Sep 13

Creating a Sustainable Data Subject Requests Routine: From Handling Requests to Continuous Improvement

Organizations nowadays are processing vast amounts of personal data, thus making the importance of having an efficient process in place for handling individuals’ Data Subject Requests (DSRs) paramount. Not only is it a critical aspect of GDPR compliance, but it also enhances an organization’s reputation for taking data protection seriously.

This blog post highlights fundamental steps to create a sustainable DSR routine and continuously improve the process.

From Understanding to Creating DSR Points of Contact

The first step in this journey involves understanding and creating DSR points of contact. GDPR empowers individuals to inquire about their personal data held by an organization, rectify inaccurate information, erase their data and more. These points of entry may include emails, website forms, phone calls, or social media channels, emphasizing the importance of user-friendly processes and clear instructions. It is important to note that an organization cannot force individuals to use a channel or form for initiating a DSR. DSRs made in other ways or forms are still valid requests that need to be complied with.

Training and Deciding on Ownership

Providing employees with comprehensive training on how to detect DSRs, whom to escalate them to, and assigning ownership to the request ensures that it is met with swift action. Elizabeth Smith, a renowned Data Protection Officer, recommends that teams involved in handling DSRs should receive increased training to equip them with the necessary responses for different types of DSRs.

Leveraging System Knowledge and Streamlining Data Extraction

To comply with DSRs, it is essential to undertake data mapping and have proficient knowledge of the systems and databases where personal data is stored. A Record of Processing Activities (RoPA) can facilitate the identification of where to search for an individual’s data.

Ensuring Compliance Through a DSR Register

Maintaining a DSR register that tracks the progress of each request and its response time within the GDPR-compliant 30-day time limit promotes transparency and efficiency in the DSR process and provides an audit trail to be able to demonstrate accountability.

Enhanced and Sustainable DSR Processing

By stress-testing the process and identifying and rectifying any weaknesses during these tests, along with having a plan in place to deal with identity verification, excessive or repetitive requests and revealing documents that include information on other individuals, organizations can create a robust and sustainable DSR routine.

A sustainable DSR routine is more than just compliance with GDPR; it demonstrates an organization’s commitment to data protection, adding to its credibility and reputation. By implementing these steps, organizations can efficiently handle DSRs, meet GDPR requirements, and foster a culture of continuous improvement.

For further insights on building a sustainable DSR routine and fostering a culture of continuous data protection improvements, explore our related blog posts here.

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