How to Choose the Right Data Protection Audit Method: 10 Key Questions

A data protection audit ensures that your company complies with the legal requirements of the GDPR and other regulations. Different audit methods are suitable depending on your objectives. The following 10 questions will help you decide whether to conduct the audit via questionnaire or interview.

Use these 10 questions to find the right data protection audit method.
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Audit via interview vs. self-assessment questionnaire: How the audit methods differ

To choose a suitable audit method, you should prepare the process thoroughly. To do so, start by defining the objective and determining the scope of the audit: Which processes do you want to examine? And which departments need to be reviewed? Most importantly, you need to determine the audit method. Which one is best suited depends on various factors. The following 10 questions will help you find the right method for your data protection audit.

  1. How high is data protection awareness in your company?

    If data protection awareness in your company is relatively low, you should choose the interview audit method. This approach allows you to guide respondents more closely and answer their questions on the spot. Are there comprehension issues due to unfamiliar technica terms? Or does an employee need additional background information to answer a question? During the interview, you can clear up any ambiguities, provide necessary additional information, and thus lay the groundwork for receiving high-quality answers.

    Furthermore, as the interviewer, you can determine during the conversation with employees which areas to focus on and where to ask follow-up questions. This allows you to identify key processes that are relevant to the audit from a data protection perspective.

  2. How high is the level of digital literacy in your company?

    Low digital literacy among employees in your company is another reason to conduct the audit via interviews. This allows respondents to focus entirely on their answers, and you can provide guidance on key points and answer follow-up questions. This is particularly important if employees are not trained to assess technical risks. For this reason, internal auditors themselves should possess a high level of digital literacy. This enables them to provide optimal support to respondents in terms of both content and method.

  3. Do you want to ask critical follow-up questions and dive deeper into the subject?

    The interview process allows for critical follow-up questions and iterative discussions where a topic is examined from multiple angles. This is one of the key advantages over a data protection audit using a self-assessment questionnaire. If your goal for the GDPR audit is a true deep dive rather than merely gaining a general impression, the interview is the most suitable audit method.

  4. Should a large number of people and departments be surveyed?

    An audit using a self-assessment questionnaire is particularly well-suited for surveying a large number of employees. When creating the audit questionnaire, it doesn’t matter how many people it’s sent to. The number of people audited only becomes relevant for the evaluation of all responses. If you use a digital tool with automated evaluations, this factor is handled automatically.

    Interviews, on the other hand, involve greater effort, primarily because they must be scheduled and conducted individually. Therefore, they are better suited for in-depth audits with a small number of people than for large-scale surveys.

  5. Would you like to collect comparable data that you can analyze systematically?

    An interview allows you to deep dive into details through spontaneous follow-up questions. However, this can cause individual conversations to unfold differently, which undermines the comparability of the responses. In contrast, the structured format of a self-assessment questionnaire makes it particularly useful for systematic analysis. Especially when you work with standardized questions and a digital tool, analyzing a data protection audit using a questionnaire becomes relatively easy.

  6. How willing are employees to implement measures for a higher level of data protection?

    If employees’ willingness to implement additional measures for a higher level of data protection in your company is rather low, a self-assessment questionnaire is not the method of choice for the audit: With a questionnaire, it is easier to answer questions superficially or evasively. Therefore, first obtain an overview of the level of acceptance for data protection before deciding on one of the two audit methods. Committed employees can provide high-quality answers that meet your standards even when using a written questionnaire.

    If data protection is not well established in your company, it is worth first conveying its importance in a different format. This can be done through a presentation or in an open forum.

  7. Would you like to get an immediate snapshot of processes within the company?

    The best way to get an immediate snapshot is to interview employees. That way, they’ll answer your questions directly and intuitively. However, if you present them with a questionnaire, they have more time to think of answers they believe to be correct or appropriate. There is a risk that these answers will reflect the target practice they are aiming for rather than the reality of day-to-day business. Additionally, employees have the opportunity and time to coordinate their responses with one another, which could skew the results, even if this is not done intentionally.

  8. How much time and resources can you allocate?

    An interview-based data protection audit requires more resources than one conducted via a self-assessment questionnaire. Scheduling appointments, conducting the interviews, and especially analyzing the results take more time when the audit is carried out through face-to-face interviews. Therefore, before deciding on one of the two audit methods, determine how much time and resources you can and are willing to allocate.

  9. Are there serious conflicts that require the respondents to remain anonymous?

    In some cases, there are major conflicts within a company regarding data protection issues. To get to the root of the problem, you should proceed with caution during your audit. Anonymizing the responses can sometimes help elicit particularly honest answers. This gives employees the opportunity to point out data privacy violations by certain departments without having to worry about their position within the company. This protection of their identity is only possible with a data protection audit conducted via self-assessment questionnaire.

  10. Do you want to build a personal relationship of trust with the respondents?

    Especially when restructuring and changes in the process landscape are expected, it is often helpful to build a trusting relationship with the affected employees. An interview is well-suited for this, as it allows you to speak face-to-face with the individuals and foster a sense of rapport.

Good to know:
It makes a difference whether you are examining the current state or the target state in your company. When auditing the current state, it might be helpful to review tools and IT systems together with the responsible departments. In that case, direct communication and a coordinated process are essential.

The right audit method for your goals

The 10 questions listed above will help you find the right audit method for your company. Keep in mind that a combination of both approaches is also feasible. For example, you can first use a questionnaire to gain a general overview and identify any areas of concern, which you can then examine in more detail through interviews. Which audit method you choose depends on your employees and the available resources. To learn what else you need to consider besides the appropriate audit method, read our comprehensive article on data protection audits. It is important not to lose sight of the goal: optimizing processes in accordance with data protection laws and thereby developing your organization.

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Article written by

Dennis Kurpierz Co-Founder & COO

Dennis Kurpierz is co-founder and Chief Operating Officer of caralegal. Thanks to his many years of experience as a senior consultant and lead project manager at ISiCO Datenschutz GmbH, he is familiar with customer needs, pain points, and challenges in data protection management. As product owner, he applies this expertise to product development at caralegal.

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