In the wake of GDPR, law firm Squire Patton Boggs reported a “sharp increase” in the number of UK residents who initiated data subject access requests (DSARs), fulfilling the same number of DSARs in the first five months of 2019 as they’d handled during the entire year of 2018.

CCPA data subject requests (DSRs) are likely to have the same effect on California-based organizations, and with a 45-day deadline for fulfillment, companies that don’t implement automated self-service workflows are at an increased risk for Denial of Service (DoS) attacks.

DoS attacks happen when legitimate users are unable to access information systems, devices, or other network resources due to cyber criminal activity that floods a host or network with traffic until it cannot respond or simply crashes, preventing access to email, online accounts, websites, etc.

These attacks disrupt a company’s online presence by keeping its web servers so busy with network requests that they’re unable to load web pages or Internet resources, costing organizations both time and money while their resources and services are inaccessible.

A DoS attack can happen when a company is inundated with DSRs. It overwhelms the CSR and IT staff, who are forced to respond to requests manually and eventually reach a breaking point in which the company can’t safely respond to requests within the required timeline.

With CCPA right around the corner, there’s no time like the present to start thinking about your company’s plans to circumvent DoS attacks and streamline DSR processes, which, according to the new regulations, must now include identity verification prior to fulfilling each request.

Technology can help teams automate manual processes, which helps save time and promote consistency, but it’s important for businesses to be aware of potential DSR threats like DoS attacks that can jeopardize fulfillment and result in both frustration and noncompliance.

Lessons Learned from GDPR

Many companies started preparing for GDPR by hiring lawyers and consultants to conduct privacy impact assessments (PIAs), data mapping, understanding workflows, manually surveying data sets, and introducing internal guidelines.

These steps were certainly helpful and necessary, but because the work had to be applied to multiple sets of data repositories, companies found they were duplicating efforts over and over.

Operationalizing CCPA with automation requires companies to leverage existing IT security tools and other systems (e.g., SIEM, ticketing, data governance), which is why it’s critical to get buy-in from CTOs, CISOs, CPOs, and data governance teams from the very beginning in order to execute processes correctly the first time.

Taking the time to prepare and automate DSR fulfillment processes can help mitigate the onslaught of DSRs, which result in DoS attacks.

Coordinated Data Subject Requests

Through the use of social media, online networking platforms, and other less obvious sources, many data subjects can quickly and easily coordinate to submit DSRs on behalf of people who may or may not exist, all at the same time.

The most recent example of this was executed under GDPR law, when Blizzard Entertainment stripped the World of Warcraft Tournament Champion of his title after publicly claiming support for Hong Kong protesters, which triggered the gaming community.

Multiple gaming sites, and even Reddit posts like this, instructed angry gamers who were upset with Blizzard how to exercise their rights under GDPR Article 15. The weaponization of DSRs quickly caught on, and led to an influx of requests that was very difficult for Blizzard to manage.

Even for large organizations with robust processes and automated systems for managing DSRs, such a large number of coordinated requests are likely to have a lasting impact, as they tend to cause excessive and manual workload by clogging automated systems with complicated requests.

Not limited to large corporations, the coordinated DSR attacks will actually do more harm to smaller businesses that don’t have the resources to deal with the tidal wave of requests, but it’s important to note that even moderate levels of DSR traffic can overwhelm organizations if they’re not properly prepared.

DSR Automation Recommendations

The first step is to build an effective intake form for DSRs that are visible, have predefined requests that the data subject can select from, and can be automated to fulfill requests quickly. Automation tools also exist that can help businesses centralize requests in a single dashboard, automate notifications, track deadlines, and establish processes for individuals who are involved in each step of the workflow.

The second step is to ensure that identity verification techniques, congruent with the sensitivity of the data being requested, are prominently integrated at the very beginning of the DSR process. This action alone can weed out bad actors and bots attempting to flood business systems with requests. The more sensitive the data being requested (think: banking, insurance, healthcare, etc.), the higher the verification assurance should be for those submitting requests.

When it comes to preventing DoS attacks, manual DSR processes that require personnel to scan hundreds of systems for every request will simply not cut it. It’s a big data problem, especially when you consider that, in the DSR fulfillment process, duplicate data sets are the primary culprits for exposure of sensitive data to unnecessary parties. As such, additional recommendations to automate DSR fulfillment include:

  • Avoid creating additional copies of customer data
  • Reduce PI surface area 
  • De-identify but beware of toxic combinations
  • Comply with privacy and security-by-design principles
  • Prepare for a data subject request DoS attack

Want to learn more about how an automated DSR fulfillment process can help your company avoid DoS attacks? Click here to register for our webinar.

How [Integris/TrustArc/Evident] Helps

How Evident Helps

Evident’s Verified Data Request (VDR) DSR identity verification tool is helping businesses vet each request, distinguishing bad actors and bots from genuine individuals who want to access, delete, or opt out their personal data.

With connections to more than 6,500 authoritative data sources through a single API, Evident’s VDR is simplifying the identity verification portion of the DSR request workflow, enabling companies to corroborate a requester’s data points quickly, securely, and accurately, without ever returning “data subject not found” results.

In addition to supporting identity verification for DSR workflows, VDR also helps businesses demonstrate general privacy compliance through Evident’s asymmetric, end-to-end encryption, designed to protect each individual piece of personal data collected for verification purposes.


The TrustArc Individual Rights Manager solution is designed to help companies comply with regulations, minimize risk and build trust with customers. The solution enables individuals to easily submit DSARs and companies to efficiently manage, review, and follow-up in required timelines. In addition, the solution creates an audit trail that demonstrates accountability and compliance. 

TrustArc is the leader in privacy compliance and data protection solutions and offers an unmatched combination of innovative technology and TRUSTe certification solutions. TrustArc addresses all phases of privacy program management and has been delivering innovative privacy solutions for two-decades to some of the world’s largest companies. The TrustArc platform leverages deep privacy expertise and proven methodologies, which have been continuously enhanced through thousands of customer engagements. Headquartered in San Francisco, and backed by a global team across the Americas, Europe, and Asia, TrustArc helps customers worldwide demonstrate compliance, minimize risk and build trust.

How Integris Software Helps

Integris Software tackles one of the most challenging aspects of data subject requests (DSRs)– finding data subjects across your data ecosystem. Our discovery process isolates your systems that contain PI, then maps attributes, categories, purpose, and sources back to each data subject. By automating the discovery and classification of sensitive data, Integris reduces the burden on IT teams and data source owners. Deep Search and just-in-time identity matching make it easy for your customer service reps (CSRs) to verify and locate data subjects across thousands of systems. Integris DSR is enterprise ready and follows the principles of privacy- and security-by-design; there’s no need to replicate consumer data across network zones.

Privacy is now critical to an effective data protection strategy. By sitting upstream from security, Integris tells you what data is important and why so you can be precise in your InfoSec controls. Integris works securely, at scale, no matter where sensitive data resides. You get a live map of your sensitive data where you can apply policies, surface issues, fulfill DSAR requests, and automate remediations via your broader ticketing and InfoSec ecosystem. Regulations like GDPR and the California Consumer Privacy Act (CCPA) are triggering knee-jerk reactions as companies lock down their data for fear of misuse. With Integris, there is finally a way to use your data without fear.

Share This

Share this post with your friends!