GDPR consulting for asset managers and fund management companies
GDPR Asset Management
Art. 30 GDPR requires asset managers and fund management companies to document all processing activities involving personal data without gaps. A structured data inventory forms the foundation for records of processing activities, retention policies and the implementation of data subject rights. We support financial services firms from initial assessment through the creation of records of processing activities to audit-ready documentation of technical and organisational measures.
- ✓Complete data inventory of all personal data in the financial sector
- ✓Records of processing activities under Art. 30 GDPR with retention periods and legal bases
- ✓Technical and organisational measures (TOMs) under Art. 32 GDPR
- ✓Retention policy reconciling regulatory obligations (MiFID, commercial law) with GDPR deletion requirements
Your strategic success starts here
Our clients trust our expertise in digital transformation, compliance, and risk management
30 Minutes • Non-binding • Immediately available
For optimal preparation of your strategy session:
- Your strategic goals and objectives
- Desired business outcomes and ROI
- Steps already taken
Or contact us directly:
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Why asset managers need a structured data inventory
⚠
Fines up to EUR 20 million for inadequate documentation
Incomplete records of processing activities breach Art. 30 GDPR. Fines can reach EUR 10 million or 2% of global annual turnover. For breaches of data subject rights or breach notification obligations, penalties can reach EUR 20 million or 4% of turnover.
ADVISORI in Numbers
11+
Years of Experience
120+
Employees
520+
Projects
From initial assessment to audit-ready documentation, we support asset managers, fund management companies and investment firms in achieving full GDPR compliance.
Our Approach:
Assessment: identification of all IT systems, data flows and processors
Data inventory: classification of personal data by category, legal basis and retention period
Records of processing: creation under Art. 30 GDPR with all mandatory information
TOM documentation: technical and organisational measures under Art. 32 GDPR
Retention policy: reconciliation of GDPR deletion requirements with regulatory retention periods
"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."
Sarah Richter
Head of Information Security, Cyber Security
Expertise & Experience:
10+ years of experience, CISA, CISM, Lead Auditor, DORA, NIS2, BCM, Cyber and Information Security
Our Services
We offer you tailored solutions for your digital transformation
Data Inventory and Data Classification
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.
Records of Processing Activities (Art. 30 GDPR)
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.
Technical and Organisational Measures (TOMs)
Design and implementation of TOMs under Art. 32 GDPR: encryption, access controls, pseudonymisation, backup strategies and incident response processes — aligned with financial industry requirements.
Retention Policies and Deletion Concepts
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.
Data Protection Impact Assessment (DPIA)
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.
Data Subject Rights and Request Handling
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.
Our Competencies in DSGVO
Choose the area that fits your requirements
GDPR AI Compliance
The General Data Protection Regulation places complex requirements on AI systems through privacy-by-design principles, automated decision-making compliance, transparency obligations and algorithmic accountability for secure AI data processing. Successful GDPR AI compliance management goes beyond traditional data protection approaches and creates integrated AI governance systems that smoothly connect AI innovation, regulatory compliance and operational efficiency. We develop tailored AI compliance frameworks that not only meet regulatory requirements, but also unlock strategic AI business opportunities, minimise risks and establish sustainable competitive advantages through superior AI governance and AI data protection excellence.
GDPR Banking Sector
The General Data Protection Regulation presents banks and financial service providers with unique challenges due to complex customer data processing, cross-border data transfers, and strict regulatory requirements. Successful GDPR compliance in the banking sector requires more than standardized data protection approaches — it requires specialized banking expertise that smoothly connects data protection law with financial regulation. We develop tailored GDPR banking frameworks that not only ensure legal compliance but also increase operational efficiency, strengthen customer trust, and establish sustainable competitive advantages through superior data protection governance in the financial sector.
GDPR Cloud Computing
The General Data Protection Regulation places complex requirements on cloud computing environments through cross-border data transfer compliance, cloud provider due diligence, data residency requirements and multi-cloud governance structures for secure cloud data processing. Successful GDPR cloud computing management goes beyond traditional data protection approaches and creates integrated cloud governance systems that smoothly connect cloud privacy, vendor management and operational efficiency. We develop tailored cloud compliance frameworks that not only meet regulatory requirements but also unlock strategic cloud business opportunities, minimise risks and establish sustainable competitive advantages through superior cloud governance and cloud data protection excellence.
GDPR Cross-Border Transfers
The General Data Protection Regulation places complex requirements on international data transfers through adequacy decisions, standard contractual clauses, and transfer impact assessments for secure cross-border data transmission. Successful cross-border transfer management goes beyond traditional compliance approaches and creates integrated governance systems that smoothly connect international data transfer security, regulatory compliance, and operational efficiency. We develop tailored transfer frameworks that not only meet regulatory requirements but also enable strategic international business opportunities, minimize risks, and establish sustainable competitive advantages through superior cross-border governance and international data protection excellence.
GDPR Data Breach Response
The General Data Protection Regulation places complex demands on data breach response management through time-critical notification compliance, comprehensive data subject rights fulfilment, regulatory authority communication and systematic post-breach recovery processes for sustainable data protection governance. Successful GDPR breach response management goes beyond traditional incident response approaches and creates integrated governance systems that smoothly connect breach prevention, rapid response and stakeholder communication. We develop tailored breach response frameworks that not only meet regulatory requirements but also enable strategic business continuity, minimise reputational risks and establish lasting competitive advantages through superior incident management governance and data protection excellence.
GDPR Implementation
The General Data Protection Regulation (GDPR) requires systematic and sustainable implementation. We support you in the complete fulfillment of all data protection requirements.
GDPR Insurance Sector
Insurance companies process particularly sensitive personal data — from health data and creditworthiness information to risk profiles. The GDPR therefore imposes stringent requirements on the insurance sector: legal bases under Art. 6 and Art. 9, consent management, data protection impact assessments for scoring and profiling, and deletion concepts that account for insurance-specific retention obligations. We advise insurers on the practical implementation of all GDPR obligations — legally compliant, efficient and aligned with industry-specific regulations such as codes of conduct under Art. 40 GDPR and national insurance supervision requirements.
GDPR Ongoing Compliance
Ensure continuous compliance with GDPR requirements through our comprehensive ongoing compliance approach. We establish data protection governance structures, automated monitoring mechanisms, and proactive adaptation processes that guarantee lasting compliance and sustainably minimize data protection risks.
GDPR Privacy by Design
The General Data Protection Regulation places complex demands on Privacy-by-Design implementation through proactive privacy protection, privacy-as-default settings, privacy-embedded design, and full-functionality privacy balance for sustainable data protection governance. Successful GDPR Privacy-by-Design management goes beyond traditional compliance approaches and creates integrated privacy systems that smoothly connect privacy engineering, data minimization, and user privacy rights. We develop tailored Privacy-by-Design frameworks that not only meet regulatory requirements but also enable strategic business innovation, minimize privacy risks, and establish sustainable competitive advantages through superior privacy governance and data protection excellence.
GDPR Readiness
A professional GDPR readiness assessment reveals where your organisation stands on data protection. We evaluate your current maturity level, uncover compliance gaps, and develop a prioritised roadmap to full GDPR conformity.
GDPR Vendor Management
GDPR Article 28 requires controllers to engage only processors that provide sufficient guarantees for appropriate technical and organisational measures. A legally sound data processing agreement (DPA) governs the subject matter, duration, purpose and security measures of data processing. ADVISORI supports you in selecting and assessing processors, drafting your DPA and establishing ongoing monitoring – practical, legally compliant and efficient.
Frequently Asked Questions about GDPR Asset Management
What are records of processing activities under Art. 30 GDPR?
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.
What data must asset managers include in a data inventory?
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.
What TOMs does the GDPR require from financial services firms?
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.
When is a DPIA required in asset management?
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.
How do you build a GDPR-compliant retention policy for financial services?
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.
What happens in a data breach in asset management?
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.
How does ADVISORI support GDPR implementation in asset management?
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.
Success Stories
Discover how we support companies in their digital transformation
Digitalization in Steel Trading
Klöckner & Co
Digital Transformation in Steel Trading
Case Study
Results
Over 2 billion euros in annual revenue through digital channels
Goal to achieve 60% of revenue online by 2022
Improved customer satisfaction through automated processes
AI-Powered Manufacturing Optimization
Siemens
Smart Manufacturing Solutions for Maximum Value Creation
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Results
Significant increase in production performance
Reduction of downtime and production costs
Improved sustainability through more efficient resource utilization
AI Automation in Production
Festo
Intelligent Networking for Future-Proof Production Systems
Case Study
Results
Improved production speed and flexibility
Reduced manufacturing costs through more efficient resource utilization
Increased customer satisfaction through personalized products
Generative AI in Manufacturing
Bosch
AI Process Optimization for Improved Production Efficiency
Case Study
Results
Reduction of AI application implementation time to just a few weeks
Improvement in product quality through early defect detection
Increased manufacturing efficiency through reduced downtime
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Work Together!
Is your organization ready for the next step into the digital future? Contact us for a personal consultation.
Your strategic success starts here
Our clients trust our expertise in digital transformation, compliance, and risk management
Ready for the next step?
Schedule a strategic consultation with our experts now
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