1. Introduction
As a leading fintech company in West Africa, NextGen Solutions must adhere to the highest standards of data protection. This report provides an external assessment of the company's current posture regarding the General Data Protection Regulation (GDPR). It serves as an actionable checklist to guide NextGen Solutions in managing its compliance obligations and protecting the data of any EU residents who use its services.
2. Actionable Compliance Checklist
| Category | Requirement | Recommended Action for NextGen | Status |
|---|---|---|---|
| Governance & Accountability | |||
| Scope & Applicability | Determine if GDPR applies. | Confirm if any clients, partners, or employees are EU residents. Review Zoho CRM and user databases. | Completed |
| DPO Appointment | Appoint a Data Protection Officer if required. | The Head of Compliance has been formally assigned the role of DPO. This is a positive step. | Completed |
| Training & Awareness | Educate staff on GDPR responsibilities. | Roll out mandatory GDPR training for all teams, with specialized modules for Customer Support and Dev teams. | In Progress |
| Data Management & Processing | |||
| Lawful Basis | Ensure all processing has a legal basis. | Map all data processing activities in payment platforms and CRM to a lawful basis (e.g., contract, consent). | In Progress |
| Consent Management | Obtain valid, informed, and unambiguous consent. | Implement granular consent checkboxes in the app onboarding flow with links to the privacy policy. | Not Started |
| Data Inventory | Document personal data flows and storage. | Create and maintain a Record of Processing Activities (ROPA) covering data in AWS, Zoho, and on-premise servers. | In Progress |
| Third-Party Management | Ensure vendors comply with GDPR. | Review contracts and sign Data Processing Agreements (DPAs) with AWS, GitLab, Zoho, and CyberArk. | Not Started |
| Security & Data Subject Rights | |||
| Data Protection | Protect data against unauthorized access/loss. | Verify encryption (at-rest and in-transit) for all customer financial data hosted on AWS and on-premise servers. | Completed |
| Access Control | Limit data access based on role (RBAC). | Audit and enforce RBAC policies in CyberArk and AWS IAM to ensure least privilege. | In Progress |
| Data Subject Rights | Enable rights like access, rectification, and erasure. | Develop an internal workflow using Freshdesk to handle Data Subject Access Requests (DSARs). | Not Started |
| Breach Notification | Notify authorities and individuals of breaches. | Develop and test an incident response plan that includes a 72-hour breach notification procedure. | In Progress |
3. Officer's Recommendation on Best Practices
Privacy by Design
It is strongly recommended that NextGen Solutions embed data protection principles into all new products and systems from the ground up. This includes adopting data minimization in the development lifecycle and conducting DPIAs for any new high-risk processing activities, such as the introduction of new biometric authentication features.