GDPR Compliance Checklist for Payment Processors

Document the lawful basis (consent, contract, legitimate interest, etc.) for each data processing activity.

Deploy clear, specific consent mechanisms with easy withdrawal options for all consent-based processing.

Allow individuals to receive their data in a structured, commonly used, machine-readable format.

Implement mechanisms for individuals to object to processing including direct marketing.

Implement processes to respond to Subject Access Requests (SARs) within one month.

Create procedures to delete personal data upon request within one month where applicable.

Designate a DPO if you are a public authority, conduct large-scale monitoring, or process special category data at scale.

Perform DPIAs for high-risk processing activities before they begin.

Integrate data protection measures into the design of all new systems, processes, and products.

Keep detailed records of all data processing activities including purposes, categories, recipients, and retention periods.

Deploy encryption, pseudonymization, and other technical measures appropriate to the risk level.

Create procedures to notify the supervisory authority within 72 hours and affected individuals without undue delay.

Ensure appropriate safeguards (SCCs, adequacy decisions, BCRs) for transfers outside the EEA.

Ensure all processors have Data Processing Agreements in place meeting Article 28 requirements.

Provide accessible, plain-language privacy information covering all Article 13 and 14 requirements.