15 points you must check for every agent — before it goes into production. If GDPR doesn't fit, it ends up costing you more hours than the setup saves. Structured by priority: what's mandatory (red), what should be in place (yellow), and what's sensible but optional (green). Practical, no legalese.
This checklist is not legal advice. It's a practical structuring sheet we use internally for our audit processes. For setups in regulated industries (health, finance, legal) or when processing special categories of data, always bring in a data protection officer or specialist lawyer. This list helps you have the right conversation with them — it doesn't replace it.
Order of work: first tick off every 🔴 must-have point — if one is left open, the agent does NOT go live. Then the 🟡 should-haves. Then, optionally, the 🟢 nice-to-haves.
Trap 1: The DPA with the LLM provider gets forgotten — every other point is fulfilled, but this one is missing. Trap 2: The privacy policy gets updated once and then forgotten — it needs to be updated again whenever you switch tools. Trap 3: "We only process internal data" — employee data falls under GDPR too. Trap 4: No audit trail — this only becomes apparent once the first complaint comes in.
Go through the must-have points with your data protection officer or whoever is responsible for data protection. Clarify together: what do we already have? What's missing? Who's responsible for creating what? This clarification typically takes 60–90 minutes — and saves weeks at the end.
Pin the list up visibly or into the project's Notion. For every major architecture decision: a 30-second check — does this violate a point? Incremental compliance is 10x cheaper than retrofitting it.
Final audit with the data protection officer. All 6 must-haves ticked off? All 6 should-haves reviewed (even if you decided not to implement them)? Written sign-off from the data protection officer. Only then go live.
Take point 15 seriously. A 90-minute review every quarter: What's changed legally? What have we changed in our setup? Are all compliance points still current? This meeting is the cheapest insurance against fines there is.
15 checkpoints. 18 pages. With reasoning for every point, real-world examples, and templates for DPA cover letters and privacy notices.
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