9 Steps To Manage Your Data Inventory For GDPR

Organizations must manage GDPR data inventory by following these steps:

1. Identify Data

Conduct a thorough assessment to identify all types of personal data that the organization collects, processes, and stores. This can include names, addresses, contact details, financial information, identification numbers, IP addresses, and any other information that can directly or indirectly identify individuals.

2. Categorize Data

Categorize the identified personal data based on its sensitivity and potential risk to individuals’ privacy. This step helps prioritize data protection efforts and determine the appropriate level of security measures required for each category. For example, sensitive personal data like health records or biometric information may require stricter security controls.

3. Document Data Flows

Create a visual representation or data flow diagram to map out how personal data flows within the organization. This includes identifying the sources of data, such as customer interactions, website forms, or employee records, as well as the different systems, databases, or applications that store and process the data. Additionally, document any third-party processors or external entities that handle personal data on behalf of the organization.

4. Update Data Inventory

Establish a structured data inventory that lists all the personal data being processed, along with relevant details such as the purpose of processing, legal basis, retention periods, and data transfers. Ensure that the inventory is regularly updated to reflect any changes in the data collected or processing activities. This helps maintain an accurate record of personal data held by the organization.

5. Document Legal Basis

Determine and document the legal basis for processing personal data under the General Data Protection Regulation (GDPR). The GDPR provides several legal bases for processing, including consent, contractual necessity, compliance with legal obligations, protection of vital interests, the performance of a task carried out in the public interest, and legitimate interests pursued by the organization or a third party. It’s important to document the legal basis for each type of processing activity.

6. Implement Security Measures

Implement appropriate technical and organizational measures to ensure the security and confidentiality of personal data. This can include measures like encryption, access controls, pseudonymization, regular security assessments, and staff training on data protection practices. The goal is to protect personal data from unauthorized access, loss, or breaches.

7. Respond to Data Subject Requests

Develop and implement procedures to effectively handle data subject requests. These requests can include providing individuals with access to their data, rectifying inaccuracies, erasing data (right to be forgotten), restricting processing, and facilitating data portability. The organization should establish a process to verify the identity of data subjects and respond to requests within the specified timeframes outlined in the GDPR.

8. Maintain Records

Keep comprehensive records of the organization’s data processing activities. This includes maintaining a record of processing activities (ROPA), which documents the purposes of the processing, data categories, recipients of the data, data retention periods, and any cross-border transfers. The ROPA helps demonstrate accountability and compliance with GDPR requirements.

9. Regularly Review and Update

Conduct periodic reviews of the data inventory and associated data protection practices to ensure they remain up to date. This includes considering any changes in data processing activities, organizational structure, or regulatory requirements. Regular reviews help identify gaps or areas for improvement in data protection and ensure ongoing compliance with the GDPR.

Are There Any Tools To Manage GDPR Data Inventory?

Yes, there are several tools available to help organizations manage their GDPR data inventory. Here are a few examples:

• Impanix: Impanix is a compliance automation software and service platform. It only processes the information it has access to. This approach ensures that Impanix can effectively analyze and provide insights while maintaining the confidentiality of your critical information.
• OneTrust: OneTrust is a widely-used privacy management software that offers a range of modules for GDPR compliance, including data inventory and mapping, consent and preference management, vendor risk management, and data subject request management.
• TrustArc: TrustArc offers a privacy management platform that includes tools for GDPR compliance, such as data inventory and mapping, privacy impact assessments (PIAs), and incident and breach management.
• Proteus GDPReady: Proteus GDPReady is a GDPR compliance platform that offers features for data inventory management, data mapping, consent management, and DPIA automation. It also provides customizable templates and workflows to streamline compliance processes.
• Collibra: Collibra provides a data governance platform that includes capabilities for managing GDPR requirements, including data inventory management, data lineage, consent management, and data cataloging.

How Does Managing Data Inventory Help?

Managing data inventory offers several benefits. Firstly, it enables organizations to gain a comprehensive understanding of the data they collect, process, and store, including its sources, purposes, and associated metadata. This knowledge helps in identifying potential privacy risks, ensuring compliance with regulations such as GDPR, and implementing appropriate security measures.