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How do you map your data flows and identify privacy risks?

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If you handle personal data in your organization, you need to map your data flows and identify privacy risks. This is not only a good practice for data management, but also a legal requirement for compliance with data protection laws such as GDPR or CCPA. In this article, you will learn how to create a data flow map and a data privacy audit checklist to assess and mitigate the potential risks of data processing.

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Charles Gretton

Privacy Officer Support | Fractional DPO Services | GDPR Consultancy | EU/UK Art. 27 Rep | DSAR Response | DSPT | AIA &…

1 What is a data flow map?

A data flow map is a visual representation of how data moves within and outside your organization. It shows the sources, destinations, transfers, and storage of personal data, as well as the roles and responsibilities of the data controllers and processors. A data flow map helps you to understand the scope, purpose, and context of your data processing activities, and to identify any gaps or vulnerabilities in your data protection measures.

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Charles Gretton

Privacy Officer Support | Fractional DPO Services | GDPR Consultancy | EU/UK Art. 27 Rep | DSAR Response | DSPT | AIA & AI Explainability
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Data flow maps are generally one of the first steps in a data protection compliance build. You can't give advice, or attempt to explain to data subjects how you're using their data until you yourself understand how that data is being processed.

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2 How to create a data flow map?

Creating a data flow map requires you to identify the personal data collected, used, shared, and stored, define the data processing activities and their legal basis, map the data flows and data lifecycle, and document the data controllers and processors involved in each data flow. This includes any data that can directly or indirectly identify a person, such as name, email, phone number, IP address, location, preferences, etc. You should explain why and how you use personal data and what legal grounds you have to do so. Additionally, you can use symbols, colors, or labels to indicate the type, format, and sensitivity of the data as well as the encryption, anonymization, or pseudonymization techniques applied. Lastly, you should identify who is responsible for deciding and carrying out the data processing activities and what agreements or contracts exist with them. Note if any of the data flows cross international borders or involve third parties outside your organization.

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Charles Gretton

Privacy Officer Support | Fractional DPO Services | GDPR Consultancy | EU/UK Art. 27 Rep | DSAR Response | DSPT | AIA & AI Explainability
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In creating a flow map, remember the advantage of having one. The purpose is to make the flow simpler to understand and easier to communicate - don't overcomplicate it! Visio & Lucid Chart are both easy to use, I'd recommend either for privacy pros.

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3 What is a data privacy audit checklist?

A data privacy audit checklist is a tool to evaluate and improve your data protection practices based on the data flow map. It helps you to identify and prioritize the privacy risks associated with your data processing activities, and to implement appropriate measures to reduce or eliminate them. A data privacy audit checklist also helps you to demonstrate your compliance with data protection laws and regulations, and to respond to any data breaches or requests from data subjects.

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Charles Gretton

Privacy Officer Support | Fractional DPO Services | GDPR Consultancy | EU/UK Art. 27 Rep | DSAR Response | DSPT | AIA & AI Explainability
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IMO: Checklists are totally worthwhile in streamlining to high-impact discussions around gaps, and digging down deeper during audit interviews, but not fit for purpose in being the sole source of truth. Data protection compliance isn't Cyber Essentials.

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4 How to create a data privacy audit checklist?

Creating a data privacy audit checklist requires following certain steps. First, review the data flow map and identify the privacy risks, such as the potential impact and likelihood of any harm or loss that may result from data processing activities. Assessing the privacy risks is also necessary, assigning a score or a level to each risk based on severity and urgency, and deciding which actions are needed to address it. Lastly, implement the actions and monitor the results, executing the planned actions to mitigate or eliminate the privacy risks and measuring the outcomes of data protection measures. It's important to document the actions and results, as well as updating your data flow map and checklist.

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5 How to maintain your data flow map and data privacy audit checklist?

Creating a data flow map and a data privacy audit checklist is not a one-time project, but an ongoing process. You need to maintain and update your data flow map and your data privacy audit checklist regularly to reflect any changes in your data processing activities, such as new data sources, purposes, or transfers, or new data protection laws or regulations. You should also review and test your data protection measures periodically to ensure they are working properly and efficiently. By maintaining your data flow map and your data privacy audit checklist, you can ensure that your data management is aligned with your business goals and your legal obligations.

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6 Here’s what else to consider

This is a space to share examples, stories, or insights that don’t fit into any of the previous sections. What else would you like to add?

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How do you map your data flows and identify privacy risks?

1

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3

4

5

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1 What is a data flow map?

2 How to create a data flow map?

3 What is a data privacy audit checklist?

4 How to create a data privacy audit checklist?

5 How to maintain your data flow map and data privacy audit checklist?

6 Here’s what else to consider

Data Management

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How do you map your data flows and identify privacy risks?

1

2

3

4

5

6

1 What is a data flow map?

2 How to create a data flow map?

3 What is a data privacy audit checklist?

4 How to create a data privacy audit checklist?

5 How to maintain your data flow map and data privacy audit checklist?

6 Here’s what else to consider

Data Management

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