How to Configure GDPR Controls That Hold Up in Audits

GDPR compliance is a set of privacy requirements that organizations must follow when processing personal data of individuals from the EU. This guide will walk you through how to translate GDPR controls into configurations that withstand audit scrutiny and prove compliance.

GDPR framework to configure and prove compliance

Compliance can’t be achieved and ensured through configurations alone, as it requires repeatable practices that adhere to your regulation’s principles. The methods below transform GDPR requirements into controls that are provable through audits, documentation, and continuous monitoring.

📌 Prerequisites:

• Repository for audit evidence, such as exports, screenshots, and logs
• Existing inventory of stored data, where it’s kept, and who can access it
• Admin access to Microsoft 365 Purview and endpoint management tools
• Defined lawful basis for collection and retention targets per processing activity

Step #1: Map compliance responsibilities to GDPR controls and safeguards

Mapping legal requirements into operational safeguards transforms your controls into tangible configurations that align with your stack’s capabilities. Pairing compliance requirements with right-sized actions ensures every data-processing activity is protected in compliance with GDPR standards.

List data processing activities and compliance obligations

Begin by creating an inventory workflows that include personal data, such as HR records, client contacts, and device logs. For each activity, identify the legal obligation required to preserve compliance. This helps you match data flow with the appropriate protection level.

Assign GDPR controls to workflows

For processing systems and services, GDPR compliance revolves around core security principles, namely confidentiality, integrity, availability, and accountability. For each processing activity, define at least one control for each pillar.

Document owners, verification procedure, and evidence

Capture control ownership, how they were verified, and the accompanying evidence. This showcases not only your existing controls, but also how you monitor and validate them.

Step #2: Enforce endpoint privacy and access configurations

Every endpoint, such as laptops, desktops, or managed devices, that touches personal client data can be exploited. Reduce your attack surface by implementing privacy and access policies on data-processing endpoints.

Recommended action plan:

1. Set policies to allow or deny OS and app access to account info by default.
2. Place consistent file access rules and manage clients through groups, not individual users.
3. Enable Controlled Folder Access (CFA) on sensitive directories, such as payroll, customer databases, or HR data folders.
4. Implement secure configurations, local firewalls, attack-surface-reduction rules, and credential protection policies.
5. Enforce full disk encryption on all laptops and workstations that handle personal data.

Step #3: Build a GDPR controls checklist for Microsoft 365 data

Microsoft 365 stores emails, files, chats, and records that can potentially contain personal data. Enforcing proper data governance ensures that personal data remains protected and accounted for, including its storage, retention, and access policies.

Utilize Purview Data Loss Prevention (DLP)

Configure Microsoft Purview DLP to secure personal data types, such as IDs and contact details. Route alerts to a dedicated triage mailbox or queue after privacy policy breaches. Adjust thresholds and actions over time to minimize false positives and tighten policies to secure sensitive content.

Apply retention labels

Retain data to match the purpose of data processing workflows in accordance with GDPR’s storage limitation principle. Consistently enforce retention labels and mark specific data sets to prevent premature deletion or modification.

Schedule regular scans

Scan high-value areas like Teams channels and OneDrive folders to identify gaps, misclassified data, or files outside retention scopes. Document findings and remediations through screenshots, export logs, or review notes to leave a traceable audit trail for future reviews.

Step #4: Consistently apply GDPR controls across your stack

Some environments rely on numerous tools, platforms, and apps that handle personal data in different ways. That said, your GDPR framework’s scope shouldn’t just stop at Microsoft 365 services; it should also extend consistently across all relevant tools.

Review consent, data retention, and retention period per app

Review how each tool handles user consent, data retention, and deletion. Align defaults with your organization’s standards; for instance, setting consistent retention across platforms like Microsoft 365, CRM, and HR systems.

Turn on logs and access controls

Enable audit logging and privacy settings across platforms that track administrative actions, data exports, or permission changes. Verify that your retention period for logs is sufficient to support audits and reviews.

Review data export and anonymization procedures

Check how each system exports or anonymizes personal data when responding to Data Subject Access Requests (DSARs). Standardize output formats and redaction rules to ensure quick responses and mitigate risks across sources.

Use vendor GDPR controls as a reference

If your vendor offers GDPR or privacy configuration pages, use these as design references when creating a runbook. Mirror their structure to streamline the standardization of your compliance model across platforms.

Step #5: Maintain backup and restore readiness for GDPR compliance

GDPR’s Article 32 states that organizations must be capable of restoring corrupted, unavailable, or lost data in a timely and accurate manner. Maintaining backup and restore readiness ensures not only the existence of backups but also their reliability and integrity.

Recommended action plan:

1. Back up Microsoft 365 services and SaaS apps that contain and process GDPR-compliant data.
2. Conduct quarterly restore tests to verify backup reliability and integrity, then document each test’s result in your evidence packet.
3. Define your RTO and RPO for each system according to the sensitivity and importance of the data it handles.
4. Compare test results to recovery objectives to identify gaps and formulate improvements.

Step #6: Maintain continuous oversight across GDPR controls

Monitoring, auditing, and capturing evidence keep your strategy current, traceable, and defensible. Simply put, these strategies prevent your GDPR controls from accidentally drifting over time.

Recommended action plan:

1. Schedule checks for encryption status, CFA state, privileged group membership, patch posture, and Purview activity summaries. Document each check, including test results and ownership.
2. Export monthly summaries of Purview DLP incidents, classification label usage, and auto-labeling coverage.
3. Maintain an incident timeline template that includes detection time, response actions, containment procedures, and alerting processes.
4. Collect all generated checklists, exports, summaries, and proofs within a single evidence packet each month. Label it by date and store it in a secure folder.

Step #7: Include subject rights operations in GDPR compliance frameworks

Creating a standardized DSAR workflow streamlines your subject rights operations, allowing you to consistently respond to access requests promptly and accurately. To accomplish this, build a DSAR response process with clear stages, including discovery queries, legal review, redaction, and secure delivery.

Track how long each stage takes to complete, and store all per-stage artifacts in an evidence folder. This serves as your defensible record, providing to audits that DSARs are handled in compliance with GDPR requirements.

Step #8: Configure GDPR controls to secure data movement

Ensuring data privacy extends to every cloud service, integration, and outsourced provider that becomes part of your data-processing system. Even if your internal systems are airtight, you can still break compliance when that personal data leaves your direct control.

Recommended action plan:

1. Build a vendor register that lists all third parties processing or storing personal data. Include data type, the transfer mechanisms used, and the verification checks employed to ensure data protection.
2. Confirm where each vendor stores and processes your data, ensuring that it aligns with GDPR’s data transfer requirements. Additionally, request documentation that confirms encryption for both data at rest and in transit.

Step #9: Sustain GDPR controls through continuous verification

Consistent testing ensures that each compliance control you have in place works as designed over time. By scheduling tests, you have a fresh, complete, and organized evidence packet that proves compliance.

Recommended action plan:

1. Conduct monthly verification procedures across key GDPR controls; review alerts, close exceptions, and capture artifacts for your evidence packet.
2. Perform quarterly restore tests and access reviews to ensure recoverability and reduce excessive permissions.
3. Optimize Purview DLP rules or labeling policies to reflect newly observed incident patterns.
4. Run annual tabletop exercises to gauge your team’s efficiency in handling actual incidents or workloads, such as data breaches, DSAR, or vendor inquiry simulations. Document your team’s response timeline.

Automation practices to support existing GDPR controls

Automation ensures your compliance controls remain consistent and timely, while lessening manual technician workflows

Here’s how automation can tighten compliance:

• Verify endpoint protection by gathering BitLocker encryption state and checking CFA enablement for all endpoints.
• Pull monthly Purview DLP incidents and label coverage reports to track policy effectiveness and identify trends.
• Test backup integrity by performing sample restores across Microsoft 365 services, ensuring backup integrity and recoverability of personal data.
• Automate evidence packet generation, including relevant GDPR clauses and assigned control owners.

NinjaOne automation features to streamline compliance

NinjaOne’s integrated backup, encryption, and script deployment tools ensure your endpoints, emails, and SaaS services remain compliant by default.

• Email archiving solution: Leverage NinjaOne email archiving solution to ensure email communications and SaaS data containing personal information are securely stored, immutable, and retrievable on demand.
• Encryption: NinjaOne’s SaaS backup solution uses 256-bit (AES) encryption for both data in transit and at rest, ensuring secure data movement and storage.
• Remote script deployment: Easily schedule verification and endpoint baseline script deployments centrally across managed endpoints through NinjaOne.
• Microsoft 365 Backup: NinjaOne supports incremental backup for Microsoft 365 services, minimizing data exposure and meeting limited storage requirements.

Enforce GDPR controls across your environment

When you connect compliance requirements to a clear control, apply those settings consistently, while pairing them with regular checks, compliance becomes part of your routine. Automation, clear ownership, and consistent documentation transform audits into a repeatable process that proves your compliance.

Related topics:

• A Comprehensive Guide to Customer Data Protection
• Data Privacy and Compliance Technologies for Operationalizing CCPA and GDPR Compliance
• What is GDPR Compliance? How to Stay Compliant
• Complete Guide: Setting Up Microsoft Purview (Compliance Center) for SMB clients
• DORA vs GDPR: Key Differences Explained