In the mid-1990s the world saw the renaissance of the computer, which quickly overtook manual paper sheet work and data entry. This revolutionized the work culture and increased productivity. No longer did you have to make entries on large registers, you could just feed it into the pre-existing document on your computer.
Another such renaissance is right on the horizon with the advent of the internet and the cloud-based storage system. Although it has advantages, one area that has become more complicated is data management, which in some organizations is not properly managed and is scattered across three mediums - paper, computers, and cloud storage.
This is especially the case with information security compliances. The data of compliance checklists for infosec compliances like GDPR is often scattered across the teams which makes it hard to be prepared for any data breaches or other such emergencies. That is why Data mapping becomes necessary under GDPR.
GDPR Data Mapping
One of the most essential parts of GDPR compliance legislation is its insistence on appropriate data mapping. It is the beginning step of each of the other requirements under GDPR, like documenting data subjects’ requests, data processing activities, or data protection impact assessment. Following are the articles under GDPR that emphasize the importance of data mapping for GDPR compliance.
Breach Notification - Article 33
One of the most useful purposes of a well-documented data mapping is that it makes sending data breach notifications very easy. If the data within the organization isn’t linked together in an organized manner then knowing how much of the data subject’s data is leaked or how many data subjects got their data leaked becomes a hassle.
As per Article 33, all GDPR-compliant organizations are required to inform a competent supervisory authority as per Article 55 within 72 hours of any data breaches that may risk the rights and freedom of any of the data subjects.
If the risk to the rights and freedom of the data subjects is high, then as per GDPR they should be notified without any delay. Such a short time window makes it near impossible to gather data on the extent of damage done to your organization’s security framework if the data isn’t mapped.
Data mapping ensures steadfast report generation on any data breaches, thereby providing those reports to the governing body and the data subject within the time window.
Consent Management - Article 4
Article 4 of the GDPR legislation clearly states that the request for a data subject’s consent is to be free, specific, informed, and unambiguous. Data Subjects should have a clear knowledge of what, why, and how their information will be used.
GDPR also requires the organizations to allow the data subjects the freedom to withdraw their consent whenever they desire. As evident, the process is highly complex. Data Mapping will be essential to document which parts of the data acquisition, processing, and sharing require consent on a legal basis.
Also, documenting the areas where consent capture mechanisms need to be put in place and also registering consent withdrawal requests will also require data mapping.
RoPAs (Record of Processing Activities) - Article 30
Under GDPR Article 30, all data processing activities are to be thoroughly tracked and recorded. Thus, GDPR-compliant controllers and processors are required to maintain a record of processing activities (RoPA).
It must also include the reason for processing data, legal grounds, consent update, DPIA Status, Cross-border transfers, and more. Data mapping enables organizations to track these activities with precision and document them under one roof.
Such a map can link together various other dependencies required to fulfill the task of data processing.
DPIA (Data Protection Impact Assessments) - Article 35
Under Article 35 of the GDPR legislation, all compliant organizations are subject to carry out data protection impact assessments (DPIAs).
DPIA must document the nature, scope, context, and purposes of the processing. For conducting DPIA efficiently, organizations must map their impact assessments.
What type of data is being collected, when and how will be collected and processed, where the data will be stored, who it will be shared with, and how data flow will happen to various systems and vendors. All of this can be done through appropriate data mapping.
Key elements of data mapping for GDPR
Data mapping in essence is aimed at simplifying GDPR compliance for an organization. Effective documentation and organization ability are the key to ensuring strict adherence to the GDPR. The organizations should be able to:
Organize, document, maintain and structure data for operational and executive needs.
Easily access and find relevant data whenever desired.
Efficiently manage and protect data.
Protect the data proportional to the risk it entails.
Allow tracking of data flow.
Well-manage records and document data processing activities.
How to comply with GDPR data mapping guidelines?
The primary objective of the Data Mapping shouldn’t be just for GDPR compliance, it should act as a well-functioning resource that enhances the organization’s productivity and efficiency.
It should be implemented in the daily operations of the organization and it should be enhanced to a level that it becomes GDPR compliant.
Automated compliance solutions, enable you to create a vibrant data map that is well organized and accounts for every inch of data acquisition, processing, or sharing done.
A well-designed data mapping system has the following components.
Maintaining records provides a structured form of data that can later be implemented under various functions for various results.
Such a system will maintain records of complex data flows and process flowcharts.
Documentation of data attributes like data type, format, location, accountability, access list, dependencies, and more.
Defining all the attributes handled by data map elements.
Documentation of the purpose and reason behind documentation of each data both organizational and legal justification required.
Ability to generate a report of the records of processing as per Article 30 which can be shared with any party internal/external.
Maintaining information and knowledge
This provides the ability to recall and access sets of data
A library of expandable information and previous reports and records.
Defining local variables of a particular data map or expanding it for multiple data maps as a global variable.
Optimizing current data maps with better-suited variables.
Making flowcharts representations of data flow within the organization and outside.
Here Data Map will also act as the inventory of all business flow.
It is a clean and proper interface between the organizations and the Records discussed in the previous sub-heading.
Supports decision-making capabilities by providing previous stats and figures, appropriate consent requirements, and more.
Maintaining engagement and collaboration
Such a system of data maps enables inter-departmental cooperation and harmony between various departments as well.
Mutually shared dashboards with an overview of data flows, processes, and their mapping.
Working with various stakeholders under one central umbrella data map.
Diverting data flow from individual departmental data maps to the central data map.
Ensuring device adaptability, working with teams through any device and on multiple platforms.
User-friendly environment to ensure regular updations by all the teams and other stakeholders.
Managing Automation, Analytics, and Insights
Data Maps won’t be useful if they aren’t automated. They should be able to provide both insights and analytics that will help in decision-making.
Automated Data Map creation through metadata ingestion.
Automatic scanning abilities include OCR (Optical Character Recognition) Web-scrapping, and classifying that data automatically in the data map.
Using attributes captured during the automated scans in the data map.
Perioding re-scans to ensure up-to-date data entries.
Automated monitoring of mapped attributes and elements for any compliance-related violations.
Pre-setting compliance standards into the system, so the system recognizes a violation.
Automated Breach Impact analysis that generates a report of how the data is affected.
Automated Tracking Consent requirements and requests for each data point in the data map.
Get GDPR Compliant with Scrut Automations
Scrut Automation provides you with a dashboard that is data mapped at the backend and records all the relevant data points, attributes, and variables that will be helpful in computing your overall compliance.
Scrut Automation is a smart and radically simple Governance, Risk and Compliance automation platform for growing startups and mid-market enterprises. With Scrut, Compliance teams can reduce ~70% of their manual effort in continuously maintaining compliance towards SOC 2, ISO 27001, GDPR, PCI DSS; and privacy laws like HIPAA, GDPR, and CCPA. Schedule your demo today to see how it works.