Which KPIs for Data Protection?

People are familiar with KPIs when it comes to sales, production, or customer service, to name some examples. However, it is not uncommon for some processes to lack clear KPIs or to have none at all.

Data protection is often considered a set of best practices integrated into every business process. However, because the GDPR requires a specific setup, including at least one dedicated Data Protection Officer (DPO) role, it becomes relevant to consider data protection as a distinct process within your organization’s process mapping.

Like every process, you should define a few things such as the resources needed, the inputs, the outputs, the KPIs, etc. In fact, if we refer to ISO 9001, you should define, among other things, clear KPIs for each process.

So, what should you do? A suggestion could be to consider the different requirements listed in the GDPR and translate them into KPIs. Depending on the level of granularity you want to achieve, these could include, among others:

• Average response delay to data subjects' requests: reflects the ability to meet the GDPR requirement of responding within 30 days.

• Comprehensiveness level of your data register: reflects the ability to monitor data protection comprehensively.

• DPIAs completion: reflects the organization's proactive stance on data protection.

• Remediation backlog resolution: track the progress of addressing identified risks, ensuring continuous improvement.

• Awareness level among employees: assessed based on participation in training sessions and engagement with insights shared through newsletters, for example.

KPIs based on variables that are not directly manageable by the DPO are good indicators for higher management but may not serve as effective performance indicators. Examples include: risk exposure or data protection contract compliance.

It is crucial not to underestimate the importance of correctly defining KPIs. For instance, if you are reporting the level of comprehensiveness of your data register, you should be able to compare the actual situation against the objective in terms of mapping. If the objective is not clearly defined or measurable, the added value of this KPI will be minimal or nonexistent.

In summary, defining clear and actionable KPIs for data protection not only helps in complying with GDPR but also enhances the overall effectiveness and accountability of your data protection efforts. Eventually, use dedicated tools such as dpO to help you with this task.