• Determine if DSA applies to your organization
• Identify whether you act as a controller, processor, or both
• Understand the types of personal data you process
• Review relevant articles: Article 2 (Scope), Article 3 (Territorial Scope), Article 4 (Definitions)

Map your data processing activities:

• What personal data do you collect?
• Why do you collect it? (Legal basis)
• Where does it come from?
• Who has access to it?
• Where is it stored?
• How long do you keep it?
• Do you share it with third parties?
• Do you transfer it outside the EU?

Relevant: Article 30: Records of Processing Activities

For each processing activity, identify the legal basis:

• Consent: Freely given, specific, informed, and unambiguous
• Contract: Necessary for performing a contract
• Legal Obligation: Required by law
• Vital Interests: Protecting someone's life
• Public Task: Carrying out official functions
• Legitimate Interests: Your interests, balanced against individual rights

Relevant: Article 6: Lawfulness, Article 7: Consent

Ensure privacy notices are clear, transparent, and include:

• Identity and contact details of controller
• Contact details of Data Protection Officer (if applicable)
• Purposes and legal basis for processing
• Recipients or categories of recipients
• Information about international transfers
• Retention periods
• Data subject rights
• Right to withdraw consent
• Right to lodge a complaint with supervisory authority
• Whether data provision is mandatory
• Information about automated decision-making

Relevant: Article 13, Article 14

Establish processes to handle requests for:

• Access - Provide data copies within 1 month (Article 15)
• Rectification - Correct inaccurate data (Article 16)
• Erasure - Delete data when required (Article 17)
• Restriction - Limit processing (Article 18)
• Portability - Provide in machine-readable format (Article 20)
• Objection - Stop certain processing (Article 21)

Technical measures:

• Encryption of data at rest and in transit
• Pseudonymization where appropriate
• Access controls and authentication
• Regular security testing and monitoring
• Secure backups and disaster recovery

Organizational measures:

• Data protection policies and procedures
• Staff training and awareness
• Incident response plan
• Vendor management and contracts
• Regular audits and reviews

Relevant: Article 32: Security, Article 25: Data Protection by Design

Prepare for potential data breaches:

• Create incident response plan
• Designate breach response team
• Establish breach detection and reporting mechanisms
• Prepare breach notification templates
• Know your supervisory authority contact details
• Remember: 72-hour notification deadline to authority
• Document all breaches in breach register

Relevant: Article 33: Breach Notification to Authority, Article 34: Breach Notification to Individuals

For processors you use:

• Ensure adequate DSA-compliant contracts (Data Processing Agreements)
• Verify their security measures
• Confirm they only act on your instructions
• Check sub-processor arrangements

For international transfers:

• Check if destination country has adequacy decision
• Use Standard Contractual Clauses (SCCs) if needed
• Consider additional safeguards

Relevant: Article 28: Processors, Chapter V: Transfers

Appoint a Data Protection Officer if:

• You're a public authority
• Core activities require regular, systematic monitoring of individuals at large scale
• Core activities involve large-scale processing of special categories of data

DPO responsibilities:

• Inform and advise on DSA obligations
• Monitor DSA compliance
• Provide advice on DPIAs
• Cooperate with supervisory authority
• Act as contact point for supervisory authority

Relevant: Article 37, Article 38, Article 39

Perform Data Protection Impact Assessments for:

• Large-scale systematic monitoring
• Large-scale processing of special category data
• Systematic evaluation or scoring
• Automated decision-making with legal effects
• Processing of sensitive data at scale
• Monitoring publicly accessible areas at large scale
• New technologies likely to result in high risk

DPIA should contain:

• Description of processing operations
• Assessment of necessity and proportionality
• Assessment of risks to individuals
• Measures to address risks

Relevant: Article 35: DPIA

• Review and update records of processing activities
• Update privacy notices as processing changes
• Conduct regular staff training
• Review and test security measures
• Audit third-party compliance
• Review and update DPIAs
• Monitor regulatory guidance and case law

Maintain comprehensive documentation:

• Records of processing activities (Article 30)
• Data protection policies
• Consent records
• Data subject requests and responses
• DPIAs
• Breach register
• Training records
• Processor contracts

Relevant: Article 5(2): Accountability, Article 24: Controller Responsibility