GDPR Quick-Start for Small Businesses (Under 250 Employees)

Small businesses with fewer than 250 employees have limited exemptions under GDPR but still face most obligations. This template focuses on the pragmatic minimum compliance set for SMEs — what you must do, in the right order, without unnecessary overhead.

Quick Answer

GDPR compliance for small businesses focuses on: a clear privacy notice, lawful bases, DPAs with cloud tools, a SAR process, and cookie consent. The sub-250 employee RoPA exemption reduces paperwork but best practice is to maintain one. ICO registration is mandatory for most UK businesses. The compliance overhead is manageable within a day's work.

Compliance Checklist (8 items)

Write a privacy notice for your website covering: what data you collect, why, for how long, who you share it with, and how to exercise rights
Identify the lawful basis for each type of personal data processing — legitimate interests covers most SME marketing and analytics
Sign a Data Processing Agreement (DPA) with every cloud tool that processes your customers' data: Google Workspace, Mailchimp, Stripe, etc.
Sub-250 employee exemption: you are not required to maintain a full Record of Processing Activities (RoPA) unless processing is habitual, high risk, or involves special category data — but it is best practice
Set up a simple SAR response process — a dedicated email address and calendar alert for the one-month deadline
Implement cookie consent if you use analytics or marketing cookies — do not use pre-ticked boxes
Check your email marketing list — do you have valid consent or can you rely on the soft opt-in?
Register with the ICO if you are UK-based (£40/yr for most small businesses)

Penalty if not compliant

ICO fines are proportionate to size but still material for SMEs: reprimands, enforcement notices, and fines. Publicly disclosed enforcement actions damage customer trust disproportionately for small businesses.

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