The Data Protection Audit: Definition, Process, and Questionnaire

What is a data protection audit?

A data protection audit under the General Data Protection Regulation (GDPR) offers companies the opportunity to have their own data protection compliance voluntarily reviewed .

An audit generally refers to an examination that captures and evaluates specific parameters, and from which corresponding consequences are derived. A data protection audit therefore identifies and assesses the conditions in the area of data protection within a company.

The audit primarily serves to highlight relevant data protection gaps to the responsible party and to help them close these gaps afterwards. Therefore, the results of the data protection audit often serve as a basis for subsequently developing an individual data protection concept.

Why is a data protection audit useful for medium-sized companies?

The GDPR has strengthened the powers of supervisory authorities and tightened proof and documentation obligations for companies. A data protection audit enables companies to gain an Overview to get an overview of what is already working well and where optimizations are needed. The resulting data protection concept documents the corresponding data protection measures.

Data Protection Audit for SMEs – Efficient and Secure with an External DPO

Would you like to have a data protection audit carried out for your medium-sized company? Our certified data protection experts support your audit process independently and relieve the burden on your team.

Externen Datenschutzexperten finden

Who is authorized to conduct a GDPR-compliant audit?

Companies can engage internal or external auditors to conduct the data protection audit. In both cases, it is crucial that the responsible person possesses appropriate qualifications and experience .

For an internal audit to yield valid results, it must be ensured that the auditing person is independent and not directly involved in the processes being evaluated. Otherwise, conflicts of interest may arise.

Data Protection Audit with an External Data Protection Officer

An efficient way to conduct a data protection audit is to collaborate with an external data protection officer. With an external auditor, such as an external data protection officer, independence is guaranteed. As a specialized data protection professional who is not part of the organization, the external expert typically brings a neutral perspective and can objectively identify weaknesses. An external consultant with extensive experience from auditing various companies and industries can also provide practical recommendations for improving data protection organization.

Proliance's independent data protection experts support your data protection audit with extensive industry knowledge and independence. Additionally, our data protection consultants accompany your audit with modern data protection software, ensuring you receive a clean and complete basis for your data protection concept.

If a data protection audit is to be carried out as part of an official certification according to Art. 42 GDPR, the auditor must be appointed by an accredited certification body be approved.

How is a GDPR audit conducted?

As part of the data protection inventory, your company's data protection legal status quo is assessed using a digital or on-site data protection audit by certified data protection officers using a questionnaire.

Your individual audit report is the core of the entire audit process because the report describes the current data protection legal situation of the company, the data protection legal status quo.

Based on your information, the auditor documents which data protection measures are already in use within the company. Furthermore, it includes the forward-looking recommendations for action (a type of checklist) and further steps necessary for optimizing and implementing data protection in accordance with the General Data Protection Regulation (GDPR). Thus, your individual audit report is a crucial component of your operational data protection concept.

Clarity in 6 Phases: How a Data Protection Audit Works in a Company

A professionally conducted GDPR audit typically follows a clearly structured process, which is divided into six key phases . Each phase contributes to comprehensively reviewing a company's data protection compliance and identifying potential for improvement.

1. Preparation & Goal Definition: In this step, the scope and objectives of the data protection audit are defined. Objectives can include, for example, an internal review, preparation for certification, or the optimization of existing data protection processes. The organizational framework is also clarified in this phase – for instance, whether the audit covers the entire company or only specific business areas.
2. Document Review (Desk Audit): Here, the auditor analyzes the existing data protection documentation and compares it with GDPR requirements. This includes, among other things, the Record of Processing Activities (RoPA), data protection policies, concluded Data Processing Agreements (DPAs), training records, and technical and organizational measures (TOMs). 
3. On-Site Audit & Interviews: Next, the auditors gain a practical understanding of how data protection processes are actually implemented within the company. Discussions with employees from departments such as IT, HR, and Marketing verify whether the documented processes are being followed in practice. At the same time, technical systems, access rules, deletion concepts, and measures for data breaches are evaluated in practice.
4. Analysis & Evaluation: Subsequently, the auditor compiles all findings from the data protection audit and systematically evaluates them. Any weaknesses or risks are identified and assessed for their criticality – for example, as low, medium, or high.
5. Report & Recommendations for Action: The results of the GDPR audit are summarized in a report. This report includes a structured overview of the evaluation and concrete recommendations for action. These serve as a guide for improving data protection management within the company and are ordered by priority and urgency of implementation.
6. Follow-up & Implementation: In the final phase, the focus is on the practical implementation of the recommended measures. Companies create a data protection action plan based on the audit report and implement necessary adjustments. Optionally, a follow-up audit can be conducted to review progress and ensure sustained compliance with data protection requirements.

Benefits of a Data Protection Audit: Through the systematic review of technical measures and organizational processes, risks can be identified and addressed before data breaches or regulatory sanctions occur. Companies that regularly conduct GDPR audits thus strengthen their legal compliance and the trust of their customers, business partners, and employees.

Have a Data Protection Audit conducted by Proliance: How we support medium-sized businesses

Previously, GDPR audits required significant personnel resources, were time-consuming, and diverted the company from its core tasks. The innovative form is the digitized audit. We offer such a data protection audit for your company – conducted by our independent experts who utilize our data protection software Proliance 360 for even greater efficiency.

A digitized GDPR audit offers many advantages:

• a location-independent execution of the inventory assessment using digital questionnaires
• time-saving telephone follow-up questions from our side regarding the information in the questionnaires
• cost-effective alternative to an on-site audit

The biggest advantage of the digital data protection audit is the relief it provides to your team, as daily workflows are minimally disrupted.

Looking for more personalized advice? As an alternative to our digital assessment, Proliance offers a data protection assessment on-site . An on-site GDPR audit is particularly beneficial due to:

• On-site assessment of the company's data protection status
• Personalized on-site support from your external data protection officer at Proliance

Data Protection Audit Questionnaire – What Does It Cover?

In addition to interviews, document reviews, and on-site inspections, the primary tool for auditors is a catalog of questions, which the auditor uses to review the data protection measures in the company. 

For data protection certifications, the focus can vary , for example, data protection compliance for a specific project. The questions are selected accordingly. Certification bodies often use software for the data protection audit questionnaire that provides a template for the GDPR audit but offers enough flexibility for individual customization.

In a general data protection audit to determine the company's existing data protection standard, the auditor generally examines the following areas:

• Human Resources
• Finance
• Purchasing
• Sales
• IT

Our data protection audit checklist shows you what specific questions you might encounter. It provides you with an insight into the questionnaire for the data protection audit.

What is the outcome of the GDPR audit?

Following the data protection audit, a comprehensive audit report is created. It describes the current data protection situation in the company and thus serves as proof of your data protection activities.

Based on the information gathered during the audit, Proliance will provide you with initial recommendations for action. , so that you can address any data protection gaps and establish or further develop your data protection concept.

How a GDPR Audit Mobilizes Your Employees for Data Protection

In addition to employee training, the data protection audit is an excellent opportunity to draw the attention of the workforce to data protection concerns. Our experience shows that employees feel valued, when their opinion counts in the discussion process regarding data protection issues.  

An audit conducted according to GDPR regulations often also succeeds in raising employees' awareness of data protection, who previously had little knowledge of the subject and no interest in it.

A data protection audit promotes interaction between the various departments. As different departments interact with each other, many new ideas and feedback, which in turn can be incorporated into new data protection concepts. This also allows you to achieve a greater awareness of data protection issues.

With the questionnaire, the GDPR audit is straightforward

Every company can easily prepare for a data protection audit in accordance with the General Data Protection Regulation. Auditors generally review the GDPR's data protection requirements, which form the basis for the data protection audit questionnaire. Any company that takes the GDPR seriously will inherently have the appropriate answers ready for the questionnaire.

A final tip: View the GDPR audit primarily as self-optimization process with an assessment of the data protection status quo in your company. In that case, the costs for the data protection audit are also a good investment.