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Data Inventory and Mapping to Support Privacy Compliance

Annie Greenley-Giudici

Improve Privacy Compliance with Data Mapping

Any business that collects data needs to ensure its privacy compliance is right.

But if you don’t know the type of data you collect and how it’s shared, processed, and stored, it is hard to know if your organization’s use of data is compliant with privacy rules – let alone have the right answers for audits or individual data subject access requests.

One of the most important steps to designing and building a privacy compliance program is to build a data inventory. Begin by mapping all the personal data processing activities within your organization.

Data Mapping is About Matching Information for Easier Management

Most organizations collect more data than they know what to do with. If your business wants to get more value from the data it collects – and meet privacy compliance – you need to know more about where this information is managed:

  • Find all sources of data – Find out every source of data your business has access to – internally and externally – and identify what information is held in each database
  • Map the flow of data – Once you know all the different data sources, you can create data flow maps of all the processes and systems the data moves through. Where it starts, all the points it is processed and analyzed, and where it is stored. Multiple versions of similar data are likely stored in multiple locations
  • Match similar information – The data mapping process focuses on matching fields in different databases, making it easier to combine this information into a central inventory for better management
  • Build and manage a central data inventory – When you have reliable data flow maps and data mapping processes set up, you can migrate and integrate valuable data into a central inventory for better management.

Privacy Compliance Relies on Good Data Management

Data mapping is not a once-a-year process – it needs to be done regularly so your organization’s data inventory records are accurate and up-to-date.

As privacy and data protection regulations expand, organizations need to show how they reduce and manage risk. So it’s important you can find the right information in your data inventory on demand.

For example, risk management and compliance reporting for the EU General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA) will rely heavily on a comprehensive data inventory.

Likewise, organizations need fast access to accurate and current personal data they hold to properly answer data subject access requests.

Data Inventory Needs to be a ‘Living Record’

Once your organization’s data processing flows have been recorded and reviewed for risk, you can make better-informed decisions about where to invest resources based on where the highest risk lies.

While the word ‘inventory’ might suggest a static list at a point in time, a data inventory for privacy compliance should be a ‘living record’ of how personal data moves throughout your organization’s systems and business processes – and changes over time.

Automated Data Mapping Streamlines Management and Compliance

There are three main ways you can handle data mapping in your organization:

  1. Manual data mapping – have your data professionals create templates and write code for processes to connect and document all data sources to the central data inventory. It can be very hands-on and time-consuming, tying up your data team – and they’ll need excellent coding skills.
  2. Semi-automated data mapping – use a tool for data mapping (or ‘schema mapping’) to find and create connections between data sources and target schema at the heart of your central data inventory; then have your data professionals check the work done by the tool and manually adjust or fix it. Potentially resource-intensive, this approach relies on data professionals with solid coding skills.
  3. Automated data mapping – use a full automated data mapping platform to do all the heavy lifting, such as integrating, migrating and organizing data in a central inventory. The platform will include tools for people who aren’t data professionals so they can map data and schedule regular updates to capture changes. This approach streamlines multiple processes by automating them, and makes reporting easier, especially for data privacy compliance.

5 Best Practices for Building a Data Inventory

TrustArc’s privacy experts have helped many businesses get up to speed with data mapping, privacy compliance and managing their data inventory.

Here are the expert’s recommended best practices for building a data inventory:

  1. Design a scalable data inventory – Remember all data inventories need to be updated regularly, so designing a scalable and repeatable process up front can save time and cost later
  2. Train data management subject matter experts – Even if your organization takes the full-automated approach to data mapping and inventory management, it is important to train team members so they understand any compliance requirements driving the data inventory, and what to expect from the process
  3. Launch a pilot program – Start small with one functional area or region so your organization can learn from a more controllable experience, learn ways to improve data management and build on that knowledge and experience to expand into other parts of the business
  4. Think outside the (server) box – Remember data can flow in a variety of ways and media. Don’t forget to capture records from printed copies of documents, video files, tape recordings and other non-electronic formats
  5. Track all data mapping tasks – A data inventory is a powerful tool that will not only meet some compliance requirements directly, but also help in other important activities such as:
  • incident response
  • individual rights requests
  • assessing risks and triggers for data protection impact assessments
  • identifying and solving cross-border data flow issues (including customizing security and privacy protections as needed).

Help your organization with data mapping privacy compliance

TrustArc understands the challenges organizations face with data mapping, including creating and building a data inventory and data flow maps that support privacy compliance.

We’re here to help you solve these challenges by making the work of data management easier.

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