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Data Privacy Assessment in Technical Due Diligence

Data privacy regulations have created new categories of M&A risk. Non-compliance can result in significant fines and operational restrictions.

Key Regulations

GDPR (EU)

  • Applies to EU residents' data regardless of company location
  • Fines up to 4% of global revenue
  • Right to erasure, portability, access
  • 72-hour breach notification

CCPA/CPRA (California)

  • Right to know, delete, opt-out
  • Applies to businesses meeting thresholds
  • Private right of action for breaches

Emerging Regulations

  • State-level US laws (Virginia, Colorado, etc.)
  • Sector-specific requirements
  • International data transfer restrictions

Assessment Framework

1. Data Inventory

  • What personal data is collected?
  • Where is it stored?
  • Who has access?
  • How long is it retained?

2. Legal Basis Review

  • Consent mechanisms
  • Legitimate interest assessments
  • Contract requirements
  • Legal obligations

3. Rights Fulfillment

  • Subject access request process
  • Deletion capabilities
  • Data portability
  • Opt-out mechanisms

4. Security Controls

  • Encryption practices
  • Access controls
  • Breach detection
  • Incident response
Key Takeaway: Privacy compliance isn't just legal risk—it affects product capabilities and go-to-market strategy. Understand the implications for the business model.

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