Why Should You Know Where Data Is?

A centralized data inventory is critical for your organization’s security and privacy compliance. It’s the starting point for understanding what and how data is collected and used across the organization.

Using data inventory and data mapping, you can pinpoint exactly where data is located and stored and draw connections between complicated data flows.

Having an easily accessible inventory enables quick identification of the assets or systems that process an individual’s data and which jurisdictional requirements apply throughout the data lifecycle.

As more data privacy laws are enacted worldwide, understanding your organization’s data inventory and mapping is necessary to meet compliance requirements.

Organizations both big and small should expect to respond to a significant number of consumer requests about their personal data – if you’re not already getting them.

Are You Compliant with CCPA and GDPR DSAR Requirements?

Perhaps the most customer-facing and public compliance requirements for the EU General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA) are around the rights of the data subject or consumer rights. Also referred to as individual rights.

Both GDPR, CCPA, and other data privacy laws significantly increase the requirements on businesses to comply with individual rights requests. These requests include the rights to:

• Access information
• Ratify or update efforts or incomplete information
• Be erased/forgotten, withdraw consent, and have their data removed
• Restrict processing or limit use and disclosure
• Object to processing
• Data portability

Requirements dictate how organizations address individual rights and related requests. These requests are called Data Subject Access Requests (DSAR).

Most commonly the laws address the type of requests businesses can expect to address and the timeline for which they will need to respond or fulfill the request.

For example, GDPR requires that requests be addressed within one month. CCPA requires requests to be addressed within 45 days – with some exceptions and extensions permitted.

Other laws have similar requirements to GDPR and CCPA.

Meeting these requirements is important because non-compliance can result in fines and angry customers. Furthermore, failure to meet these requirements is a violation of individual rights.

Forrester Research found consumers are likely to exercise their rights around their personal information. 63% reported that they are likely to exercise their right related to GDPR to ask companies to delete their information.

However, if your company is unsure of what information it’s collecting, where it lives, and the processes surrounding data use, responding to DSARs will quickly become a burden.

Before your team is overwhelmed with DSARs, ensure you have an accurate, centralized data inventory.

What Happens When a Data Subject Requests a Copy of Their Data?

GDPR Article 15 grants data subjects the right of access giving individuals a right to obtain confirmation as to whether personal data is being processed about them or to request a copy of that data.

The 5 state privacy laws (California, Colorado, Connecticut, Virginia, and Utah) also include the right of access for consumers.

As mentioned above, along with the right to request a copy of their data, it’s required by law for organizations to respond to the request within a specific number of days.

For example, your organization collects data about customers to enhance the customer experience.

If a customer requests a copy of their data, will you know where to find it? If they ask additional questions about their data, will you be able to answer them?

Now, what would happen if thousands of customers made this request around the same time? Could your IT department handle that volume of requests?

DSARs are just one of the many reasons why your business needs a data inventory.

What Does Data Inventory Have to do with Global Business Transactions?

GDPR Article 46 allows for data transfers to non-EU countries through mechanisms that provide appropriate safeguards.

Appropriate safeguards include Binding Corporate Rules (BCRs), Model Contract Clauses (MCCs), also known as Standard Contractual Clauses (SCCs), and legally binding documents and enforceable instruments between public authorities or bodies.

If you’re about to close a global deal and personal data will need to be transferred out of the EU to the US based on a subsidiary that uses a vendor in Asia to process that data.

Are any measures in place to ensure your team will not overlook specific requirements as the data travels across countries?

International data transfers are a highly discussed topic in data privacy, with many regulations and differing opinions.

Even though it’s not explicitly stated in GDPR, companies are required by Article 30 to produce “records of processing activities” to demonstrate to regulators that the organization is adhering to GDPR.

Implement a data inventory process that focuses on how data is collected and why it is collected to respond to both DSARs and maintain privacy law compliance.

Documenting the Data Lifecycle

The process of documenting this lifecycle is referred to as a data flow analysis or data mapping. Data mapping requires collaboration between those who know where data is at each stage across the enterprise and with third parties.

Data lifecycle stages include collection, storage, usage, transfer, processing, and disposal.

Comply with Data Privacy Law DSAR Requirements

• Ensure understanding of what data you collect and process and where it resides.
• Establish a process to intake individual rights requests (that is easy on the individual) and ensure this process is well-communicated throughout the organization.
• A request may come in from many routes, and the person receiving that request needs to understand that a request is being made.
• Individuals typically won’t understand or use the exact verbiage in the law.
• Validate the individual’s identity.
• Once the request is validated, have a process to review it, evaluate the data referenced, the reasons for processing the data, and any exceptions.
• Have a response process and an appeals process for denied requests.
• Retain documentation throughout the process.

Improve Privacy Compliance with Data Mapping

Any business that collects data needs to ensure its privacy compliance is right.

But if you don’t know the type of data you collect and how it’s shared, processed, and stored, it is hard to know if your organization’s use of data is compliant with privacy rules – let alone have the right answers for audits or individual data subject access requests.

One of the most important steps to designing and building a privacy compliance program is to build a data inventory. Begin by mapping all the personal data processing activities within your organization.

Data Mapping is About Matching Information for Easier Management

Most organizations collect more data than they know what to do with. If your business wants to get more value from the data it collects – and meet privacy compliance – you need to know more about where this information is managed:

• Find all sources of data – Find out every source of data your business has access to – internally and externally – and identify what information is held in each database
• Map the flow of data – Once you know all the different data sources, you can create data flow maps of all the processes and systems the data moves through. Where it starts, all the points it is processed and analyzed, and where it is stored. Multiple versions of similar data are likely stored in multiple locations
• Match similar information – The data mapping process focuses on matching fields in different databases, making it easier to combine this information into a central inventory for better management
• Build and manage a central data inventory – When you have reliable data flow maps and data mapping processes set up, you can migrate and integrate valuable data into a central inventory for better management.

Privacy Compliance Relies on Good Data Management

Data mapping is not a once-a-year process – it needs to be done regularly so your organization’s data inventory records are accurate and up-to-date.

As privacy and data protection regulations expand, organizations need to show how they reduce and manage risk. So it’s important you can find the right information in your data inventory on demand.

For example, risk management and compliance reporting for the EU General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA) will rely heavily on a comprehensive data inventory.

Likewise, organizations need fast access to accurate and current personal data they hold to properly answer data subject access requests.

Data Inventory Needs to be a ‘Living Record’

Once your organization’s data processing flows have been recorded and reviewed for risk, you can make better-informed decisions about where to invest resources based on where the highest risk lies.

While the word ‘inventory’ might suggest a static list at a point in time, a data inventory for privacy compliance should be a ‘living record’ of how personal data moves throughout your organization’s systems and business processes – and changes over time.

Automated Data Mapping Streamlines Management and Compliance

There are three main ways you can handle data mapping in your organization:

1. Manual data mapping – have your data professionals create templates and write code for processes to connect and document all data sources to the central data inventory. It can be very hands-on and time-consuming, tying up your data team – and they’ll need excellent coding skills.
2. Semi-automated data mapping – use a tool for data mapping (or ‘schema mapping’) to find and create connections between data sources and target schema at the heart of your central data inventory; then have your data professionals check the work done by the tool and manually adjust or fix it. Potentially resource-intensive, this approach relies on data professionals with solid coding skills.
3. Automated data mapping – use a full automated data mapping platform to do all the heavy lifting, such as integrating, migrating and organizing data in a central inventory. The platform will include tools for people who aren’t data professionals so they can map data and schedule regular updates to capture changes. This approach streamlines multiple processes by automating them, and makes reporting easier, especially for data privacy compliance.

5 Best Practices for Building a Data Inventory

TrustArc’s privacy experts have helped many businesses get up to speed with data mapping, privacy compliance and managing their data inventory.

Here are the expert’s recommended best practices for building a data inventory:

1. Design a scalable data inventory – Remember all data inventories need to be updated regularly, so designing a scalable and repeatable process up front can save time and cost later
2. Train data management subject matter experts – Even if your organization takes the full-automated approach to data mapping and inventory management, it is important to train team members so they understand any compliance requirements driving the data inventory, and what to expect from the process
3. Launch a pilot program – Start small with one functional area or region so your organization can learn from a more controllable experience, learn ways to improve data management and build on that knowledge and experience to expand into other parts of the business
4. Think outside the (server) box – Remember data can flow in a variety of ways and media. Don’t forget to capture records from printed copies of documents, video files, tape recordings and other non-electronic formats
5. Track all data mapping tasks – A data inventory is a powerful tool that will not only meet some compliance requirements directly, but also help in other important activities such as:

• incident response
• individual rights requests
• assessing risks and triggers for data protection impact assessments
• identifying and solving cross-border data flow issues (including customizing security and privacy protections as needed).

Help your organization with data mapping privacy compliance

TrustArc understands the challenges organizations face with data mapping, including creating and building a data inventory and data flow maps that support privacy compliance.

We’re here to help you solve these challenges by making the work of data management easier.