What is GDPR?
The General Data Protection Regulation (GDPR) is one of the most comprehensive data privacy laws in the world. Enforced since May 25, 2018, GDPR harmonizes data protection across the European Economic Area (EEA) and establishes strict obligations for how organizations handle personal data. While it originated in the EU, its territorial scope means that even non-EEA businesses must comply if they offer goods or services to—or monitor the behavior of—individuals in the EU.
Why it matters: GDPR compliance isn’t just a box to check. It’s a foundational part of building trust with customers and maintaining a strong security posture in a data-driven world.
How GDPR has been implemented historically
Since its enforcement, GDPR has reshaped how businesses think about personal data. The regulation requires businesses to implement “appropriate technical and organizational measures” (Article 32), such as encryption, resilience protocols, and regular testing, to secure personal data based on risk.
Early approaches were reactive. In the initial years, many organizations scrambled to update privacy policies, build Records of Processing Activities (RoPAs), and implement cookie banners. Compliance efforts were often driven by legal teams, disconnected from security and IT operations.
Lack of clarity led to inconsistency. Without a centralized enforcement body, each EU member state’s Data Protection Authority (DPA) interpreted GDPR slightly differently. This created confusion for multinational businesses and inconsistent audit practices.
Voluntary certification created a fragmented landscape. Articles 42 and 43 of the GDPR introduced the concept of certification. But this certification is not a blanket endorsement—it applies to specific data processing operations. Because certification schemes must be approved by national DPAs or the European Data Protection Board (EDPB), few recognized audits were initially available. Many organizations sought certifications or privacy seals from unaccredited bodies, assuming incorrectly that it demonstrated GDPR compliance.
Common challenges with GDPR compliance
Staying compliant with GDPR is not a set-it-and-forget-it task. The regulation is built around accountability, ongoing monitoring, and demonstrable controls.
Misunderstanding the certification scope. One of the most frequent missteps is assuming GDPR certification applies at the organization level. In truth, certification covers specific processing operations. Expecting a single certificate to cover your entire business is a setup for disappointment—and audit failure.
Documentation gaps. Article 30 requires detailed records of processing activities, and Article 35 mandates data protection impact assessments (DPIAs) for high-risk processing. Many organizations start these documents but fail to update them, making it difficult to demonstrate continuous compliance. Weak or outdated evidence trails can derail an audit.
Processor oversight difficulties. Under Article 28, controllers must ensure their processors (e.g., cloud vendors or analytics providers) are contractually required to allow and support audits. Many organizations neglect this obligation, assuming shared responsibility or that third-party compliance will suffice.
Unaccredited privacy seals. Without verifying that a certification body is accredited under Article 43, organizations may end up showcasing seals that offer no legal or reputational protection. Accreditation requires strict criteria—from evaluator independence to ongoing surveillance—and is essential for meaningful certification.
The GDPR audit and certification process
Although GDPR certification is voluntary, it can be a powerful tool for transparency and accountability. The audit process typically follows the model used in ISO/IEC 17065-accredited schemes:
Defining the certification scope. Organizations must specify which data processing operations are to be evaluated. This initial step is crucial; ambiguous or overly broad scopes can delay or derail the process.
Evaluation by independent auditors. The certification body conducts technical and organizational assessments and may review documents, interview staff, and conduct onsite visits. These auditors must be independent, qualified, and meet GDPR-specific competence standards.
Certification issuance and monitoring. If approved, certification is granted for up to three years, subject to ongoing monitoring. Regular surveillance checks ensure that certified practices remain compliant over time.
Accreditation matters. Certification bodies must be accredited by national DPAs or accreditation bodies. Accreditation confirms that the auditor’s methods, processes, and staff meet the required standards for independence, impartiality, and technical expertise.
Looking ahead: GDPR in 2026
As we move toward 2026, GDPR enforcement is becoming more mature—and more demanding.
More certifications, fewer shortcuts. In 2022, the EDPB approved the Europrivacy certification criteria, marking the beginning of EU-wide standardized privacy certification. By 2026, expect more organizations to pursue accredited certification, and more DPAs to clarify acceptable criteria. Informal seals or voluntary badges won’t carry the same weight.
Technology will drive compliance. Automated platforms are becoming essential to meet GDPR’s continuous accountability requirements. Organizations that rely solely on spreadsheets and manual tracking will struggle to keep pace with regulators’ expectations for real-time evidence and ongoing risk assessments.
Greater emphasis on cross-framework compliance. As privacy overlaps with broader security and risk standards (e.g., ISO/IEC 27001, ISO/IEC 27701, SOC 2), companies will look to unify their control frameworks. GDPR will no longer be treated in isolation—it will be evaluated in tandem with adjacent compliance obligations.
Stronger third-party scrutiny. Enforcement actions increasingly focus on supply chain risks. Controllers who fail to oversee their processors face liability, and by 2026, DPAs will expect evidence of ongoing third-party due diligence—not just SLAs and signed contracts.
How Thoropass improves GDPR compliance
Compliance shouldn’t slow you down. Thoropass streamlines GDPR readiness by automating documentation, centralizing evidence, and aligning privacy controls across frameworks.
Automate and centralize your privacy artifacts. Thoropass helps maintain up-to-date Records of Processing Activities (RoPAs), DPIAs, and third-party assessments in one platform. That means easier audits and faster preparation.
Bridge the gap between legal and security teams. Our platform maps GDPR obligations to technical security controls like encryption, access management, and backup testing—making Article 32 compliance traceable and repeatable.
Integrate GDPR into your broader compliance program. Thoropass supports multi-framework control mapping across GDPR, SOC 2, ISO/IEC 27001, and ISO/IEC 27701. This allows you to minimize duplication and scale your compliance program without repeating the same work for every framework.
Enable continuous monitoring. With integrations and automated evidence collection, Thoropass keeps your controls and documentation inspection-ready year-round. You’re not just checking statuses—you’re proving operational effectiveness.
Work with trusted experts. Our audit partners are independent, and our platform includes access to GDPR guidance and services like EU/UK representative partnerships via GDPRLocal. You’ll be supported by legal, privacy, and technical professionals every step of the way.
GDPR compliance, smarter and faster
GDPR has changed how the world handles personal data, but compliance doesn’t have to be overwhelming. With the right tools, organizations can maintain accountability, reduce audit fatigue, and build a sustainable privacy program that grows with their business.
Thoropass delivers that foundation. By connecting your technical controls, privacy documentation, and audit workflows in one streamlined platform, we make GDPR compliance a repeatable, reportable process—not an annual fire drill.
Schedule a discovery session today to learn how Thoropass can simplify your path to GDPR compliance.
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