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Poland · Compliance

GDPR compliance in Poland

Achieve GDPR compliance in Poland with Sterling: 8,100+ client engagements in 60+ countries, 20+ years.

  • Compliance, end to end
  • Frankfurt office team
  • Effivity software included
  • Academy training included

Clients include

  • Allianz
  • Emirates Flight Catering
  • Etihad Rail
  • Haier
  • Whirlpool
  • Emerson
In short

GDPR compliance in Poland at a glance

Regulation (EU) 2016/679 (GDPR / RODO) with the Ustawa z dnia 10 maja 2018 r. o ochronie danych osobowych, Art. 34 is the instrument itself: it applies to the organisations within its scope, and buyers and partners in Poland ask for evidence that you meet it.

Supervision of GDPR compliance in Poland sits with one authority rather than several. Art. 34 of the Act of 10 May 2018 makes the President of the Personal Data Protection Office, the UODO, both the competent authority and the supervisory authority within the meaning of the Regulation, appointed by the Sejm with the Senate's consent. The Act adds national rules: Art. 8 applies Art. 37 of the GDPR to the designation of data protection officers, names public finance units, research institutes and the Narodowy Bank Polski as obliged public bodies, and requires the designation to be notified to the President. Arts. 12 to 15 set up GDPR-specific certification by the President or by certifying bodies accredited by the Polish Centre for Accreditation. Beyond that, compliance is shown through records of processing, notices, processor contracts, rights handling, breach procedures and security measures. Sterling's Frankfurt office builds that evidence for Polish clients and aligns it with ISO/IEC 27701 where an external benchmark is wanted, with Effivity and Sterling Academy included.

The need

Who needs GDPR in Poland, and what happens without it

These are the organisations in Poland that most often need to show GDPR.

  • Private companies processing personal data in PolandSupervised by the President of the Personal Data Protection Office (UODO), the supervisory authority under Art. 34 of the Act.
  • Controllers and processors that must designate a data protection officerArt. 8 of the Act applies Art. 37 of the GDPR, and the officer is notified to the UODO.
  • Public finance units, research institutes and the Narodowy Bank PolskiThe Act names them as the public bodies obliged to designate an officer.
  • BPO, shared-service and IT providers acting as processorsClients need processor contracts and security evidence, and may value GDPR certification where it exists.

Not sure which of these applies to you?Answer a short set of questions and your readiness report arrives by e-mail.

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Requirements

GDPR requirements in Poland

Strip away the vocabulary and the GDPR requires an organisation to comply in six areas covering how it uses personal data.

Every use of data has a lawful basisEach processing purpose is identified and rests on a lawful basis, with data limited to what that purpose needs.
People are informed and their rights respectedClear privacy information is given, and requests to access, correct, erase or object are answered within the regulation's time limits.
Accountability is documentedRecords of processing, policies and, where required, a data protection officer show how you comply.
Privacy is designed in and risks assessedData protection is built into systems by design and by default, with impact assessments for high-risk processing.
Data is secured and breaches handledAppropriate security protects personal data, and breaches are recorded and notified to the authority and individuals where required.
Processors and transfers are controlledProcessors work under compliant contracts, and transfers outside the EEA rely on a recognised transfer mechanism.

In Poland these six sit alongside the local laws and regulations listed under drivers below; one system can evidence both. The detail is on the global hub: GDPR explained →

How Sterling gets a Polish company compliant with GDPR

How to achieve GDPR compliance in Poland

One team from the Frankfurt office carries the work from scoping to sign-off. Clients in Poland are served from Sterling's Frankfurt office, on-site where the work needs it and remotely otherwise.

  1. Discovery call and scopeEntities, locations, regulators and target date, agreed before any proposal.
  2. Gap assessment against GDPR and the Polish requirements that apply to youControls you already run for your regulators and customers are reused, not rebuilt.
  3. Your system built with your team in EffivityRisks, controls, evidence, incidents and reviews in one live system the auditor can see.
  4. Internal audit, management review and corrective actionsYour internal auditors trained by Sterling; the evidence proven before any external review.
  5. Reviews by regulators, customers and auditorsSterling supports the reviews your regulators, customers and auditors run.
Included in every engagement
  • End to end, from one team
  • Effivity ISO & GRC software
  • Preferential Sterling Academy access, with complimentary awareness training for your people
  • Internal auditor training for your audit team, as applicable to your standard
  • Vulnerability assessment on ISMS engagements

The Sterling Promise: 100% on-time completion, 100% success, 8,100+ client engagements.Sterling does not certify. Certification decisions stay with independent bodies.

Time

How long does GDPR compliance take in Poland?

There is no standard duration: it depends on your scope and on how much of the system already runs. In Poland these are the factors that set the timeline.

  • Number of processing activities and systems to map
  • Number of legal entities and establishments
  • Processor and international-transfer review
  • Employee-data and monitoring arrangements

Sterling agrees a dated plan with you on the discovery call, once the scope is known.

Cost

How much does GDPR compliance cost in Poland?

The cost has two parts: the consulting work to build and prove the system, and any external assessor’s fees, which are quoted separately. In Poland these factors move both.

  • Number of entities and processing activities in scope
  • Volume of data subjects and special-category data
  • Security remediation needed
  • External data protection officer arrangement

Sterling gives one customised, all-inclusive proposal after the discovery call, never before the scope is agreed.

Choosing a partner

GDPR consultants and assessors in Poland

Two different organisations are involved. A consultant helps you build the system and prove it works; your regulators, customers and auditors then audits or assesses it and decides. Keeping the two separate is what makes the result credible to buyers and regulators.

  • Check that the body’s accreditation or approval covers GDPR and your sector, and that its certificates can be verified online.
  • Ask the consultant how the local requirements in Poland are mapped into the same system, so nothing runs twice.
  • Ask for client references in your sector; Sterling’s client letters are available on request.
  • Agree who owns the evidence and the tool after the engagement; with Sterling the system stays yours, in Effivity.

    Laws and regulations that drive GDPR in Poland (3)

    InstrumentHow it treats the standard
    Regulation (EU) 2016/679 (GDPR / RODO) with the Ustawa z dnia 10 maja 2018 r. o ochronie danych osobowych, Art. 34The instrument itself
    The President of the Office is the competent authority and the supervisory authority within the meaning of the GDPR.
    Ustawa o ochronie danych osobowych, Art. 8 to 11 (data protection officer)The instrument itself
    Designation follows Art. 37 of the GDPR, public bodies obliged to designate are defined, and the designation is notified to the President of the Office.
    Ustawa o ochronie danych osobowych, Art. 12 to 15 (certification and accreditation)The instrument itself
    GDPR certification is carried out by the President of the Office or a certifying body, and the Polish Centre for Accreditation accredits certifying bodies.

    Accreditation, audit language and remote audits in Poland

    Compliance, not certification of the organisation: the GDPR has no general certificate. Evidence is the controller's or processor's records of processing, notices, processor contracts, rights handling, breach procedures and security measures. Polish law provides for GDPR-specific certification under Art. 42 by the President of the Office or a certifying body accredited by the Polish Centre for Accreditation; that is separate from ISO/IEC 27701 certification. Edition and transition details: GDPR hub →

    Audit language

    The UODO works in Polish; privacy notices must suit the audience they serve. Internal records can be kept in Polish or English.

    Remote and on-site

    Data-mapping workshops can be on-site or remote; no external assessment is prescribed for general compliance.

    GDPR in Poland: questions clients ask

    Which authority supervises GDPR compliance in Poland?

    The Prezes Urzędu Ochrony Danych Osobowych, the President of the Personal Data Protection Office. Art. 34 of the Polish Act of 10 May 2018 makes the President the competent authority and the supervisory authority within the meaning of the GDPR, and the Sejm appoints the President with the consent of the Senate. Take advice on how this applies to a multi-country group.

    Do we have to designate a data protection officer in Poland?

    If Art. 37 of the GDPR requires it, yes. Art. 8 of the Polish Act applies that Article to controllers and processors, and Art. 9 defines the public bodies that must designate an officer as public finance sector units, research institutes and the Narodowy Bank Polski. Check your own processing against Art. 37 with counsel.

    Must we tell the UODO who our data protection officer is?

    Yes. An entity that designates an officer notifies the President of the Office, giving the officer's name and an e-mail address or telephone number, and makes the officer's details available. The Act allows an authorised representative to file the notification with a power of attorney. Check the current form and channel on the UODO's website.

    Is there GDPR certification in Poland?

    Yes, as a GDPR-specific route. Under the Polish Act, certification under Art. 42 of the GDPR is carried out by the President of the Office or by a certifying body, and the Polish Centre for Accreditation accredits those bodies. It is distinct from ISO/IEC 27701 and is not a general GDPR certificate for the whole organisation. Your counsel or the UODO can confirm how it applies to you.

    Read more

    More on GDPR for Polish organisations

    Explore

    Other standards Polish businesses ask Sterling for

    Organisations in Poland often combine GDPR with one of these, under one management system where the scopes allow.

    All 22 standards Sterling delivers in Poland →

    Next step

    Start with a free discovery call from the Frankfurt office

    A Sterling consultant goes through your entities, your regulators and your target date with you. No proposal until the scope is agreed.

    Sources

    1. Regulation (EU) 2016/679 (GDPR / RODO) with the Ustawa z dnia 10 maja 2018 r. o ochronie danych osobowych, Art. 34 — api.sejm.gov.pl (accessed 7 Oct 2026)
    2. Ustawa o ochronie danych osobowych, Art. 8 to 11 (data protection officer) — api.sejm.gov.pl (accessed 7 Oct 2026)
    3. Ustawa o ochronie danych osobowych, Art. 12 to 15 (certification and accreditation) — api.sejm.gov.pl (accessed 7 Oct 2026)

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