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GDPR compliance requires an organization to understand and justify how it processes personal data, protect that data, respect individuals’ rights, and be able to demonstrate that it is meeting its obligations. OneTrust and TrustArc describe software workflows that can support parts of this work, but neither platform by itself establishes legal compliance. The right choice depends on your processing, existing systems, governance and implementation needs.
What are the GDPR requirements?
The General Data Protection Regulation (GDPR), Regulation (EU) 2016/679, sets obligations for organizations according to their role and the processing they perform. A privacy-management program should translate those obligations into assigned, documented work—not treat compliance as a software installation or a completed checklist.
Apply the seven data-protection principles
Article 5 requires personal data to be processed according to these principles:
- Lawfulness, fairness and transparency: process data on a valid basis, in a fair way, and communicate about it clearly.
- Purpose limitation: collect data for specified, explicit and legitimate purposes, and assess whether later use is compatible with them.
- Data minimisation: limit collection to what is necessary for the stated purposes.
- Accuracy: keep personal data accurate and, where necessary, up to date.
- Storage limitation: retain identifiable data no longer than necessary for its purposes, subject to applicable requirements.
- Integrity and confidentiality: use appropriate safeguards against unauthorised or unlawful processing, accidental loss, destruction or damage.
- Accountability: take responsibility for compliance and be able to demonstrate it.
Accountability is not a separate document or a vendor-generated report. It depends on whether the underlying decisions, controls and records reflect what the organization actually does.
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For each relevant processing activity, an organization needs to understand what personal data it handles, whose data it is, why it is used, where it goes, who can access it and how long it is kept. Article 6 sets out lawful bases for processing, including consent, contract, legal obligation, vital interests, public task and legitimate interests. The appropriate basis depends on the specific purpose and circumstances; it should not be selected merely because a platform offers a field for it.
Responsibilities vary with context and role. Controllers determine purposes and means of processing; processors handle data on a controller’s behalf and have their own obligations. An organization may act in different roles for different activities. Check the GDPR’s territorial scope and the duties applicable to each role and activity before drawing a legal conclusion.
Provide clear information and handle rights requests
People must receive required privacy information, subject to the GDPR’s provisions and exceptions. The European Commission describes that information as needing to be concise, transparent, intelligible and accessible, with clear and plain language. Article 12 also governs communication with individuals and the handling of rights requests.
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Operationally, a program needs a way to receive and route requests, verify identity where appropriate, locate relevant data, coordinate decisions, respond within applicable requirements and retain evidence of what was done. Relevant rights include access, rectification, erasure, restriction of processing, data portability and objection; individuals also have protections relating to certain solely automated decisions, including profiling. The applicable right and response depend on the circumstances and GDPR conditions.
Keep records, assess risk and protect data
Article 30 addresses records of processing activities (RoPA). Those records should reflect actual processing and the applicable requirements; generating a template or inventory in a tool does not by itself make a record complete or accurate.
Organizations also need appropriate technical and organizational security measures under Article 32. Articles 33 and 34 address personal-data-breach notification to supervisory authorities and communication to affected individuals in specified circumstances. For example, a controller generally must notify the supervisory authority without undue delay and, where feasible, within 72 hours after becoming aware of a breach unless it is unlikely to result in a risk to individuals’ rights and freedoms. Communication to affected individuals is required without undue delay when the breach is likely to result in a high risk, subject to the regulation’s conditions and exceptions.
Article 35 requires a data protection impact assessment (DPIA) before processing likely to result in a high risk to individuals’ rights and freedoms. A DPIA is a substantive assessment of the processing and its risks and safeguards, not simply a questionnaire marked complete. Applicability, required content and any further steps depend on the facts.
How do OneTrust and TrustArc describe their GDPR workflows?
The following comparison summarizes each provider’s own public product descriptions. These are vendor claims, not independent verification of implementation, accuracy, usability or outcomes. The cited pages do not establish a controlled feature comparison.
| Workflow area | OneTrust describes | TrustArc describes |
|---|---|---|
| Readiness and remediation | GDPR readiness assessments and remediation plans. | A risk profile that reviews variables and recommends assessments. |
| Inventory and processing records | A processing inventory and live Record of Processing Activities. | Data Mapping & Risk Manager for recording personal-data processing; inventories and data-flow maps. |
| Privacy and impact assessments | Automated DPIA and PIA workflows. | Privacy assessments, including PIAs, DPIAs and vendor risk assessments. |
| Consent | Consent management. | Consent preferences. |
| Individual rights | Data-subject request fulfillment. | Individual Rights Manager workflows and data-subject requests. |
OneTrust: described capabilities
OneTrust presents its GDPR offering as a set of workflows for readiness, assessment and remediation, DPIAs and PIAs, processing inventories and RoPA, consent management, and data-subject request fulfillment. It frames these capabilities as support for an ongoing accountability program. The descriptions do not, on their own, show how accurately a particular organization’s records will be populated or maintained.
OneTrust also publishes a customer testimonial from Daniele Bianchi, DPO at EOLO, describing the ability to use questionnaires across departments as a reason for choosing the platform. That is a vendor-hosted testimonial, not independent comparative evidence.
TrustArc: described capabilities
TrustArc describes Data Mapping & Risk Manager for recording personal-data processing, a risk profile that reviews variables and recommends assessments, and Individual Rights Manager workflows. Its GDPR solutions material also describes inventories and data-flow maps, privacy assessments that include PIAs, DPIAs and vendor risk, consent preferences, and data-subject requests.
TrustArc’s GDPR explanations and handbook are vendor educational materials. They can help orient a reader, but the regulation—not a vendor’s summary—is the controlling legal source.
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Which platform fits your GDPR program?
The available public descriptions support a workflow comparison, not an overall winner. Neither establishes comparable current pricing, independent implementation outcomes or product performance. Evaluate both against the same realistic scenarios and the controls your organization must operate.
Use a like-for-like evaluation
- Test inventory and data discovery. Show how each product captures processing across your systems, links data flows to owners and purposes, and keeps records current when systems or activities change.
- Inspect RoPA evidence. Verify which required details can be recorded, how entries trace back to source information and process owners, and whether records can be reviewed and exported for audit needs.
- Walk through a DPIA or PIA. Use a real or representative high-risk scenario. Check initiation criteria, risk review, safeguards, approvals, reassessment, and evidence retention—not just the questionnaire interface.
- Simulate a rights request. Follow intake, identity checks, routing to relevant teams, locating data, deadline tracking, decision-making and closure evidence. Confirm how exceptions and complex requests are handled.
- Check consent operations where relevant. Demonstrate how preferences are captured and how changes reach downstream systems that rely on them. Establish which integrations and organizational processes are needed.
- Assess processor and vendor oversight. Test how assessments are assigned, reviewed, escalated and linked to processing activities, contracts or remediation work.
- Map implementation and ownership. Ask what integrations, data cleanup, configuration, training and ongoing administration your deployment would require, and who in your organization owns each task.
- Compare cost and operating terms. Request comparable proposals for your scale and intended scope. Validate support, deployment requirements, reporting, data governance and total cost rather than comparing headline descriptions alone.
Decide based on operational fit
Build a short scorecard around your highest-risk and highest-volume processes, then ask both vendors to demonstrate the same scenarios using the same success criteria. Include the people who will maintain the inventory, assess risks, respond to individuals and review evidence. A platform that appears broad on a product page may still require substantial integration, governance and process work to fit your environment.
Before selecting either product, confirm current scope and terms directly with the provider. Product capabilities and availability can change, and a demonstration should establish what is included for your proposed deployment rather than relying on a general GDPR overview.
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