
When conducting DPIA, processing is likely to result in a high risk to individuals’ rights and freedoms. This is likely in cases involving:
- Large-scale processing of personal data
- Processing of sensitive data (health, biometrics, etc.)
- Systematic monitoring (e.g., employee surveillance)
- New technologies (facial recognition, AI-based decision-making)
For instance, when a hospital introduces AI-powered diagnostic tools, a DPIA ensures the system doesn’t inadvertently misuse sensitive health records or expose them through poor security. Skipping this step could lead not only to compliance failures but also to serious ethical and reputational damage.
DPIAs aren’t about slowing innovation—they’re about making sure that innovation doesn’t come at the expense of trust. By embedding them into project planning, you align with GDPR Requirements and show stakeholders that your organization treats privacy as a strategic priority, not a regulatory burden.
8.International Data Transfers:
In today’s interconnected world, very few organizations keep data strictly within national borders. GDPR Requirements recognize this reality and set strict conditions for transferring personal data outside the European Economic Area (EEA). The goal is simple: data must receive the same level of protection no matter where it travels.
- Adequacy Decisions: Some countries have GDPR Requirements-comparable laws, allowing free data transfer.
- Standard Contractual Clauses (SCCs): Pre-approved contracts for data protection in countries without adequacy decisions.
- Additional Safeguards: Encryption or data minimization may be needed for certain transfers.
- Transfer Impact Assessments (TIAs): Assess risks before transferring data.
- Data Subject Rights: GDPR rights apply internationally.
The Schrems II ruling in 2020 is a notable example. The EU invalidated the Privacy Shield agreement with the U.S. after determining that American surveillance laws did not provide adequate protection. As a result, thousands of companies had to quickly adopt SCCs or alternative safeguards to remain compliant.
International transfers aren’t just a legal formality—they are a test of accountability. By carefully managing them, you show customers and regulators alike that GDPR Requirements are being respected, even in complex global operations.
9.Data Protection Officers (DPOs):
Another critical element of GDPR Requirements is the role of the Data Protection Officer (DPO). A DPO isn’t just a compliance checkbox—they act as the guardian of data protection within your organization. Whether mandatory or voluntary, having a DPO demonstrates a serious commitment to privacy.
DPOs have several responsibilities:
- Advise and monitor data protection practices.
- Conduct staff training.
- Serve as a contact point.
- Oversee Data Protection Impact Assessments.
- Assist with data breach management.
DPOs should be independent, knowledgeable about GDPR Requirements,technicalities and well-resourced. Even if not mandatory, having a DPO shows commitment to data protection.
Take the example of Deutsche Wohnen, a German property company fined €14.5 million in 2019. One of the failures noted was poor accountability and lack of proper oversight—issues that a well-supported DPO could have helped prevent.
Even when not strictly required, appointing a DPO sends a strong message to clients, regulators, and partners: your organization treats GDPR Requirements with the seriousness they deserve. It’s an investment in both compliance and credibility.
10.Accountability:
Accountability is a core GDPR principle. It means taking responsibility for your data protection practices and being able to demonstrate compliance, not just claim it.
How to Exhibit Accountability:
- Documentation: Maintain records of data protection activities.
- Privacy by Design and Default: Incorporate privacy in systems and processes.
- DPIA: Perform DPIAs for high-risk activities.
- Staff Training: Train staff on data protection practices.
- Incident Response: Establish procedures for managing data breaches.
- Data Subject Rights: Set up mechanisms for individuals to exercise rights.
- DPO: Appoint a DPO if necessary.
- Regular Reviews and Audits: Regularly evaluate and update data protection measures.
For example, when the UK’s Information Commissioner’s Office (ICO) investigated British Airways after its breach, one of the aggravating factors was the lack of demonstrable accountability—BA could not show they had systematically reviewed or tested their data protection measures.
True accountability goes beyond regulatory compliance. It reassures customers, partners, and stakeholders that your organization doesn’t just meet GDPR Requirements on paper—it lives them in practice. In a market where trust is currency, accountability is one of your most valuable assets.
Conclusion:
GDPR Requirements may seem complex, but it empowers individuals and businesses alike. By embracing these principles, you gain a competitive advantage. Proactive data protection builds trust, unlocking the full potential of data. Take charge of your data practices now. If you need support, expert resources are available at our VISTA InfoSec website to guide your compliance journey.
Let us help you
Need expert help with GDPR Requirements & GDPR compliance? We’ve been guiding organizations since the regulation’s start. Our comprehensive services ensure your data protection controls are robust.
We have a dedicated team of privacy experts offering both auditing and consulting/advisory services to help you define robust processes and achieve lasting compliance. Our proven track record includes successful GDPR readiness assessments, gap analysis, policy development, and final certification support.
As a vendor-neutral partner with a strict no-outsourcing policy, we prioritize the confidentiality and integrity of your data throughout the process. We specialize in the following technical assessments crucial for GDPR compliance:
- Data Protection Impact Assessments (DPIAs)
- Records of Processing Activities (ROPAs)
- Data Breach Notification Procedures
- Data Subject Access Request (DSAR) Processes
- Privacy by Design Reviews
Let us help you navigate the GDPR landscape with confidence and protect your organization from costly penalties. Contact us today for a personalized consultation.
Narendra Sahoo (PCI QPA, PCI QSA, PCI SSF ASSESSOR, CISSP, CISA, CRISC, 27001 LA) is the Founder and Director of VISTA InfoSec, a global Information Security Consulting firm, based in the US, Singapore & India. Mr. Sahoo holds more than 25 years of experience in the IT Industry, with expertise in Information Risk Consulting, Assessment, & Compliance services. VISTA InfoSec specializes in Information Security audit, consulting and certification services which include GDPR, HIPAA, CCPA, NESA, MAS-TRM, PCI DSS Compliance & Audit, PCI PIN, SOC2 Compliance & Audit, PDPA, PDPB to name a few. The company has for years (since 2004) worked with organizations across the globe to address the Regulatory and Information Security challenges in their industry. VISTA InfoSec has been instrumental in helping top multinational companies achieve compliance and secure their IT infrastructure.
