GDPR: The Alphabet Soup
I’m building a privacy compliance register for my clients and I almost forgot how the GDPR is built on all these acronyms that the EU expects most people to understand.
Here’s a real sentence from compliance documentation:
“If you transfer data outside the EU/EEA without an adequacy decision, you may need a TIA, and a separate DPIA where the processing is high risk and a LIA if the processing is based on legitimate interest, while your TOMs are set out in the DPA or SCC annexes, and finally recording all processing activities in the ROPA with the help of your DPO.”
If you needed to read that twice, that’s normal for EU compliance.
Actually, if you needed to read it three times and still aren’t entirely sure what half of it means, you’re in good company. Most business owners, founders, and even legal professionals who don’t specialize in privacy law find GDPR documentation borderline incomprehensible.
The Acronym Problem
The issue isn’t that GDPR compliance is conceptually impossible. The issue is that the entire regulatory framework has been built on the assumption that everyone already speaks fluent privacy law and understands what TIA, DPIA, LIA, TOMs, DPA, SCC, ROPA, and DPO mean.
They don’t.
Here’s what those acronyms actually mean in plain language:
TIA (Transfer Impact Assessment): An analysis you need to do before sending personal data outside the EU to countries that don’t have an adequacy decision. You’re evaluating whether the destination country has adequate data protection laws and whether additional safeguards are needed.
DPIA (Data Protection Impact Assessment): A risk assessment required when your data processing is likely to result in high risk to people’s rights and freedoms. Things like large-scale processing of sensitive data, systematic monitoring, or automated decision-making that significantly affects people.
LIA (Legitimate Interest Assessment): A balancing test you perform when you’re relying on “legitimate interest” as your legal basis for processing data. You’re documenting why your interest in processing the data outweighs the person’s right to privacy.
TOMs (Technical and Organisational Measures): The security measures and processes you’ve implemented to protect personal data. Things like encryption, access controls, employee training, incident response procedures.
DPA (Data Processing Agreement): The contract between you and your service providers that sets out what they can and can’t do with the data you share with them. Required whenever you use a processor (someone who handles data on your behalf).
SCC (Standard Contractual Clauses): Pre-approved contract templates from the European Commission that you use when transferring data internationally. They’re designed to provide adequate safeguards even when sending data to countries without strong privacy laws.
ROPA (Record of Processing Activities): A registry documenting all the ways you process personal data—what data you collect, why you collect it, who you share it with, how long you keep it, what security measures you’ve implemented.
DPO (Data Protection Officer): The person responsible for overseeing GDPR compliance in your organization. Required in certain cases, like if you’re a public authority or if you do large-scale systematic monitoring or processing of sensitive data.
The Real Problem
But here’s the thing: even once you know what the acronyms mean, you still need to understand how they fit together, when they’re required, and how to actually implement them.
The GDPR doesn’t just ask you to tick boxes. It asks you to conduct meaningful assessments, implement appropriate safeguards, document your decision-making, and continuously monitor your compliance. All while running your actual business.
Most companies—especially small and medium-sized businesses—don’t have the resources for a full-time DPO or a dedicated privacy team. They’re trying to figure this out while also dealing with sales, operations, product development, customer service, and everything else that keeps a business running.
So what happens in practice? One of three things:
Option 1: They ignore it and hope they don’t get caught. Risky, especially as enforcement is increasing.
Option 2: They hire an expensive consultant who produces a 50-page compliance manual full of the same acronyms, which sits on a shelf and never gets implemented because nobody understands it.
Option 3: They try to do it themselves, get overwhelmed, implement something half-assed, and end up with a compliance program that looks good on paper but doesn’t actually work in practice.
None of these are great outcomes.
Making It Practical
The GDPR is actually built on reasonable principles: be transparent about what you’re doing with people’s data, give them control over it, protect it properly, and be accountable for your decisions.
The problem is the implementation. The documentation requirements. The acronyms. The assumption that everyone has a legal team that can translate regulatory language into operational reality.
What businesses actually need is practical guidance that explains not just what they need to do, but how to do it in a way that makes sense for their specific situation. They need someone who can translate “you need a TIA for international data transfers” into “here’s the three-page assessment template, here’s how to fill it out, here’s when you need it, and here’s what to do with it once you’ve completed it.”
They need compliance programs that are proportionate to their actual risk, not cookie-cutter solutions that assume every company is processing millions of records of sensitive data.
They need documentation that their actual employees can understand and use, not legal boilerplate that checks compliance boxes but provides zero practical value.
My Approach
This is why when I build privacy compliance registers for clients, I focus on making them actually usable. That means:
Clear language instead of acronyms (or at least, clear explanations when acronyms are unavoidable). Practical templates that can actually be filled out without a law degree. Guidance that’s tailored to what the company actually does, not generic best practices. Documentation that employees can reference when they need to make real decisions about real situations.
Because compliance isn’t about producing the most technically perfect documentation. It’s about creating systems and processes that actually protect people’s data while allowing the business to function effectively.
The GDPR is here to stay. The acronyms probably are too. But that doesn’t mean compliance has to be incomprehensible.
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