GDPR: How businesses build compliance that actually works

When the Danish Data Protection Agency supervises, it is rarely sufficient to refer to a course alone. What really matters is whether the company can document that employees understand their duties, follow established procedures and handle personal data in a way that reduces risk.

GDPR is to a small extent about law in everyday life. It's about internal control, responsibility and practice. Training is one of the means, but only if it is relevant, up-to-date and actively used in the organization.

What is meant by GDPR training in practice?

GDPR training for employees is not about turning everyone into a privacy nuisance. It is about ensuring that employees

• understand what personal data is
• Know what data they are processing
• know your company's sharing, storage, and deletion practices
• know what to do in the event of errors, deviations or incidents

In practice, this means that training must be role-based and risk-oriented. An employee who works in customer service, HR or finance has a completely different risk picture than an employee who rarely handles personal data. Yet many businesses still provide equal training to everyone, with no clear link to actual work tasks.

Why many GDPR courses do not give the desired effect

A common problem is that GDPR training is conducted as a one-time activity. The course is completed, course certificates are saved, and the topic is considered covered. In practice, the opposite often happens. Knowledge is weathering, routines are forgotten, and employees are left unsure of what actually applies.

When the Danish Data Inspectorate questions supervision, it is rarely about whether training has been carried out, but about how the company works systematically with data protection over time. Then it becomes quickly apparent whether the training is integrated into management, routines and follow-up, or whether it has been only formal.

GDPR and Internal Control

GDPR requires companies to be able to show accountability. This means that the company must have an overview of how personal data is processed, what risks exist, and what measures have been taken to reduce these.

Training is part of this internal control. If employees do not know procedures for access management, transparency, deviation management or the safe use of IT systems, even good policies will be of limited value. GDPR training must therefore be viewed in the context of:

• Internal procedures and guidelines
• information security
• Deviation Management
• Management's responsibility and follow-up

What an audit typically looks for

When supervising, the Danish Data Inspectorate assesses whether the training is relevant to the business, not just whether it exists. The company should be able to explain:

• which employees need training
• how training is adapted to different roles
• how the training is followed up over time
• How the company ensures that the knowledge is applied in practice

It is also common for the supervisory authority to request documentation showing the link between training, routines and actual compliance. For example, how employees know what to do in the event of a discrepancy, or how new employees are inserted into privacy routines.

Role-Based Training for Better Compliance

Companies that are successful with GDPR training often build it around roles. This means that all employees get a basic understanding of privacy, while employees with special responsibilities receive more targeted training.

Managers must understand their responsibilities for internal control and priorities. HR must know the rules for processing employee data. Employees who work with customer data need to know how transparency, rectification and deletion are handled in practice. When training mirrors everyday life, it becomes both easier to understand and easier to follow.

Documentation that can withstand verification

For GDPR training, it is important to be able to document more than just participation. The company should be able to show when the training has been completed, who has participated, and what the training has included. This is especially true where the training is internal.

Documentation should also show how the training is kept up to date. Regulations, systems and work processes are changing, and training needs to be adjusted accordingly. A static solution rarely produces lasting compliance.

Follow-up makes the difference

The difference between GDPR training that has been completed and GDPR training that actually works often lies in the follow-up. Short tests, confirmations or repetitions help to anchor the knowledge. Equally important, employees know where to find routines, and who to contact with questions or incidents.

When deviations occur, they should be used as learning. Events often give a clear picture of where training should be strengthened or adjusted.

Common causes of non-compliance

When GDPR work does not work as intended, it is often due to a lack of structure. Training is conducted, but not linked to roles. Routines exist, but are little known. Responsibility is defined on paper, but unclear in practice. Over time, this leads to uncertainty among employees and an increased risk of errors.

GDPR training for employees is not about ticking off another requirement, but about building an organization that understands and handles personal data in a safe and structured way. When training, routines and follow-up are linked, compliance becomes a natural part of everyday work.

See Compend's course on GDPR