GDPR compliance is not optional for e-commerce websites in 2026: it is a legal obligation backed by fines of up to 20 million euros or 4% of annual global turnover (Article 83 GDPR). Yet a significant proportion of online stores still fall short of full compliance. The good news is that with a structured approach, achieving compliance is entirely feasible, even for small businesses. This guide provides a concrete 10-step action plan.
Why a structured action plan is essential
GDPR compliance is far more than publishing a privacy policy on your website. It involves a comprehensive approach covering data collection, storage, security, user rights and third-party relationships. Without a plan, businesses address these topics in a piecemeal fashion, leaving gaps that can prove costly during a regulatory audit.
A structured plan helps you prioritise actions, document your approach (which itself constitutes evidence of good faith), and ensure nothing is overlooked. It transforms what many perceive as an overwhelming obligation into a series of concrete, achievable tasks.
The 10 steps to GDPR compliance
Step 1: Map your data processing activities
The first step is to conduct a thorough inventory of all personal data your business collects. For an e-commerce site, this typically includes: order data (name, address, email, phone), payment data (handled by your payment processor), browsing data (cookies, IP addresses), customer account data, and marketing data (newsletter subscriptions, purchase history).
For each processing activity, identify: what data is collected, from whom, for what purpose, how long it is retained, and who has access. This mapping exercise forms the foundation of your entire compliance strategy.
Step 2: Identify the legal basis for each processing activity
The GDPR requires every data processing activity to rest on a valid legal basis (Article 6). The most common ones in e-commerce are:
- Contract: for data necessary to fulfil an order (name, delivery address, confirmation email).
- Consent: for non-essential cookies, newsletters, email marketing.
- Legitimate interest: for fraud prevention, anonymised statistics.
- Legal obligation: for invoice retention (tax requirements).
Each processing activity must be linked to a specific legal basis. Where consent is relied upon, it must be freely given, specific, informed and unambiguous.
Step 3: Draft or update your privacy policy
The privacy policy is the centrepiece of your GDPR compliance. Articles 13 and 14 of the GDPR list the mandatory information: identity of the data controller, purposes and legal bases, data recipients, retention periods, individuals’ rights, and DPO contact details where applicable.
This document must be written in clear, accessible language. Avoid unnecessary legal jargon. For a comprehensive guide on this topic, read our article on mandatory privacy policy requirements and fines.
Step 4: Implement a compliant cookie policy
Following regulatory guidance across Europe, the cookie banner has become an essential element of any website. Your site must inform users about the cookies used, obtain consent before deploying non-essential cookies, and allow users to refuse just as easily as they accept.
In practice, your banner should offer “Accept” and “Refuse” buttons of equal size and visibility. Analytics and advertising cookies must not be set before consent is given. For a complete guide, see our article on cookie policy rules and sanctions.
Step 5: Create your terms of use and terms of sale
Terms of Use and Terms of Sale are essential contractual documents for any e-commerce site. The Terms of Use govern how visitors interact with your site, while the Terms of Sale regulate the commercial relationship with your customers (pricing, delivery, returns, warranties).
These documents must be consistent with your privacy policy and cookie policy. For a full overview, see our guide on the 4 essential legal documents for every e-commerce website, and avoid common pitfalls with our article on terms of sale mistakes.
Step 6: Establish a record of processing activities
Article 30 of the GDPR requires maintaining a record of processing activities. This register documents all your data processing operations: purposes, categories of data and data subjects, recipients, transfers outside the EU, retention periods and security measures.
This record does not need to be complex. A well-structured spreadsheet can suffice for an SME. Many data protection authorities provide free templates. The key is to keep it up to date and available in case of an audit.
Step 7: Secure personal data
Article 32 of the GDPR requires appropriate technical and organisational measures to ensure data security. For an e-commerce site, this means at minimum:
- HTTPS encryption across the entire site (not just payment pages).
- Strong passwords for admin and customer accounts.
- Regular updates of your CMS, plugins and dependencies.
- Encrypted backups with a tested restoration plan.
- Access controls limited to those who genuinely need them.
Document your security measures: this documentation is invaluable in case of an audit or incident.
Step 8: Guarantee individuals’ rights
The GDPR grants individuals several rights over their data (Articles 15 to 22): right of access, rectification, erasure, portability, objection and restriction of processing. Your site must provide straightforward means for exercising these rights.
In practice, set up a dedicated email address (e.g. dpo@yoursite.com) or a specific contact form. You have one month to respond to any request. Train your team on handling these requests and document every response.
Step 9: Govern data transfers outside the EU
If you use services hosted outside the European Union (cloud hosting, analytics tools, email services), you must govern these transfers in accordance with Chapter V of the GDPR. The EU-US Data Privacy Framework facilitates transfers to certified US companies, but you must verify each provider’s certification status.
Identify all your sub-processors and their locations. For each transfer outside the EU, verify the existence of an adequacy decision, standard contractual clauses, or another valid transfer mechanism. Document these checks in your record of processing activities.
Step 10: Establish a data breach notification procedure
Article 33 of the GDPR requires notification of any data breach to the supervisory authority within 72 hours of becoming aware of it. If the breach poses a high risk to individuals, they must also be informed (Article 34).
Prepare an internal procedure: who should be alerted first, how to assess the severity of the incident, which form to use for the notification, and how to inform affected individuals. Not having a procedure in place is itself a failing that regulators can sanction.
How to accelerate your compliance
Faced with these 10 steps, several options are available:
Hire a specialised lawyer (500-2,000 euros): maximum customisation and strategic advice, but high cost and a timeline of several weeks. Suited to businesses with complex or sensitive data processing.
Do it yourself with free templates (0 euros): many templates are available online, but they are often outdated and generic, requiring several hours of adaptation. The risk of non-compliance remains high without legal expertise.
Use generic AI (0 euros + 150-300 euros for review): tools like ChatGPT can produce drafts, but each document must be generated separately, leading to inconsistencies. Professional review is essential.
Use specialised legal AI (€14.90-19.90): solutions like WebLegal.ai generate all your legal documents in under 10 minutes, with guaranteed consistency across privacy policy, cookies, terms of use and terms of sale. This option covers steps 3 to 5 of this action plan and suits 95% of e-commerce sites.
Conclusion
Achieving GDPR compliance for your e-commerce site is not a one-off project but an ongoing process. This 10-step plan gives you a clear framework to progress methodically, starting with your data audit and finishing with incident preparedness. Each step completed reduces your legal risk and strengthens customer trust. In 2026, compliance is no longer a competitive advantage — it is a prerequisite. Do not wait for a regulatory audit to take action.