Data mapping under the EU GDPR
Under Article 30 of the EU GDPR (General Data Protection Regulation) organisations need to have documentation of their data processing activities. The best way to create this documentation, is to map your data flows. This is also an essential first step for completing a DPIA (data protection impact assessment), which is a mandatory risk assessment for certain types of processing.
It is also an essential first step for completing a data protection impact assessment (DPIA), which is mandatory for certain types of processing.
The key elements of data mapping
To effectively map your data, you need to understand the information flow, describe it and identify its key elements.
1. Understand the information flow
An information flow is a transfer of information from one location to another, for example:
- From inside to outside the European Union; or
- From suppliers and sub-suppliers through to customers.
2. Describe the information flow
- Walk through the information lifecycle to identify unforeseen or unintended uses of data. This also helps to minimize what data is collected.
- Make sure the people who will be using the information are consulted on the practical implications.
- Consider the potential future uses of the information collected, even if it is not immediately necessary.
3. Identify its key elements
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Data items
What kind of data is being processed (name, email, address, etc.) and what category does it fall into (health data, criminal records, location data, etc.)?
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Formats
In what format do you store data (hardcopy, digital, database, bring your own device, mobile phones, etc.)?
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Transfer method
How do you collect data (post, telephone, social media) and how do you share it internally (within your organization) and externally (with third parties)?
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Location
What locations are involved within the data flow (offices, the Cloud, third parties, etc.)?
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Accountability
Who is accountable for the personal data? Often this changes as the data moves throughout the organization.
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Access
Who has access to the data in question?
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Lawful basis
Identify the lawful basis used for processing the personal data.