The European market offers attractive conditions for doing business, providing access to solvent audiences, stable banking instruments, and international investments. However, entering this market is associated with high security requirements. One of these standards is the General Data Protection Regulation (GDPR).

 

What is the complexity of GDPR? It is not enough to simply copy someone else’s privacy policy. The Regulation requires a company to understand the path of every byte of information: where the data is stored, who has access to it, and how it is deleted. Within this project, Lawrange experts helped the client build a system from scratch, making it understandable both for regulators and for users.

 

Want more details? Learn them from the following sections of the material!

 

Task: Enter the EU Market While Minimizing Potential Regulatory Risks to Zero

A company planning to scale its service to European countries approached us. At the project start, the business had only a basic privacy policy that did not take into account the technical and legal nuances of GDPR.

 

This created a number of problems. For example, when concluding contracts with European partners, doubts arose regarding the feasibility of cooperation. In addition, the risk of being subject to sanctions from independent state supervisory authorities in the EU (DPAs) increased.

 

After reviewing the client’s materials, we formulated the tasks for the coming months:

  • Conduct an audit of current methods for collecting and storing information.
  • Develop a complete package of external and internal documentation.
  • Regulate employee work with confidential data.
  • Prepare agreement templates with contractors who have access to client information.
  • Reduce the risks of data leaks and unauthorized data use.

 

We understood that the main challenge lay in implementing the Regulation’s requirements. It was crucial not to complicate the user journey (UX) or overload the company’s internal processes.

 

Start of Work: Process Systematization and Creation of a Legal Framework

GDPR is based on the principle of accountability – the company’s obligation to document and prove the legality and transparency of personal data processing. Therefore, the key objective of the project was to create clear action algorithms for different scenarios.

 

To ensure that the implementation of new rules would not halt the client’s team operations, it was decided to divide the process into several stages. Within the project, we completed the following steps:

 

  1. Mapping of Personal Data Flows (Data Mapping). We identified all data collection points, categories of data subjects and data types, processing purposes, data retention periods, as well as legal bases (Legitimate Interest, Consent, and other grounds provided for under GDPR).
  2. Development of an External Documentation Package. We created a transparent Privacy Policy and Cookie Policy with disclosure of data subjects’ rights, legal bases for processing, and information about possible cross-border data transfers.
  3. Preparation of Internal Regulations. We developed instructions for employees, including Data Protection Policy and Data Retention Policy, as well as procedures for responding to and notifying data breaches (Data Breach Response & Notification Procedure).
  4. Consulting on Consent Mechanisms Setup. We developed correct wording for checkboxes and registration forms for data processing to ensure compliance with the criteria of “explicit and voluntary” user consent (including the possibility of subsequent withdrawal).
  5. Formalization of Contractual Basis with Partners. We prepared and agreed on amendments to contracts (Data Processing Agreements) with cloud providers and marketing services. The goal was to define liability for data breaches (referring to partners who also have access to client data).

 

What does such a comprehensive approach provide? In the event of an audit, the company can quickly and without issues provide documentary proof of compliance with GDPR requirements.

 

Result – Legal Status and Readiness for Scaling

The cooperation was productive. As a result, the client received a structured personal data management system and a regulatory resilient business model.

 

This helped resolve questions from European acquiring banks and partners for whom confirmed GDPR compliance is a mandatory condition for onboarding and further partnership.

 

In summary, the main achievements were:

  1. Minimization of regulatory risks: The business was brought into compliance with GDPR requirements and prepared for potential inspections by European supervisory authorities.
  2. Simplification of integrations and partner due diligence: Ready-made agreements and internal policies accelerated Due Diligence and Onboarding procedures with new partners and payment providers.
  3. Increased user trust: The availability of data management tools and clear explanations of client rights strengthened brand reputation resilience.
  4. Operational scalability readiness: The company received instructions on how to act when launching new products, changing functionality, or expanding the scope of processed data.

 

We transformed regulatory compliance into a systematic and manageable process. This allowed compliance to be integrated into the operational model without constraining business activity – exactly what the client wanted.

 

Planning to operate in Europe or want to align your current processes with GDPR? Entrust your documentation preparation to the lawyers at Lawrange. Contact our manager to audit your project!