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.
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.
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.
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.
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.
What is a data registry?
In this workshop, Natuvion walks you not only through the requirements of creating a data registry for your company but in doing so also helps you find a way to comply with other GDPR articles. This includes an analyzation of the different basis of processing and grounds for deletion including many others that build the necessary information needed for a data registry.
Cross-border data transfers.
The GDPR allows for data transfers to countries whose legal regime is deemed by the European Commission to provide for an “adequate” level of personal data protection. In the absence of an adequacy decision, however, transfers are also allowed outside non-EU states under certain circumstances, such as by use of standard contractual clauses or binding corporate rules GDPR (BCRs).
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;
- Personal employee data (name, address, date of birth, etc.)
- Information about customers, patients, clients (marketing databases, medical records, contact lists, any contact information)
- Data transferred to third parties (accounting books, credit registers, direct marketing)
- Non-public personal data of business partners and providers
- IP (Internet Protocol) addresses
- Cookie identifiers, or others such as Radio Frequency Identification (RFID) tags
- Camera records
- Iris scan
- User ID and passwords - access registration
- Smart meter data
- Biometric data
- Health data
- Membership of a labor organization