How to strengthen data privacy across your supply chain
Guest blog by Will Jackson, CEO at C2 Risk
A practical roadmap for ensuring your data strategy complies with GDPR and the ePrivacy Directive.
Managing personal data online goes beyond merely adhering to legal requirements; it is also essential for building trust and engaging with users. Non-compliance can lead to significant business risks. Under GDPR, companies that collect personal data must formalise agreements with any parties that process or receive this data, whether they are internal affiliates or external third-party providers.
One of the biggest challenges for organisations is maintaining visibility over their vendors and managing the access these third parties have to sensitive data.
Since GDPR came into effect in May 2018, alongside the Data Protection Act, its impact on non-compliant businesses has been severe. As of 2024, GDPR fines are approaching a staggering €5 billion, highlighting the continued focus on data protection enforcement and the growing financial risks of non-compliance.
Despite the regulation driving change, many businesses have been slow to achieve full compliance. However, as enforcement actions increase and more companies face penalties, the demand for stronger data protection measures continues to grow.
Below, we outline five practical steps to help align your supply chain’s data security strategy with GDPR and the ePrivacy Directive.
Conduct a Comprehensive Data Audit
Evaluate how your vendors handle data by assessing their processing activities and ensuring their compliance with GDPR. Request and review their data protection policies and practices to confirm they align with legal requirements. Regular audits or assessments can help verify that vendors continue to uphold compliance standards over time.
Understand the Regulatory Requirements
Ensuring GDPR and ePrivacy Directive compliance isn’t just your responsibility – it also extends to your vendors and third-party service providers. A clear understanding of these regulations, along with the risks of non-compliance, is essential. Review and update your contracts to include specific data protection clauses, such as confidentiality agreements, security standards, and limitations on data processing.
Strengthen Data Protection Controls
Restrict access to sensitive data by implementing strict access controls, both within your organisation and among your vendors. Regularly monitor and evaluate the security measures they use, such as encryption, secure data transfers, and safe storage practices, to maintain robust data protection across your supply chain.
Define Clear Privacy Policies and Guidelines
Set clear expectations for how vendors manage personal data through well-defined contractual agreements. These should include clauses requiring vendors to apply strong technical and organisational measures to protect the data they process. Establish a framework for ongoing vendor assessments to ensure continued adherence to compliance obligations.
Ensure Transparent Consent and Opt-Out Processes
Partner with your vendors to guarantee that they obtain clear and valid consent from individuals before processing personal data on your behalf. Develop structured processes for managing consent and opt-out requests consistently across all third-party providers. Keeping accurate records of consent is crucial for demonstrating compliance with GDPR and ensuring accountability.
By taking these proactive steps, your business can not only align its data strategy with GDPR and the ePrivacy Directive but also establish stronger safeguards to protect sensitive information throughout your supply chain. Regularly reassessing your policies will help you stay ahead of evolving regulations and maintain a high standard of data security.
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Jill Broom
Head of Cyber Resilience, techUK
Jill leads the techUK Cyber Security programme, having originally joined techUK in October 2020 as a Programme Manager for the Cyber and Central Government programmes. She is responsible for managing techUK's work across the cyber security ecosystem, bringing industry together with key stakeholders across the public and private sectors. Jill also provides the industry secretariat for the Cyber Growth Partnership, the industry and government conduit for supporting the growth of the sector. A key focus of her work is to strengthen the public–private partnership across cyber to support further development of UK cyber security and resilience policy.
Before joining techUK, Jill worked as a Senior Caseworker for an MP, advocating for local communities, businesses and individuals, so she is particularly committed to techUK’s vision of harnessing the power of technology to improve people’s lives. Jill is also an experienced editorial professional and has delivered copyediting and writing services for public-body and SME clients as well as publishers.
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Annie Collings
Programme Manager, Cyber Resilience, techUK
Annie is the Programme Manager for Cyber Resilience at techUK. She first joined as the Programme Manager for Cyber Security and Central Government in September 2023.
In her role, Annie supports the Cyber Security SME Forum, engaging regularly with key government and industry stakeholders to advance the growth and development of SMEs in the cyber sector. Annie also coordinates events, engages with policy makers and represents techUK at a number of cyber security events.
Before joining techUK, Annie was an Account Manager at a specialist healthcare agency, where she provided public affairs support to a wide range of medical technology clients. She also gained experience as an intern in both an MP’s constituency office and with the Association of Independent Professionals and the Self-Employed. Annie holds a degree in International Relations from Nottingham Trent University.
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Tracy Modha
Team Assistant - Markets, techUK
Tracy supports several areas at techUK, including Cyber Exchange, Cyber Security, Defence, Health and Social Care, Local Public Services, Nations and Regions and National Security.
Authors
Will Jackson
CEO, C2 Risk
