Checklist · Updated 23 October 2026

Privacy throughout the customer journey.

Examine how customer data is collected, used and passed through your systems. Use this checklist to identify questions and assign someone to resolve them.

Use the template
Privacy in practiceWho needs
to know what?

Purpose. Access. Retention.

Good procedures start with a clear overview.Follow information through the customer journey.
What you take away

A list of questions to resolve, documentation and responsible people.

People to involve

The process owner, system administrator and privacy expertise where needed.

See it in practiceFrom a situation to a next step

Illustrative example · not a client case

A form sends information to email, a CRM and a spreadsheet. Nobody has a complete overview of who uses these copies.

  1. Investigate

    Draw the actual data flow. Examine the purpose of each copy, access permissions, suppliers and how long the information is retained.

  2. Try

    Assign an owner to each unresolved processing question. Document the assessments and update procedures and information to match the actual setup.

  3. Follow up

    Do you know where the data is, why it is there and who handles access, rights and deletion?

01 / 06

Purpose and lawful basis

Describe which personal data you process, why and on which lawful basis. Assess each purpose before collection begins. Responding to an enquiry and sending later marketing are different purposes.

What we have checked

Norwegian Data Protection Authority: Lawful basis

02 / 06

Clear information

Explain what happens to personal data where the customer needs that information. The notice must match the actual setup: purposes, controller, recipients, storage and rights. An old standard document may describe tools you no longer use.

What we have checked

Norwegian Data Protection Authority: Information and transparency

03 / 06

Consent for tracking

Map cookies and other technologies that store or access information on a device. Where consent is required, obtain it before using the technology. Assess any strictly necessary exemption specifically. Saying no should be as easy as saying yes, and withdrawing consent should be easy.

What we have checked

Norwegian Data Protection Authority: Cookies and consent

04 / 06

Suppliers and data flows

Find out who processes information on your behalf and arrange the necessary data processing agreements. Check subprocessors, storage locations and possible access from outside the EEA. A European server location alone does not resolve the entire transfer question.

What we have checked

Norwegian Data Protection Authority: Data processing agreements

05 / 06

Access and security

Grant access according to need and review it when roles or staff change. Assess risks, account protection, backups and procedures for errors or incidents. Check that integrations do not provide broader access than the task requires.

What we have checked

Norwegian Data Protection Authority: Information security

06 / 06

Retention, deletion and rights

Determine how long the information is needed and clarify any duty to retain records. Test correction, access and deletion across systems. Deleting data from the CRM does not automatically remove copies in other tools.

What we have checked

Norwegian Data Protection Authority: Correction and deletion

See also Norwegian guidance on transfers outside the EEA and the overview of business obligations.

Agree on a commitment.

One practical improvement is a good place to start. Agree on who will take it forward and when you will review whether it works. The plan is included when you download your notes.

Let’s talk

The Færder guide

Two quick choices. A practical starting point.

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