UK GDPR: Controller due diligence and audit checklist for new and existing personal data processors

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Checklists

This Checklist outlines the main factors a controller would ordinarily consider when undertaking an audit with a view to assessing whether a potential or current processor of personal data is suitable under the United Kingdom General Data Protection Regulation, Assimilated Regulation (EU) 2016/679 (UK GDPR). For more detail about controllers’ obligations and engaging processors within the UK GDPR regime, see the following Practice Notes:

The UK General Data Protection Regulation (UK GDPR)
Key definitions under UK data protection law
Supply chains under data protection law—arrangements between controllers and processors

Audits of processors

Although processors subject to the UK GDPR have distinct duties under the legislation, controllers remain accountable for a processor’s handling of personal data carried out under their instructions and on their behalf. Under the accountability principle of the UK GDPR, the controller is responsible for, and must be able to demonstrate, compliance with the data protection principles in Article 5(1) UK GDPR—which include lawfulness, fairness and transparency; purpose limitation; data minimisation; accuracy; storage limitation; and integrity and confidentiality—in relation to its processing, including processing undertaken on its behalf by processors...

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Web page updated on 20/05/2026

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