GDPR consulting for asset managers and fund management companies
Art.
Without a complete data inventory, asset managers cannot fulfil data subject rights under Art. 15-22 GDPR within required timeframes or report data breaches within 72 hours. Records of processing activities under Art. 30 document all processing activities — from client master data and transaction histories to risk profiles. They form the foundation for retention policies, data protection impact assessments and cooperation with the data protection officer.
6 service modules
Bookable individually or as an end-to-end programme.
Systematic identification of all personal data assets in your organisation. We map data sources, processing purposes, legal bases and storage locations — as the foundation for records of processing activities and retention policies.
Creation and maintenance of records of processing activities as required by Art. 30 GDPR. Documentation of all processing activities including purpose, legal basis, recipient categories, retention periods and technical-organisational measures.
Design and implementation of TOMs under Art. 32 GDPR: encryption, access controls, pseudonymisation, backup strategies and incident response processes — aligned with financial industry requirements.
Development of industry-specific retention policies balancing GDPR storage limitation with regulatory retention obligations (e.g. MiFID, national commercial codes). Definition of deletion rules, deletion protocols and automated deletion routines.
Conducting data protection impact assessments under Art. 35 GDPR for high-risk processing in asset management — such as automated investment decisions, profiling or cross-border data transfers.
Implementation of efficient processes for access, rectification, erasure and portability requests under Art. 15-20 GDPR. Setup of internal workflows with defined timelines, responsibilities and documentation.
5 phases
From initial assessment to audit-ready documentation, we support asset managers, fund management companies and investment firms in achieving full GDPR compliance.
identification of all IT systems, data flows and processors
classification of personal data by category, legal basis and retention period
creation under Art. 30 GDPR with all mandatory information
technical and organisational measures under Art. 32 GDPR
reconciliation of GDPR deletion requirements with regulatory retention periods
Your contact
Sarah Richter
Head of Information Security, Cyber Security
10+ years of experience, CISA, CISM, Lead Auditor, DORA, NIS2, BCM, Cyber and Information Security
Strategic GDPR asset management excellence is the foundation for future-proof data asset governance, combining comprehensive asset transparency with operational compliance innovation. Modern asset management frameworks not only create regulatory security but also enable strategic data asset optimization, operational synergies, and sustainable competitive differentiation. Our integrated asset governance approaches transform complex compliance challenges into strategic business enablers that ensure long-term business success and operational excellence.
7 QUESTIONS, BRIEFLY ANSWERED
Records of processing activities (RoPA) are a mandatory documentation requirement under Art. 30 GDPR. They list all processing activities involving personal data, the respective purpose, legal basis, recipient categories, retention periods and a description of technical-organisational measures. For asset managers and fund management companies, RoPA forms the basis of any data protection audit by supervisory authorities.
Asset managers typically process client master data, financial data, risk profiles, transaction histories, identity verification documents and communication records. All these categories must be captured in the data inventory — including storage location, access permissions, legal basis and retention period. Data of employees, business partners and service providers must also be included.
Art. 32 GDPR requires technical and organisational measures appropriate to the risk. For financial services firms, this includes: encryption of data at rest and in transit, role-based access control systems, pseudonymisation of sensitive data, regular security assessments, backup and recovery procedures, and documented incident response processes.
A data protection impact assessment under Art. 35 GDPR is required when processing is likely to result in a high risk to data subjects. In asset management, this particularly applies to automated investment decisions, client scoring and profiling, systematic monitoring of large datasets, and cross-border data transfers to third countries.
A retention policy defines when which data must be deleted. The challenge in financial services: regulatory retention obligations (e.g. 10 years under commercial law, 5 years under MiFID) often override the GDPR deletion requirement. The policy must address both — with clear deletion rules per data category, automated deletion routines and documented reviews after retention periods expire.
In the event of a personal data breach, the controller must notify the competent supervisory authority within 72 hours (Art. 33 GDPR). Data subjects must be informed where there is a high risk (Art. 34). Fines can reach up to EUR 20 million or 4% of global annual turnover. A documented incident response process is therefore essential for asset managers.
ADVISORI supports asset managers, fund management companies and investment firms from initial assessment to audit-ready documentation. We create data inventories, records of processing activities, retention policies and TOM documentation. Our consultants understand the industry-specific requirements from financial regulation and connect data protection with existing compliance structures.
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