GDPR is live. It went into effect on May 25th, and we’ve been running under it at the fintech startup for three days now. I want to write this down while it’s fresh, because I suspect the lessons from this first week will be the ones that actually stick.
The Lead-Up Was Worse Than Go-Live
Here’s something nobody warned me about: the last two weeks before GDPR were more painful than enforcement day itself. We’d been working on compliance for months – data mapping, consent flows, vendor contracts, the whole thing. But the final stretch still felt like a sprint.
The reason? Every team kept finding one more thing. Engineering found personal data in log files we hadn’t inventoried. Legal flagged a sub-processor we’d missed. Product realized our consent screen needed another iteration because the wording was ambiguous.
We got through it. But the idea that you can start a GDPR project three months out and finish cleanly? Naive. We started earlier than most and still felt the pressure.
Consent Fatigue Is Already Real
The internet on May 26th was wild. Every website, every app, every newsletter – all hitting you with consent banners at once. I must have clicked through fifty of them in a single morning.
Most of them were terrible. Walls of legal text. Cookie dialogs that blocked the entire page with no obvious way to decline. “Accept all” in bright green, “manage preferences” in tiny gray text buried at the bottom. Some of these designs are going to get companies in trouble. They technically present a choice while practically eliminating it.
At the fintech startup, we spent real time on this. We went through multiple rounds of consent UX with legal, product, and engineering all in the room. It slowed us down. But I’d rather have a consent flow that actually respects the user than a pretty banner that’s going to attract regulator attention.
Data Subject Requests Hit Faster Than Expected
We got our first data access request on day one. Day one. I don’t know why I was surprised – people are curious, they want to test the system, and fintech users are particularly aware of their data rights.
The good news: our automated pipeline handled it. We’d built a workflow that could pull a user’s data from our main database, billing system, analytics, and support tickets, package it up, and generate an audit log. It wasn’t glamorous, but it worked.
The teams that didn’t automate this are in trouble. You have thirty days to respond to a request. That sounds generous until you realize deletion isn’t just flipping a switch. It’s a distributed operation across every service, cache, backup, and third-party integration that touched that user’s data. And you need to prove it happened while not retaining the personal data you just deleted. It’s a paradox that forces you to think carefully about your audit trail design.
The Vendor Problem
This one bit us. We had our own house mostly in order, but one of our analytics vendors was slow to update their data processing agreement. Another couldn’t clearly explain their data retention policies.
When your compliance depends on every processor in your stack, a single lagging vendor becomes your bottleneck. We ended up replacing one tool entirely because the vendor’s GDPR response was vague and their timeline kept slipping. Not ideal with a hard deadline.
Lesson learned: start vendor conversations early. Not “send them an email” early. “Get a meeting, get commitments in writing, have a backup plan” early.
What We Got Right
Cross-functional involvement from the start. This wasn’t an engineering project or a legal project. It was both, plus product, plus support. Every consent decision had technical implications. Every technical decision had legal implications. The teams that siloed this work are the ones scrambling now.
We also ran our data subject request pipeline end-to-end before enforcement day. Not just the happy path – we tested what happens when one service is down, when a user submits duplicate requests, when a deletion partially fails. Those failure modes are where the real risk lives.
What’s Next
Enforcement is just beginning. The first major fines and rulings will shape how aggressive regulators actually are. Some companies are applying GDPR principles globally rather than maintaining separate privacy regimes per region, which honestly makes sense. The overhead of regional exceptions isn’t worth it for most teams.
Cookie consent is still a mess industry-wide. Implementations are inconsistent and often hostile to users. I expect standards to emerge, but right now it’s the wild west.
GDPR isn’t a box you check and move on from. It’s an ongoing program. The data mapping we did? It needs to stay current as we ship new features. The consent flows? They’ll need updates as guidance evolves. The vendor contracts? They need periodic review.
Three days in and that’s already obvious. This is the new normal.