Data Subject Request Considerations

March 1, 2020

The term ‘data subjects’ refers to the people who have shared their data –sensitive or otherwise –with your organization to enable some kind of processing, sharing, or transaction operations. These data subjects could be your customers and even your employees.

Data subjects are allowed to submit data subject access requests related to their data to know how and where their informationisbeing used. This is part of the customers’ right to know whether or not their information is being usedin a lawful manner as acceptable by regulatory bodies.

Here are some considerations you must keep in mind when dealing with data subject requests.

Where is the data located?

To address any kind of data subject request, you must know where the customer’s/employee’s data are stored. This is also important from the point of view of meeting industry standards and regulations. Thorough knowledge of storage locations will make the responses to these data subject requests more prompt. This will also increase the general visibility of your storage infrastructure.

How is the data requested?

Data subjects’ requests for gaining access to the shared data could be manual or automated. No matter how the requests are submitted, it is important that all data subjects are able to submit them as per their needs, and then receive the requested data promptly and accurately. This way, your organization will be complying with standards and regulations, while also using its resources judiciously.

Is the data correct?

You must also verify that the personal data provided by your customers and stored in your organization are all correct. You can automate the verification process when your organization is dealing with large amounts of data. This is important not only to meet standards but also to earn trust among your customers. Moreover, sharing private information of one customer with another, unauthorized customer by mistake is a violation of their privacy and, in many cases, of federal and state laws.

Is your data subject request handling team prepared?

The employees who are part of the team that is designated to receive, process, and respond to data subject requests must be trained for this job. All data subject requests need to be handled privately. The employees should be aware of the location and nature of data to respond to the requests promptly and correctly. They should understand the handling, privacy, and information security policies to the letter and be prepared to abide by them.

How efficient is your data access request-response system?

Your organization may get a large amount of data subject requests a day. Are your procedures efficient enough to deal with this volume of requests? Analyze and amend your current policies and procedures to make the response system more efficient. Consider automating the response system. Your organization must also maintain a history of all data subject requests coming their way. This will increase the visibility and transparency of your response system.

Conclusion

Your customers have the right to know what you do with their data. The next time your organization deals with data subject requests, make sure your team heeds the considerations mentioned above

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