Processing personal data has become part of nearly every organization’s day to day operations.
Collecting information about your customers helps improve products, refine marketing strategies, and strengthen customer relationships. But these opportunities come with some serious responsibilities.
The General Data Protection Regulation (GDPR) sets strict standards for handling personal data. Noncompliance can result in significant fines and reputational damage.
In this article, we’ll explain how data mapping can give you clarity into your organization’s data collection and data processing activities to help you to achieve GDPR compliance and make the most of the information you have on hand.
Key takeaways
- Data mapping gives a single view of personal data, including what it is, why it’s been collected, where it came from, who it belongs to, retention timelines, and lawful basis for processing.
- Though not named in the GDPR, data mapping is essential to operationalize RoPAs, DPIAs, DSARs, and breach notifications.
- Mapping should take place at the processing-activity level to document purpose, legal basis, storage, recipients, transfers, and consent to reduce your risk of fines.
- Mapping speeds up both DSAR retrieval by subject type and breach response, including 72-hour authority notice and timely user communication.
- Best practices: automate, link data to subject types, track cross-border and third-party flows, document security measures, and keep maps current.
What is data mapping?
Data mapping is the process of identifying, cataloging, and visualizing how data flows through an organization’s systems.
Once information is surfaced through data discovery or other means, data mapping helps teams understand where that information comes from, where it goes, how it’s used, and who has access to it.
A data map offers a clear picture of how user data moves through internal systems and beyond, including to third-party tools, partners, or processors. It should outline:
- The type of personal data collected
- The source of the data, such as forms, cookies, or application programming interfaces (APIs)
- The purpose of processing
- Where data is stored or transferred
- Who has access to it
- How long it will be retained
- The lawful basis for processing it
This visibility is crucial for staying compliant with many data privacy laws, including the GDPR.
Is data mapping necessary for GDPR compliance?
The text of the GDPR doesn’t explicitly mention data mapping, but the process is essential for meeting the regulation’s requirements.
It also makes it easier to fulfil the conditions for each of the processes we outline below, as data mapping gives you a clear view of what data you’re holding, where it’s stored, and where it’s going.
Record of Processing Activities (RoPA)
Art. 30 GDPR requires most organizations to maintain a clear and up to date Record of Processing Activities (RoPA).
This includes documenting what personal data you process and for what purpose, where it’s stored, how long it’s kept, who has access to it, and whether it’s shared with any third parties or sent across borders. The RoPA also needs to note whether consent has been obtained.
There are some nuances when it comes to the responsibilities of data controllers and data processors. Both have obligations, but the extent of the actions they must undertake differs.
Controllers must document the purpose and legal basis for processing, while processors need to outline what processing activities they carry out on behalf of the controllers they serve. Controllers do have legal responsibilities for the actions of contracted processors, however.
Failure to maintain proper records can lead to fines of up to EUR 10 million or 2 percent of annual global turnover, as per Art. 83(4)(a) GDPR.
Data mapping enables you to keep tabs on all of the information you gather and store, so it can help you to easily provide evidence of your processing activities and avoid fines and penalties.
Data Protection Impact Assessments (DPIAs)
According to Art. 35 GDPR, organizations must carry out a Data Protection Impact Assessment (DPIA) when the processing activities they intend to carry out are likely to pose a high risk for the data subjects’ rights and freedoms.
A DPIA involves evaluating:
- How data is collected, used, stored, and shared
- Potential risks that collecting, holding, and processing this data can create
- Safeguards that can be implemented to reduce those risks
For example, if a company includes biometric authentication as one of the login steps when employees access workplace systems, the sensitive nature of that data means it needs to be protected. Likewise, if a website monitors visitors’ location to measure the effectiveness of its ads, it can create risks that trigger the need for a DPIA.
These assessments help organizations to anticipate problems so that they can be proactive, implement strong protections, and build trust with their customers in the process.
Data Subject Access Requests (DSARs)
Under the GDPR, individuals are entitled to know what personal data an organization holds about them and how it’s used. This is one of the GDPR’s fundamental data subject rights.
When someone submits a data subject request, an organization is obligated to provide a copy of the relevant data, explain the purpose for processing it, outline who it’s shared with, and indicate the amount of time they intend to store it.
The specifics of what you’re required to share vary based on the type of data subject that makes the request. For example, employees can request access to HR files like payroll records, while customers can ask to see account information, and suppliers might want to get details about the contracts you have with them.
Generally, you have one month to respond to a DSAR. However, if the request is particularly complex, the timeline can be extended by another two months. Security is important with these requests as well, and companies need to verify the identity of any individual making a data request.
Notification of personal data breaches
Art. 33 GDPR requires organizations to notify the relevant supervisory authority of a personal data breach within 72 hours of becoming aware of it, unless the breach is unlikely to pose a risk to individuals’ rights and freedoms.
When the risk is high, Art. 34 GDPR applies and organizations must also inform the affected data subjects without undue delay.
For instance, if an employee laptop with access to information like customer addresses and payment details is stolen, the business would need to notify the authorities and inform the impacted customers.
Data mapping makes this possible by showing you exactly which types of data were stored on the device and which individuals are affected. This visibility reduces the time needed to figure out what information has been exposed, which can help you to meet the notification obligations within the specified timeframes.
5 GDPR data mapping best practices to help you achieve compliance
Well-executed data mapping can be the difference between struggling to achieve and maintain privacy compliance and successful GDPR implementation.
The best practices outlined below can guide you in building a data map that provides helpful visibility into your data flows and helps you satisfy regulatory obligations.
1. Automate data mapping with a purpose-built tool
Manually tracking how personal data flows across systems is not only time-consuming, it can also be inaccurate.
Purpose-built GDPR data mapping software can streamline this process by automatically cataloging data sources, mapping transfers, and keeping records up to date. This reduces the risk of oversights and frees up teams to focus on higher-value privacy initiatives.
Automation also makes it easier to demonstrate compliance, since the data map the software produces can be used as evidence of your fulfillment of the requirements for RoPAs, DSARs, DPIAs, and other activities.
2. Map data at the processing activity level
Building your map around processing activities, rather than around isolated data points, is one of the most effective ways to align your data mapping process with GDPR requirements.
Doing so will enable you to mirror the structure of the RoPAs required under Art. 30 GDPR, by capturing not only what data you hold, but also why you collect it and how you use it.
By starting at the processing activity level, you can create a consistent framework that directly connects to the regulation’s obligations. This also makes updates more manageable, since changes to a process can be reflected simultaneously across all associated data records.
3. Link data elements to data subject types
Effective data mapping requires more than simply listing the information that you hold. You also need to connect each data element back to the type of data subject that it relates to, such as customers, employees, or suppliers.
This link gives you a clearer picture of the personal data processing activities you’re undertaking, including whose data is being processed and for what purpose. This can also influence your selected legal basis for processing under the GDPR, and necessary resulting actions.
This is also particularly valuable for managing DSARs. When a request comes in, having your data elements linked to your data subject types enables you to quickly pull all relevant records associated with that individual’s category.
4. Track data flows across borders and systems
Personal data can only be transferred outside of the EU/EEA when data controllers or processors have implemented adequate safeguards. There need to be adequacy agreements or mechanisms like Standard Contractual Clauses between the countries where data is flowing.
To meet the GDPR’s requirements, organizations need to have visibility into exactly where data travels and which systems handle it. Data mapping provides that visibility by showing you where data flows across internal platforms and external partners, and highlighting if or when it leaves these regions.
5. Document technical and organizational security measures
The GDPR requires organizations to implement and document appropriate technical and organizational security measures to protect the personal data they collect. These measures must be proportionate to the risks associated with data processing.
This might include encrypting your personal data inventory, implementing access controls, training staff around data privacy best practices, and undergoing regular audits to verify data security.
Data mapping can help you to establish where personal data is stored, how that data flows through your business and beyond, and which security measures are in place. Having these clear records can make it easier to respond to data breaches and meet the obligations of the GDPR.
Handle data responsibly and achieve GDPR compliance
Mapping the personal data that your organization holds brings transparency to your data collection and data processing practices and clarifies how data flows across your and your partners’ systems.
Data mapping for the GDPR is not a one-time task. Ongoing oversight is necessary to get the information you need to fulfill regulatory obligations, including responding to requests and notifying data subjects of any data breaches.
Thankfully, the right partner can make this journey much easier. Usercentrics CMP helps you create transparency around your data collection and handling processes so your customers and the relevant authorities know how you manage the personal information you collect.
When combined with effective data mapping, Usercentrics gives you the tools you need to achieve and maintain GDPR compliance and build trust with your audience.
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