GDPR consent

What is SAP GRC ?

Governance, Risk Management and Compliance or GRC is an umbrella term whose scope touches most offices in an organization.

GRC aims to synchronize various internal functions, integrate governance, management, risk and compliance activities.

SAP GRC is a software solution used for managing compliance and policy management. The compliance management capabilities allow organizations to manage and monitor their internal control environments. GRC Modules include;

  1. SAP GRC Access Control

  2. SAP GRC Process Control and Fraud Management

  3. SAP GRC Risk Management

  4. SAP GRC Audit Management

  5. SAP GRC Fraud Management

  6. SAP GRC Global Trade Services

GDPR Data Protection Officer | Do organizations have to appoint a Data Protection Officer (DPO)?

GDPR Data Protection Officer | Do organizations have to appoint a Data Protection Officer (DPO)?

A data protection officer, DPO is the voice of data protection compliance within an organization. The DPO is still expected to be able to help organizations comply with their legal obligations and for GDPR manage the security of personal data.

What SAP applications help with Right of Access?

What SAP applications help with Right of Access?

Art. 15 “Right of access by the data subject” - The data subject shall have the right to obtain from the controller confirmation as to whether or not gdpr personal data concerning him or her are being processed, and, if that is the case, access to the gdpr personal data plus other details.  There are other examples too.

GDPR Implementation | How do we automatically identify all personal data in a SAP system landscape?

GDPR Implementation | How do we automatically identify all personal data in a SAP system landscape?

Sophia software provides discovery analytics that helps with the first step of implementing the GDPR compliance process by reporting on what personal data is in your landscape and where it is stored.

GDPR compliance requirements: Does an organization need explicit permission to store records of email addresses and phone numbers of customer contacts that are already in my CRM?

GDPR compliance requirements: Does an organization need explicit permission to store records of email addresses and phone numbers of customer contacts that are already in my CRM?

If you are using a SAP CRM system and its email marketing system with prospects and customers from the European Union, then the GDPR legislation is very important for you and your organization.  You will need explicit permission to store records and email addresses of prospects and customers to follow GDPR compliance requirementsPseudonymization can reduce the risk with these data protection processes.

Data Protection Marketing (Target Marketing)| GDPR Data Subject Rights

Data Protection Marketing (Target Marketing): The GDPR restricts “profiling” and sets significant GDPR data subject rights to avoid profiling-based decisions.

Advancements in technology have expedited methods for data controllers to gather, analyze, and process personal data for a variety of purposes, including drawing conclusions about data subjects and potentially taking action in response to those conclusions in data protection marketing such as target marketing or price differentiation. This is called "profiling."

Under Article 4(4), data processing may be characterized as “profiling” when it involves

  • automated processing of GDPR personal data and
  • using that personal data to evaluate certain personal aspects relating to a natural person. 

Specific examples include analyzing or predicting “aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.”

"Profiling” requires some sort of an outcome or action resulting from the data processing, and is underscored by the GDPR data subject rights in which the data subject is informed about the “consequences” of profiling decisions

Articles 13 and 15 cover the GDPR data subject rights and addresses the information to be provided to data subject upon personal data collection and--upon the GDPR data subject's request--both require disclosure of “the existence of automated decision making including profiling” along with “the significance and the envisaged consequences of such processing for the data subject.”

When we analyzed Natuvion customer’s current processing times to meet these GDPR requirements that cover GDPR data subject rights, to produce such report (in a useful format for a data subject) on this data, across heterogeneous landscapes, it takes a minimum of two months, and sometimes much longer.  GDPR requires a response in one month.

This is where SAP Information Retrieval Framework helps.  Schedule your one-day GDPR workshop so the Natuvion team can share how hundreds of other SAP customers use free SAP tools to meet these GDPR reporting requirements.

 

Preparing for the General Data Protection Regulation | Why should a company act now and not wait?

Preparing for the General Data Protection Regulation | Why should a company act now and not wait?

Preparing for the General Data Protection Regulation: A 'Wait and See' approach is going to be pricey for US organizations doing business with the EU.

What do Human Resources departments need to know about Data Protection Policy (GDPR) when using SAP HCM or SAP SuccessFactor systems?

What do Human Resources departments need to know about Data Protection Policy (GDPR) when using SAP HCM or SAP SuccessFactor systems?

What do Human Resources departments need to know about Data Protection Policy (GDPR) when using SAP HCM or SAP SuccessFactor systems?

The General Data Protection Regulation (GDPR) will be enforced from 25 May 2018, giving Human Resources (HR) departments just a few months to ensure that they have updated their processes for collecting and processing data about employees, former employees and job candidates.

Three important GDPR articles that HR needs to know now....

Is GDPR consent required for the use of anonymous data?

Is GDPR consent required for the use of anonymous data?

The GDPR sets very particular regulations on consent. With the new regulation coming in May 2018, companies need to be prepared for new GDPR consent mechanisms for their SAP test and QA systems. Anonymizing data in these systems make GDPR consent no longer mandatory. Natuvion's TDA tool offers a safe way to anonymize data so that it can be safely and rightfully used while expediting the process to full compliance and without the risk of facing GDPR  fines.  

GDPR | Changes for Prospect Management and Prospect Consent

The GDPR changes prospect and customer engagement rules.

The conditions for obtaining prospect consent are stricter under GDPR requirements, as the individual must have the right to withdraw consent at any time. There is also a presumption that consent will not be valid unless separate consents are obtained for different processing activities.

  1. Newsletters | This means you have to be able to prove that the individual agreed to a certain action, like receiving a newsletter for instance. It is not allowed to assume or add a disclaimer, and providing an opt-out option is not enough.
  2. Marketing and sales activities | Companies will have to review business processes, applications and forms to be compliant with double opt-in rules and email marketing best practices. For example in order to sign up for communications, prospects will have to fill out a form or tick a box and then confirm it was their actions in a further email.
  3. Audit Trails | Organizations must prove that consent was given in a case when the individual objects to receiving the communication. This means that any data held, must have an audit trail that is time stamped and reports information detailing what the contact opted into and how.  It must also be possible to permanently delete data from your CRM systems.
  4. Purchase marketing lists | The company is responsible for getting the proper consent information, even if a vendor or outsourced partner was responsible for gathering the data.
  5. Trade Shows | In the corporate world, sales people meet potential customers at a trade show, they exchange business cards, and they add the contacts to the company’s mailing list when they come back to the office. In 2018, this will not be possible anymore. Companies will have to look at new ways of collecting trade show prospect information.

To learn more about managing your prospect data, schedule a one-day workshop for Natuvion to build your GDPR road map.

Is there a document available online which lists everything that is considered GDPR personal data?

In the General Data Protection Regulation, the personal data definition is formulated very generally. Below, we list some examples. However, given the breadth of the regulation, it is not easy to list all the types of data that are considered personal.

The GDPR regulation applies to any kind of data concerning a determinate or determinable individual.  Below we listed some examples we see at our customers but there are more;

 

  1. Personal employee data (name, address, date of birth, etc.)
  2. Information about customers, patients, clients (marketing databases, medical records, contact lists, any contact information)
  3. Data transferred to third parties (accounting books, credit registers, direct marketing)
  4. Non-public personal data of business partners and providers
  5. IP (Internet Protocol) addresses
  6. Cookie identifiers, or others such as Radio Frequency Identification (RFID) tags
  7. Camera records
  8. Iris scan
  9. User ID and passwords - access registration
  10. Smart meter data
  11. Biometric data
  12. Health data
  13. Membership of a labor organization
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Do we need data privacy consent from individuals to use real data in secondary systems?

Do we need data privacy consent from individuals to use real data in secondary systems?

The best way to eliminate your risk is to anonymize the data in secondary systems.  Anonymizing the data removes the need for data privacy consent and (with proof) removes the systems from GDPR compliance processing, while still providing the data for analysis or testing.