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Data discovery explained: best practices for GDPR compliance

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Summary

Every time someone interacts with your business, whether by placing an order, signing up for a service, or even browsing your website, they’re likely sharing personal data. 

The General Data Protection Regulation (GDPR) has strict requirements around how this information should be handled, and the responsibility of meeting these standards falls squarely on your organization.  

Data discovery can be a powerful tool here. It enables you to uncover and organize data in a way that helps you to meet compliance requirements, be transparent with your customers, and draw meaningful insights to drive marketing strategies.

We’ll walk you through all of the GDPR data discovery basics, outline why the process matters, and share practical steps you can take to implement it effectively across your organization.

What is involved in data discovery?

  • Data discovery gives organizations full visibility into what personal data they hold, where it is stored, who has access to it, and how it flows across systems.
  • A structured data discovery process is essential for meeting GDPR obligations around transparency, accountability, and processing records.
  • Identifying, classifying, and minimizing data helps strengthen security, reduce compliance risk, and cut unnecessary storage costs.
  • Effective data discovery extends beyond internal systems to include third-party vendors that process or store personal information.
  • Continuous monitoring and automated tools make GDPR data discovery sustainable, audit-ready, and adaptable as new data is collected.

Data discovery is a method for identifying and categorizing data held across multiple tools and systems to make it useful. 

The process provides insight into exactly what data you keep; how and where it’s used, stored, and processed; as well as how it travels within and beyond your organization. This visibility can help you to build and maintain accurate data stores, analyze them, and gather insights that can help you make better business decisions. 

Think about when a customer makes a purchase on your website. They have to provide their name and credit card information, possibly also email and mailing address, and you also likely collect their IP address and some behavioral data. 

This single event has the potential to create a virtual mountain of data that could be stored in a variety of digital places.

To effectively discover this data, you need to take inventory of your digital assets and map out the flow of the information across your systems. This can involve scrutinizing structured databases, unstructured data sources, cloud storage platforms, archives and backup files, and other platforms.

What is data discovery in data privacy?

Data privacy focuses on protecting personal information from misuse, unauthorized access, or loss. It exists to safeguard individuals’ rights, reduce the risk of data breaches, and as a result, build trust with data subjects.

In this context, data discovery refers to the process of proactively scanning your organization’s data sources to identify where personal or sensitive data is stored. It often involves tagging or classifying data based on its type and sensitivity, which makes it easier to manage and protect.

By giving you a clear view of what information you hold and where it lives, data discovery strengthens your ability to maintain comprehensive privacy practices that align with the requirements of data privacy regulations, partner platforms’ policies, and other critical frameworks.

What is data discovery for the GDPR?

When we talk about data discovery in the context of the GDPR, we’re focusing on identifying, organizing, and documenting all of the personal data your organization processes in order to meet GDPR obligations. 

This process, often referred to as GDPR data mapping, is central to achieving GDPR compliance. The visibility it provides lays the groundwork for transparency and accountability.

Key elements of data discovery for the GDPR include:

  • Identifying personal data: Pinpoint where everything is stored that’s considered personal data, e.g. names, email addresses, IP addresses, and behavioral profiles,, including in databases, file systems, cloud storage, and other data repositories.
  • Data classification: Tag and categorize personal data by type, e.g. sensitive or special data, and risk level so you can implement the appropriate security measures and access controls.
  • Map data flows: Understand and document how personal data moves within your organization’s systems, who can access it, and where it’s shared or transferred to third parties.
  • Continuous compliance efforts: Maintain accurate and up to date Records of Processing Activities (RoPAs) to keep your organization audit-ready and capable of fulfilling data subject access requests (DSARs).

Data discovery not only helps your organization to maintain ongoing GDPR compliance, but also prepares you to respond quickly to subject access requests, conduct risk assessments, and manage consent effectively. 

Why is data discovery important for GDPR compliance?

Thorough data discovery streamlines the path to GDPR compliance. By knowing exactly what personal and sensitive data you hold and where it lives, you can reduce complexity, close compliance gaps, and respond to DSARs more quickly.

Protecting personal data

One of the primary benefits of data discovery is the ability to protect sensitive information more effectively. By identifying and classifying personal data, organizations can determine which datasets require heightened safeguards, such as encryption, strict access controls, or data anonymization

For example, special category data under the GDPR — like health records, biometric identifiers, or details about someone’s religious beliefs — requires stronger protection than basic contact information. 

Take a proactive approach here — which is also legally required with sensitive data — to help safeguard your data processing activities, prevent unauthorized access, leaks, and breaches by matching your data security measures to the sensitivity of the data.

Responding to data subject access requests

The GDPR gives individuals, also known as data subjects, the rights to access, correct, or request the erasure of their personal data. It also stipulates that organizations must fulfill valid requests within one month of receiving them in most cases. 

Meeting this deadline can be difficult without effective data discovery and mapping. Relevant information may be buried across multiple systems, stored in a range of formats, or held by specific departments. 

Maintaining a clear, up to date data map enables organizations to quickly locate, verify, and provide the requested records in a usable format, which reduces delays and errors.

Meeting transparency requirements

The GDPR places a strong emphasis on transparency, and requires organizations to clearly explain how personal data is collected, used, and stored. Data discovery helps by giving you a complete view of your data processing practices, from collection points to storage locations and data access controls. 

Besides helping to demonstrate compliance to relevant authorities, you’ll also gain insights that support informed decision-making, reduce risks, and build trust with customers and stakeholders.

Demonstrating compliance

Accountability is a core principle of the GDPR, and organizations need to be able to prove that they’re complying with the law.

That means maintaining accurate records of where personal data is stored, how it’s processed, and who has access. These records provide tangible evidence of your regulatory compliance, including adherence to principles like data minimization, which is invaluable during audits or investigations. 

The ability to demonstrate these proactive measures not only reduces legal risk, but also reinforces your commitment to protecting individual privacy.

How do you achieve GDPR data discovery? 5 best practices

Using data discovery to achieve GDPR compliance requires a structured, consistent approach. Below are five practical strategies that will help you better manage personal data to meet the law’s stringent requirements.

1. Use specialized tools to automate the process

While manual reviews still have their place, particularly for verifying sensitive records, automation is the backbone of efficient GDPR data discovery. 

Specialized data discovery tools like data mapping software can scan large volumes of information across databases, cloud storage, and third-party systems much more quickly than any human team. 

Take an ecommerce business as an example. Each purchase generates multiple data points: customer names, shipping addresses, payment details, order histories, and IP addresses. 

Without automation, data discovery could take days or weeks. With the right automated data discovery tools, that mapping can happen in hours. It will provide a clear, actionable view of your data management landscape while reducing the chance of human error.

2. Identify and classify different types of data

Once you know where your customers’ data is, you’ll need to categorize it based on how sensitive it is and the legal basis for processing it. 

This includes identifying special category data, like health information or biometric data, alongside other classifications like employee records, customers’ personally identifiable information (PII), and transactional data. Each category has different handling requirements, security needs, and rules for storing.

Let’s return to the ecommerce business example. The checkout process alone may require customers to provide several categories of data, including PII like names, mailing addresses, and email addresses. At the same time, an ecommerce business is likely also collecting behavioral data like purchase history or browsing patterns.

Classifying this data at the source means you’ll know which elements call for additional security measures and what legal basis applies to each. It’s then far easier to meet GDPR requirements for each data type.

3. Recognize redundant data and delete where relevant

Art. 5 GDPR outlines the principle of data minimization. It states that you should only store personal data that’s necessary for the purpose for which it was collected. Returning to our ecommerce example, if a customer purchased an ebook, you wouldn’t need a mailing address (though you would need a billing address to accompany the credit card details). 

You also shouldn’t retain data any longer than needed to fulfill the stated purpose. If someone made a one-off purchase from your ecommerce site eight years ago and hasn’t returned, there is little need to maintain their information. Even the requirements of financial regulations have time limits.

Removing redundant records not only strengthens compliance but can also reduce storage costs and security risks. For instance, consider ecommerce customers who make multiple purchases using a guest checkout. 

If a customer checks out as a guest, i.e. without creating an account, each transaction they execute might create duplicate records of information like their name, email address, and shipping address. 

Over time, this process would increase the volume of personal data you’re responsible for protecting. By identifying and removing redundant entries, you streamline your systems, cut unnecessary storage expenses, and lower the risk surface for breaches, all while staying aligned with GDPR requirements.

4. Investigate and audit third-party processors 

Under the GDPR, data controllers are responsible for ensuring that third-party processors handle personal data in line with legal requirements. This means your data discovery process can’t stop at your own systems; it must extend to any external vendors who store, process, or access your customers’ information.

In the context of an ecommerce website, this could include payment gateways, fulfilment partners, marketing platforms, or customer support tools. Each of these processors may hold personal data, such as customer names, addresses, order histories, or payment details. If they mishandle it, your business could be held accountable.

To gain a complete picture of where personal data lives, include third-party processors in your data discovery efforts. Audit their security measures, review data handling policies, and map their role in data flows. 

Doing so reduces compliance blind spots, aids you in implementing strict access controls, and helps ensure that everyone in your supply chain upholds the same privacy standards.

5. Establish a regular cadence and practice continuous monitoring 

Just like GDPR compliance, data discovery is not a one and done exercise. Your organization is most likely constantly collecting new information, updating customer records, and integrating with additional systems that need to be mapped.

Without a regular review process, it’s easy for gaps to form, records to become outdated, and compliance risks to grow unnoticed. 

Think about seasonal peaks in ecommerce selling. These busy periods bring an uptick in new customer data. If this data isn’t consistently mapped and classified, duplicate entries or unsecured datasets could slip through.

By setting a defined cadence, whether monthly, quarterly, or aligned with major campaigns, you can keep your data maps accurate and flag changes in real time. This can help you maintain visibility and act quickly if risks arise to align your data inventory with GDPR requirements.

Data discovery is far more than just a box to tick for GDPR compliance. It’s your foundation for knowing exactly what personal data you hold, how it moves, and how to protect it. By making it part of your ongoing operations, you can reduce risks, improve transparency, and increase customer trust. 

Cleaner, more up to date, and comprehensive data also enables better insights to drive marketing strategies like personalization.

Usercentrics provides a comprehensive privacy compliance platform so your business can obtain GDPR-compliant consent for processing of personal data, and use consent preferences to control its use among your martech stack. 

It also securely stores comprehensive consent records as part of your data mapping strategy, which are easy to provide upon request. The Usercentrics CMP’s automated functions also customize consent banners by jurisdiction so you manage the right data the right way around the world. Plus regulatory updates keep your consent management up to date as laws change.

Achieve and maintain GDPR compliance

Manage user consent and stay up to date with evolving GDPR requirements with Usercentrics.

Celestine Bahr
Director Legal, Compliance & Data Privacy, Usercentrics GmbH
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