The final quarter is often overlooked for compliance work, but it’s actually ideal for a GDPR audit. Unlike the potential start of year chaos of Q1, you’ve got time to think clearly and work methodically. You’re also in the middle of budget planning for the next financial year, which means any findings can inform spending decisions whilst they’re still flexible. Starting now gives you breathing space to fix issues before the ICO comes knocking or before an incident forces your hand. Audits carried out in December can shape training programmes, technology investments, and headcount requests for 2026, rather than being a reactive exercise after something’s already gone wrong.
What a GDPR Audit Should Actually Include
A proper GDPR audit checklist should go beyond surface-level checks. Start with your core policies: privacy notices, data retention schedules, and internal governance documents. Review your subject access request process from start to finish. Have you logged every SAR and responded within time? Check your Data Protection Impact Assessments (DPIAs) against current projects. Pull training logs to confirm who’s completed what, and when refreshers are due. Your data maps need updating too, particularly if you’ve launched new services, hired staff, or changed systems this year. Don’t forget lawful basis documentation. Can you evidence why you process each category of personal data? If the answer’s vague, that’s a red flag.
The Most Common Gaps We Find
Some issues come up repeatedly: privacy policies still referencing the old company structure or products you discontinued two years ago; shared drives full of historical data that nobody’s reviewed, let alone categorised; processor contracts that were never signed or are sat in someone’s drawer rather than on a central register; staff who completed training once in 2018 and haven’t thought about GDPR since; and marketing teams running campaigns without checking the lawful basis. These aren’t exotic compliance failures; they’re the everyday gaps that grow quietly until an audit shines a light on them.
How to Use Audit Results to Inform Next Year’s Plan
Your audit shouldn’t end with a report gathering dust. Use the findings to build a realistic roadmap for 2026. If your data maps are incomplete, allocate time and resource to finish them. If training compliance is patchy, budget for a refresher programme or a new platform. If you’re missing contracts with key processors, plan the legal time to get them in place. If your tech stack can’t handle SARs efficiently, this is the evidence you need to pitch for better tools. Audits give you the business case for next year’s investment, not just a list of problems to feel bad about.
Quick Wins You Can Action Before March
Even if the full action plan stretches further into 2026, some fixes are fast. Update that stale privacy policy now. Delete the obvious stuff cluttering shared drives. Chase missing processor contracts. Bring in CSRB for refresher training with your team. Document your lawful basis for the top five processing activities. Tackling the low-hanging fruit before year end builds momentum and shows stakeholders, you’re serious about compliance.
When to Get Help (and What That Looks Like)
If you’re stretched thin or lack in-house expertise, bringing in a data protection specialist can make all the difference. CSRB’s experienced data protection professionals can run the audit objectively, spot gaps you’ve missed, and prioritise actions based on risk. They’ll interview stakeholders, review documentation, stress-test your processes, and deliver findings that are practical rather than theoretical. CSRB also bring knowledge of what good looks like across many sectors, so you’re not reinventing the wheel. Whether you need someone for a one-off audit or ongoing support, external help often pays for itself in clarity, speed, and confidence that you’ve covered the right ground. Get in touch to discuss how CSRB can help you use improved privacy and data protection processes for business improvement as well as compliance. Book an initial conversation and follow us on LinkedIn for the latest data protection news.