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GDPR · 15 RECURRING ACTIVITIES

GDPR Compliance Calendar — Articles 30, 32, 35 in operating mode

GDPR is not a one-and-done program — Articles 24, 30, 32, 33, 35 all imply continuous obligations. This calendar maps every recurring GDPR activity, including the rule that breaks most teams: 72-hour breach notification.

Cadence mix:2× Monthly3× Quarterly1× Every 6 months6× Annually3× Event-triggered
Who this is for
  • Controllers + processors handling EU/UK personal data
  • Data Protection Officers (mandatory or voluntary)
  • SaaS companies with EU customers — subject to GDPR via Article 3(2)
Typical effort
Plan a designated DPO or Privacy Lead. Major efforts: annual RoPA refresh + any DPIA-triggering change.

The calendar

Monthly (2)

DSAR queue + SLA monitoring
DSAR
Track all access / erasure / portability / restriction / objection requests. Default deadline 1 month from receipt.
Reference
Art. 12, 15–22
Owner
DPO + Privacy ops
Effort
Variable
Evidence
DSAR ticket log
Sub-processor change watch
Sub-processor
Track changes in sub-processor list per Art. 28(2). If contract requires advance notice (typ. 30d), trigger customer notification.
Reference
Art. 28
Owner
DPO + Procurement
Effort
1–2 hrs
Evidence
Sub-processor register + notice log

Quarterly (3)

Article 30 RoPA spot-update
Records
Refresh records for any new processing activities, retention changes, recipient changes, transfer changes.
Reference
Art. 30
Owner
DPO
Effort
4 hrs
Evidence
Updated RoPA
Tier-1 processor reassessment
Vendor
Refresh DPA, SCCs / TIA, security attestation for high-risk processors.
Reference
Art. 28, 32
Owner
DPO + Security
Effort
4–6 hrs
Evidence
Updated processor file
Consent / cookie banner audit
Cookies / Consent
Verify banner reflects current trackers, default-off non-essential, granular controls, withdraw-as-easy-as-give.
Reference
Art. 4(11), 6(1)(a), 7; ePrivacy
Owner
Marketing + DPO
Effort
2–3 hrs
Evidence
Banner audit log

Every 6 months (1)

Article 32 controls testing
Resilience
Validate state-of-the-art technical + organisational measures: encryption at rest/transit, access, backup integrity, restoration test.
Reference
Art. 32
Owner
Security
Effort
8–16 hrs
Evidence
Controls test report

Annually (6)

Article 30 RoPA full refresh
Records
Both controller (30(1)) and processor (30(2)) records reviewed end-to-end with each business unit. Auditable on request from supervisory authority.
Reference
Art. 30
Owner
DPO + Business owners
Effort
16–32 hrs
Evidence
Refreshed RoPA
DPIA inventory review
Risk / DPIA
Review all completed DPIAs; refresh those with changed processing; trigger new DPIAs for high-risk new processing.
Reference
Art. 35
Owner
DPO
Effort
8–16 hrs
Evidence
DPIA register
Privacy notice / Article 13–14 disclosures review
Privacy Notice
Refresh purposes, lawful bases, retention, recipients, transfers, rights. Re-publish.
Reference
Art. 13, 14
Owner
DPO + Legal
Effort
4–8 hrs
Evidence
Updated privacy notice
GDPR awareness training
Training
All staff with access to personal data — content covers DSARs, breach reporting, lawful bases, sub-processor onboarding.
Reference
Art. 39(1)(b)
Owner
DPO + HR
Effort
4 hrs admin
Evidence
Training records
Transfer impact assessment refresh (Schrems II)
Transfers
For each non-adequacy transfer, refresh TIA: laws of recipient country, technical safeguards, supplementary measures.
Reference
Art. 46, EDPB Recommendations 01/2020
Owner
DPO + Legal
Effort
8–16 hrs/transfer
Evidence
TIA + SCCs
Breach notification tabletop
Breach
Drill the 72-hour clock: detect → contain → assess → notify SA → notify data subjects (if high risk).
Reference
Art. 33, 34
Owner
DPO + Security
Effort
4 hrs
Evidence
Tabletop after-action report

Event-triggered (3)

Personal data breach — notify within 72h
Breach
Notify supervisory authority within 72h of awareness; data subjects without undue delay if high risk.
Reference
Art. 33, 34
Owner
DPO + Incident lead
Effort
Variable
Evidence
Breach record + notifications
New high-risk processing — DPIA before launch
DPIA
Required when: large-scale special category, public-area systematic monitoring, automated decisions with legal effects, etc.
Reference
Art. 35
Owner
DPO + Project lead
Effort
16–32 hrs
Evidence
DPIA
New sub-processor onboarding
Sub-processor
DPA in place, security review, customer notice per controller contract.
Reference
Art. 28
Owner
DPO + Procurement
Effort
4–8 hrs
Evidence
DPA + due diligence

Pitfalls — where teams actually fail

Want this calendar mapped to YOUR controls?

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What happens when the cadence slips — real GDPR actions

€1.2B
Meta Platforms · 2023
€746M
Amazon Europe Core · 2021
€345M
TikTok · 2023

FAQ

Do we need a DPO under GDPR?
Required by Art. 37 if you are a public authority, your core activities involve large-scale systematic monitoring, or large-scale processing of special-category data. Many SMBs designate a Privacy Lead voluntarily — same calendar applies.
Is annual RoPA refresh formally required?
Article 30 doesn't set a frequency, but supervisory authorities expect records to be 'kept up to date.' Annual full refresh + quarterly spot-update is the working norm.
How does this calendar overlap with the UK GDPR / DPA 2018?
Almost identical. UK GDPR + DPA 2018 mirror the EU framework; this calendar applies. Differences are mainly around regulator (ICO vs SAs) and minor age-of-consent / law enforcement rules.
What changes under EU AI Act / Data Act for ongoing GDPR cadence?
Both add new obligations on top of GDPR (e.g. AI Act Art. 26 deployer obligations, FRIA for some high-risk uses). Privacy programs increasingly fold AI inventory + DPIA-FRIA hybrid into this same calendar.

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