[discoursism]

> we have no idea which overheads are actually going to prove justified and which are just throwing money away

Life is risk. I contend that if you make a good faith effort to comply with this law (i.e. consult with a lawyer, once, to develop those eight documents you mentioned in another part of this thread) and generally practice good private information hygiene (wipe out old data, don't log private info, don't retain logs or emails too long, etc.), you're probably going to be fine. This is probably not going to be in the "inner loop" of risks your small business faces.

In every regulation, there are winners and losers. Some of the losers didn't do anything wrong, but are just losing because that's the nature of designing laws that factor in disparate interests. At this point, it's the law, and your only choice is how you're going to handle it. And my contention is that, if your small business is receiving letters like this with any regularity, calling a lawyer and spending half a day on it each time is not among the reasonable spectrum of risk-mitigating responses.