Post-GDPR: First Week Lessons Learned

May 28, 2018

The GDPR enforcement deadline passed on May 25th. After months of preparation, we’re now operating under the new regulation. Here’s what we learned from the experience and what we’re seeing across the industry.

What Went Well

Early Start Paid Off

We started GDPR preparation 14 months ago. This was essential:

Teams that started in April 2018 didn’t have time to do it properly.

Cross-Functional Collaboration

GDPR required alignment across:

Early collaboration prevented last-minute conflicts.

Privacy by Design Adoption

The process forced us to think about privacy from the start:

These practices improve our products regardless of regulation.

What Surprised Us

Users are overwhelmed by consent dialogs:

Some implementations create poor user experience:

"We value your privacy. Here's a 47-page privacy policy
and a consent form with 15 categories and 127 third-party
vendors. Make your choices now to continue."

This creates consent fatigue without meaningful control.

Dark Patterns Emerged

Some companies implemented technically-compliant but ethically-questionable patterns:

These may face regulatory scrutiny.

Data Subject Requests Higher Than Expected

We anticipated some access and deletion requests. We underestimated volume:

Automation was essential.

Third-Party Dependencies

Our compliance depended on vendors:

Start vendor assessments early.

Technical Lessons

Automation Is Essential

Manual data subject request handling doesn’t scale:

# Automated export pipeline
def handle_access_request(user_id, request_id):
    data_sources = [
        user_service,
        order_service,
        analytics_service,
        support_service,
        marketing_service,
    ]

    export_data = {}
    for source in data_sources:
        try:
            export_data[source.name] = source.export_user_data(user_id)
        except Exception as e:
            log_error(f"Export failed for {source.name}: {e}")
            alert_operations(request_id, source.name)

    generate_export_file(export_data, request_id)
    notify_user(user_id, request_id)

Build automation from the start.

Data Discovery Continues

We thought we mapped all personal data. We were wrong:

Data mapping is ongoing, not a one-time exercise.

Deletion Is Complex

“Delete my data” sounds simple. In practice:

Our deletion pipeline handles over 15 systems.

Testing Data Subject Requests

We didn’t test enough scenarios:

Test the full flow, including failure modes.

Process Improvements Made

Data Subject Request Tracking

We built a tracking system:

class DataSubjectRequest:
    id: str
    user_id: str
    request_type: str  # access, erasure, rectification
    status: str  # received, processing, completed, failed
    received_at: datetime
    deadline: datetime  # 30 days from receipt
    completed_at: Optional[datetime]
    audit_log: List[AuditEntry]

Tracking ensures we meet the 30-day deadline.

Consent signals now flow to all systems:

User withdraws marketing consent →
Consent service updates →
Event published →
Email service stops marketing emails →
CRM updates preferences →
Analytics stops marketing-related tracking →
Audit log records change

Consent changes propagate immediately.

Privacy Impact Assessment Process

New features go through privacy review:

  1. Data inventory: What personal data is processed?
  2. Purpose: What’s the lawful basis?
  3. Retention: How long is data kept?
  4. Security: What protections are in place?
  5. Third parties: Who receives data?
  6. User rights: How are rights supported?

This catches privacy issues before they ship.

Industry Observations

Enforcement Uncertainty

Three days post-deadline, no major enforcement actions yet. But:

Regulatory interpretation will evolve.

US Companies Reacting

Many US companies are applying GDPR principles globally:

GDPR is becoming a de facto global standard.

Cookie consent implementations vary wildly:

This area needs industry standardization.

Data Breaches Now Higher Stakes

GDPR’s breach notification and penalty provisions change the calculus:

Security investment is increasing.

What We’re Doing Next

Continuous Improvement

GDPR compliance is ongoing:

Preparing for Enforcement

When enforcement actions start:

Extending Privacy Program

Privacy beyond GDPR:

Build a flexible privacy program, not GDPR-specific compliance.

Key Takeaways

The enforcement deadline was a milestone, not an end. Ongoing privacy work continues.