How to Map Data Flows

Privacy Compliance
August 10, 2022
Mapping data flows is a complex but rewarding process when it comes to GDPR compliance.

How to Correctly Map Data Flows for your Organization

GDPR compliance is very important for businesses that deal with sensitive consumer personal data and information of EU residences. Understanding how to map data flow within an organization is an important part of GDPR compliance. Many privacy specialists view data mapping as a crucial part of GDPR compliance. It is frequently one of the first actions done. 

However, there is also often some misunderstanding over what privacy specialists mean by a data map and its compliance significance.

One of the key requirements under the GDPR is that an organization understands and knows all of the data that they process. This includes knowing what they intake, where it goes, how it is handled in the organization, and then how it is deleted or stored afterward. To fulfill this expectation, many organizations choose to create a data flow map. Mapping a data flow shows all of the places where data flows throughout the organization, including all the parties to who it flows.

This can be a complex process to go through. In this guide, we’ll break down some steps and tips for Data Protection Officers that are looking to map their data flows the right way.

How to Properly Map Your Data Flows

     1. Understand Why Data Mapping Is Important for GDPR Compliance.

Many companies are required by GDPR Article 30 to keep a written record of their data processing operations, and even those that are not obligated to do so should nonetheless do so as a best practice. One method used by businesses to produce the necessary textual documentation is a data map. The creation of a data map is one piece of information that would assist in satisfying the supervisory authorities' request for records of the processing operations within an organization.

Data maps can also play a significant role in Article 6. According to GDPR, every instance of processing personal data must have a lawful basis. Organizations must determine which reason for processing applies, inform consumers of it as part of their privacy policy or other disclosures, and make sure that the necessary paperwork is produced. This is significantly more challenging  if they do not maintain a list, or "map," of all of their processing. It is also simpler for businesses to defend their processing or decide that it needs to be modified after a list of processing has been created.

The purposes of the processing, the categories of personal data involved, the categories of recipients, any transfers of personal data to a third country or an international organization, the duration of data retention for each category, and, if possible, a general outline of the technical and organizational security measures in place must all be documented by data controllers

Any transfers to a third country or international organization must include documentation of the appropriate safeguards in place, and processors must keep records of the contact information for each controller, the categories of processing carried out for the processor, any such transfers to a third country or international organization, and a general description of the technical and organizational security measures used.

     2. Start the Data Flow Mapping Process

Understanding the flows of the data, describing it, and identifying its essential components are all necessary before you can map it effectively. Utilizing the information within your Data Protection Impact Assessment (DPIA) will be extremely helpful in this process as well. 

The movement of information from one place to another is referred to as information flow, make sure to recognize that piece first. The flow may occur from within the European Union to outside of it, or it may start with suppliers and subsuppliers and end with customers.

Describe the information flow after that. To find unplanned or unintended applications of data, go through the information lifecycle. Ensure that the information's users are consulted on any practical implications. Even if they are not immediately required, think about how the information collected may be used in the future. This process additionally helps to lessen the amount of data that is collected.  

Next, pinpoint all essential components, which may include the following:

  • Items of data - What sort of data is being processed, and what classification does it belong to?
  • Location - Which sites, such as offices, the Cloud, outside parties, etc., are engaged in the data flow?
  • Accountability - Who is responsible for the personal information? As the data travels around the company, this frequently changes.
  • Accessibility - Who has access to the aforementioned data?
  • Lawful basis - Determine the legal justification for handling personal data.
  • Formats - What format do you use to store your data? Are there physical copies, digital files, databases, BYOD options, mobile phones, etc.?
  • Method of transfer - How do you get data and disseminate it both internally and externally?

     3. Begin Creating Your Data Flow Map

Start by outlining the extent and goals of the processing. Every stage of each process in your organization should be documented, together with information on who performs each step and what resources are employed.

Add personal information to a flowchart of each process' data. Start your data flow diagram by noting which specific processes deal with personal data. The supporting resources utilized to process personal data should then be included. Identify the hardware, software, or processes that are utilized to process personal data.

To illustrate the data flow between assets, add data transfers after adding your supporting assets. Mark the direction of data flow between assets, specifying the types of data that are exchanged and the means by which they are done.

Review the procedure to complete your map. View and print reports to share with stakeholders. Every time a process modification is made, update the process map and specifics.

     4. Understand the Challenges of Data Mapping for GDPR Compliance

When starting the data mapping procedure, there will be certain difficulties. Personal information can be kept in a variety of places and media, including paper, electronic, and audio. Choosing what information to record and in what format is your first difficulty.

From there, you may have trouble choosing the right organizational and technical precautions. You must decide who has access to the information and how to keep it safe. You must decide on the best technology, as well as the use guidelines and policies, in order to do this. 

If you need guidance along the way, consult the GDPR experts that you are working with. And if you do not have any GDPR compliance consultants or a software solution in place, try Accountable free today! We provide the guidance that you need to simplify GDPR today.

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