A privacy programme needs to work when a product team changes a feature, a supplier requests access or an individual asks for their information. We connect the approved legal position to specific operational steps, with evidence that the relevant teams can find and explain.
GDPR applicability is not determined solely by citizenship or residence. It includes relevant processing in the context of an EU establishment and specified offering or monitoring activities involving individuals in the EU. We establish the factual scope with your legal advisers, including controller, processor and any joint-controller relationships.
Scope matters. EU GDPR, UK data protection law and sector-specific requirements need to be distinguished in a multi-market programme. A shared privacy process can support several obligations, but its legal basis, notices, transfer mechanism and response rules must be appropriate to the processing concerned.