Overview

This article ensures the accurate understanding and application of GDPR terminology, including concepts such as personal data, processing, controller, processor, consent, and pseudonymisation. Proper definitions support consistent identification and management of personal data processing activities.


Key Principles

  • Clarity: Establish a clear understanding of GDPR terms to avoid misinterpretation.

  • Consistency: Apply definitions uniformly across all organizational processes and systems.

  • Compliance: Ensure all personal data processing activities align with GDPR requirements through accurate terminology.

Organizational Applicability

This article applies to all organizations that process personal data, provided the processing falls within the EU’s jurisdiction:

  • Organizations handling personal data of EU/EEA data subjects.

  • Public and private sector entities, including controllers, processors, and third-party vendors.

  • Departments responsible for policy, IT systems, data management, and compliance.

Implementation Requirements

  • Maintain an internal glossary of GDPR terms relevant to the organization.

  • Ensure all policies, contracts, and process documentation use GDPR-compliant definitions.

  • Map processing activities to the correct GDPR terms (e.g., controllers, processors, personal data categories).

  • Provide guidance on consent, pseudonymisation, and other technical/organizational measures.

Implementation Guidance

  • Develop a GDPR Definitions Reference document for internal use.

  • Train staff to correctly interpret and apply GDPR terminology.

  • Include definitions in privacy notices, internal policies, and data handling procedures.

  • Review and update definitions when GDPR guidance or case law changes.

Periodic Review

  • Frequency: Annually or when new guidance or regulations are issued.

  • Responsible Role: Data Protection Officer (DPO) or Compliance Team.

  • Outcome: Ensure terminology remains accurate, aligned with GDPR, and consistently applied across the organization.

Non-Compliance Risks

  • Misinterpretation of GDPR obligations, leading to incorrect processing practices.

  • Regulatory penalties for failure to properly manage personal data.

  • Legal disputes due to misclassification of roles or processing activities.

  • Operational inefficiency and potential reputational damage.