SERVICES

Data Protection (GDPR) for Business

If your organization processes personal data, GDPR obligations extend across every department. We help you close compliance gaps through audits, DPO outsourcing, privacy engineering, and targeted regulatory training for staff and management.

Section 01 · Privacy services

What GDPR compliance services have to produce

The GDPR is an accountability regulation. Article 5(2) requires the controller to demonstrate compliance, not merely to achieve it. That distinction changes the deliverable: the output of privacy work is evidence that survives a supervisory question, a customer audit, or a subject complaint — not a policy set that has never been tested against the processing it describes.

Four activities carry a programme. Establishing the factual position through records of processing under Article 30, data-flow mapping, and supplier inventory. Deciding, through risk assessment and impact assessments under Article 35. Building, through data protection by design and by default under Article 25. Operating, through subject requests, breach notification inside the 72-hour window in Article 33, and processor oversight under Article 28.

The engineering half is where programmes usually fail. Controls that exist only in a document break the first time a team ships a feature, because Article 25 requires the measures to be implemented in the processing itself: defaults, minimisation, retention, access, and logging as built, not as described. Each of those is a decision a reviewer can verify in code.

In Poland the supervisory authority is the President of the Personal Data Protection Office, applying the GDPR alongside the Personal Data Protection Act of 10 May 2018. Evidence assembled for privacy purposes also carries into ISO 27001 control A.5.34 on privacy and protection of PII, and into NIS 2 obligations where the same systems are in scope, which is the argument for building it once rather than per audit.

99
Articles in the Regulation
72 h
Deadline to notify a breach (Art. 33)
4%
Upper fine tier, global annual turnover
8
Data subject rights under Chapter III
Risk-led
Basis for defining scope
GDPR obligations an engagement is measured against

Privacy work is assessed against the text of the Regulation rather than a private maturity model. Each cell represents one provision; point at a group to see the provisions that most often carry the evidence. Counts are the full sets, not a selection.

Rights under Chapter III

8 of 34
  • Art. 13–14 Right to be informed
  • Art. 15 Right of access
  • Art. 16 Right to rectification
  • Art. 17 Right to erasure
  • Art. 18 Right to restriction of processing
  • Art. 20 Right to data portability
  • Art. 21 Right to object
  • Art. 22 Automated individual decision-making
Section 02 · Engagement drivers

What brings a privacy programme forward

Privacy work is seldom commissioned in the abstract. It is triggered by a change that outruns the existing records: a product that starts processing a new category of data, a supplier moved to a jurisdiction outside the adequacy list, an AI feature trained on customer data, a subject access request that nobody can answer within the statutory month, or a complaint that has already reached the supervisory authority.

  1. 01 New or materially changed processing A new product, analytics stack, or AI feature changes both the risk and the Article 30 record that describes it. 5
  2. 02 Customer or supervisory scrutiny A buyer audit, a subject complaint, or a supervisory enquiry exposes gaps between the policy and the processing. 4
  3. 03 Transfers outside the EEA A supplier change moves data under Chapter V and requires safeguards and a transfer assessment. 4
  4. 04 Unanswerable subject requests Requests that cannot be met within the statutory month indicate that records and systems have diverged. 3
  5. 05 Breach readiness The 72-hour clock in Article 33 is short enough that the decision path has to exist before the incident. 2
Indicative strength on a 1–5 scale, based on Up Secure engagement patterns.
Organisations required to appoint a DPO

Article 37 triggers the appointment for public authorities and for large-scale regular monitoring or special-category processing; the role must be independent and adequately resourced.

Product teams handling personal data

Article 25 places the obligation in the design itself, so defaults, retention, minimisation, and logging become engineering decisions rather than policy statements.

Processors serving EU controllers

Article 28 contracts flow controller obligations down to the processor, and buyers increasingly verify them before signature rather than after.

Section 03 · Programme coverage

Where each service contributes

A privacy programme runs from establishing the factual position through to sustaining it after the first review. The matrix shows where each area attaches; the services that deliver them are listed further down.

Data protection service coverage across the programme lifecycle
EstablishAssessImplementOperate
Assessment & assurance
GDPR compliance audit
Privacy maturity audit
Impact assessment (Art. 35)
Vendor and transfer review
Engineering
Privacy by design in the product
Data-flow and architecture review
Retention and access implementation
Operating roles
DPO role outsourcing
Privacy engineer capacity
Enablement
Request and breach handling training
Section 04 · Service portfolio

GDPR compliance services by delivery model

The catalogue below groups the available services by expertise: point-in-time audits and assessments, advisory work, embedded specialist roles such as an outsourced DPO, and recurring managed activities. The distinction matters when scoping, because an audit answers where the organisation stands while a role keeps the answer current.

Audits and Assessments

Systematic compliance audits, security assessments, and maturity evaluations across GDPR, ISO 27001, NIS 2, SOC 2, and AI Act frameworks for organizations in regulated industries.

GDPR Compliance Audit

GDPR compliance audit covering Art.5–35 with gap matrix, RoPA assessment, DPA chain analysis, and remediation roadmap.

GDPR
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AI System Privacy & Ethical Risk Audit

AI system audit covering data protection, ethical risks, bias assessment, and GDPR/AI Act compliance gaps.

AI ActISO 42001
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Consultancy and Advisory

Strategic consultancy and implementation advisory across GDPR, AI Act, ISO 27001, NIS 2, and cybersecurity for organizations building compliance programs or making security architecture decisions.

GDPR implementation consultancy and support

GDPR implementation support — gap analysis, policy development, RoPA setup, and ongoing compliance advisory.

GDPR
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Security and Privacy Architecture Review

Security and privacy architecture review for SaaS applications — threat modeling, data flow analysis, and design recommendations.

NIS 2 DirectiveGDPRISO 27001
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Cybersecurity and Data Protection Risk Assessment

Combined cybersecurity and data protection risk assessment with risk register, treatment plan, and DPIA support.

NIS 2 DirectiveGDPRISO 27001SOC 2
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US Software Review for EU Regulatory Compliance

Review of US-built software against EU privacy and cybersecurity regulations — GDPR, NIS 2, and AI Act compliance.

AI ActNIS 2 DirectiveGDPR
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Compliance and Risk Assessment Workshops

Compliance and risk assessment workshops — DPIA facilitation, risk analysis, and team capability building.

AI ActGDPR
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Role Outsourcing

Dedicated specialist roles including DPO, Privacy Engineer, Security Engineer, vCISO, and AI Compliance Officer available on a fractional or full-time outsourced basis.

Privacy Engineer Role Outsourcing

Embed Privacy by Design and privacy engineering into your software development and data management processes.

GDPR
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Software Engineering for Privacy and Security

SaaS prototyping, architecture reviews, and secure platform upgrades for Python/Django with privacy and security by design.

GDPR
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Data Protection Officer Outsourcing

Outsourced DPO fulfilling GDPR Art. 37–39 — DPIA support, data subject requests, and authority liaison.

GDPR
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EU Data Protection Representative Outsourcing for US based companies

EU Data Protection Representative under GDPR Art. 27 for US companies processing EU personal data.

GDPR
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Process Outsourcing and Managed Services

Ongoing risk assessments, vendor due diligence programs, and compliance monitoring delivered as managed services with defined service levels and regular reporting cadences.

Cybersecurity and Data Protection Risk Assessment

Combined cybersecurity and data protection risk assessment with risk register, treatment plan, and DPIA support.

NIS 2 DirectiveGDPRISO 27001SOC 2
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Vendor Risk Assessment

Third-party vendor risk assessment for cybersecurity, data protection, and supply chain security compliance.

NIS 2 DirectiveGDPRISO 27001SOC 2
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Start the conversation

Scope a data protection engagement around your processing and the systems behind it.

The first conversation maps what you process, who owns it, which suppliers touch it, and where the documentation has stopped matching the estate. From there, choosing between an audit, an impact assessment, engineering work, or a standing DPO role becomes a decision rather than a guess.

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Why Up Secure
Certified DPOs and engineers One engagement team that can read the Regulation and the code, which is the seam where privacy programmes usually come apart.
Independent by construction An external appointment resolves the Article 38(6) conflict of interest that rules out most internal candidates.
Built once, used repeatedly Records, risk decisions and supplier reviews serve GDPR, NIS 2 and ISO 27001 together instead of separately.
Section 05 · Frequently asked

Questions asked before a privacy engagement is scoped

Frequently asked questions

How is this page different from the GDPR framework page?
This is a service portfolio page: it explains how the work is delivered — assessment, engineering, specialist roles, and enablement. The GDPR framework page explains the Regulation itself, its obligations, and its enforcement context. The two link to overlapping services because they answer different questions: what the law requires, and who does the work.
Does appointing an external DPO transfer accountability?
No. Article 37 allows the data protection officer to fulfil the role on the basis of a service contract, and Articles 38 and 39 define the independence and tasks that come with it. Accountability under Article 5(2) stays with the controller. What an external appointment provides is an independent function with defined expertise, reporting to the highest management level, without a conflict of interest with the processing being supervised.
When is a data protection impact assessment mandatory?
Article 35 requires one where processing is likely to result in a high risk to individuals, and specifically for systematic and extensive automated evaluation producing legal or similarly significant effects, large-scale processing of special categories, and systematic large-scale monitoring of publicly accessible areas. Each supervisory authority also publishes a list of operations requiring an assessment, so the national list has to be checked alongside the Article 35 criteria.
What is required before moving data outside the EEA?
Chapter V applies. A transfer runs either on an adequacy decision under Article 45, on appropriate safeguards under Article 46 — most often the standard contractual clauses — on binding corporate rules under Article 47, or on a derogation under Article 49. Where safeguards are used, the destination country's law has to be assessed for whether it undermines them in practice, and supplementary measures added when it does.
What does the 72-hour breach deadline actually require?
Article 33 requires notification to the supervisory authority without undue delay and, where feasible, within 72 hours of becoming aware of a personal data breach — unless the breach is unlikely to result in a risk to individuals. Notification may be phased when the full facts are not yet available. Article 34 adds communication to affected individuals where the risk is high. The practical constraint is the decision path: who assesses risk, who authorises notification, and how it is evidenced.
Can privacy and cybersecurity work be coordinated?
Yes, and the evidence overlaps substantially. Article 32 security of processing, ISO 27001 control A.5.34 on privacy and PII protection, and NIS 2 risk-management measures draw on the same data flows, access controls, incident records, and supplier assessments. Producing that evidence once and reusing it is the difference between one programme and three parallel ones.