GDPR Data Mapping: What it is and How to Comply?

On the 25th of May 2018, the EU enforced the General Data Protection Regulation (GDPR)—a comprehensive data protection law that dictates how companies collect and process personal data. 

GDPR compliance is mandatory for any business operating in or targeting users in the EU. Non-compliance may attract severe penalties, including fines of up to 4% of the company’s global turnover or 20 million euros, whichever is higher.

To ensure compliance with the GDPR, you must first identify and visualize how data flows through your organization. This process, known as GDPR data mapping, is critical for identifying potential compliance issues. 

In this article, we’ll be outlining everything you need to know about GDPR data mapping, from its definition to practical use cases, and discuss some key challenges in implementing GDPR data mapping.

What Is Data Mapping for GDPR?

Data mapping is a systemic approach that involves identifying, categorizing, and documenting how data moves within and outside an organization. This critical process allows companies to consolidate information from multiple sources, providing a clear and comprehensive view of how data is handled across different departments and systems.

Data mapping is an essential foundational element in achieving GDPR compliance. It ensures that your company can accurately track the journey of personal data, from its entry point to its exit. This visibility is crucial not only for maintaining up-to-date records of processing activities (RoPA) but also for managing data subject access requests (DSARs). These requests are a core aspect of GDPR, allowing individuals to inquire about what personal data is held about them, how it is used, and to request corrections or deletion.

By documenting all data flows, your company can ensure compliance with GDPR’s accountability principle, which mandates that organizations must not only comply with this regulation but also demonstrate your compliance through clear and auditable records. This level of documentation helps in preparing for potential audits by regulatory authorities and builds trust with your customers by showcasing a commitment to data protection.

Benefits of Data Mapping in GDPR

Below are some of the key benefits of data mapping for GDPR:

1. Ensures GDPR Compliance

Data mapping is integral to maintaining a RoPA, as required by GDPR. This process aids businesses in identifying data, understanding its processing purposes, and establishing all legal bases for these activities. Such comprehensive documentation is crucial for demonstrating compliance during audits.

2. Mitigates Risks

By creating a detailed data map, organizations can pinpoint where data resides and how it flows through their systems. This visibility allows them to identify vulnerabilities and enhance their security measures accordingly. Additionally, mapping personal data facilitates the implementation of risk-based controls tailored to the sensitivity of the data, significantly reducing the likelihood of unauthorized access.

3. Identifies Security Opportunities 

Data mapping in GDPR serves as a security roadmap that helps discover potential security gaps within the flow of personal data throughout an organization. It enables organizations to implement stricter security protocols to safeguard sensitive personal data, particularly during data transfers. 

4. Provides Insight into Your Data Landscape

With data mapping, businesses can get a comprehensive view of the entire lifecycle of personal data within their organization. It gives you insight into the data collection process, like what data is collected, how it is used, where it is stored, and for how long it is stored. 

This understanding is vital for managing data privacy practices effectively, ensuring control over all systems involved in data processing.

Use Cases of Data Mapping in GDPR

This section outlines some of the common use cases of data mapping in ensuring compliance with GDPR data protection laws:

1. Record of Processing Activities 

As stipulated in Article 30 of the General Data Protection Regulation, every data controller and processor must maintain a RoPA. It is the documentation of your organization’s record of processing that involves collecting and managing personal data. 

Data mapping facilitates the comprehensive collection and ongoing maintenance of this information, helping organizations document the categories of data they process, the purposes of processing, the recipients of the data, and the storage duration of the data. 

2. Data Breach Management 

According to Article 33 of the EU GDPR, data controllers are required to notify the supervisory authority in case of a personal data breach within 72 hours after becoming aware of it. 

Data mapping enables companies to swiftly assess the impact of data breaches and the associated risks to the rights and freedoms of the data subjects. It also helps organizations get information about the nature of the data breach, the categories, and the approximate number of personal data affected by the breach—all of which are important information for effective communication with supervisory authorities or affected individuals. 

3. Data Protection Impact Assessments (DPIA)

Article 35 of GDPR mandates that organizations conduct data protection impact assessments (DPIA) whenever data processing is likely to result in a high risk to the rights and freedom of individuals. 

DPIA is a methodology employed to identify, mitigate, and minimize the potential risks and impact of the rights of privacy and data protection due to the processing of personal data.

Conducting DPIA requires data mapping. This is because DPIA requires organizations to have proper documentation of the types of data they are collecting, when and how the data is being collected and used, where they are storing the data, and how data moves within and outside the organization. 

4. Data Subject Access Requests (DSARs)

GDPR’s Article 15 gives data subjects access to request from an organization a copy of all the personal data they have about them. Data subjects can also request details about how their data is processed.

Data mapping helps organizations create systems that allow them to easily locate and retrieve this data and respond to the DSARs promptly.

What are the key challenges of Data Mapping in GDPR?

Here are some of the major challenges you can encounter in data mapping in GDPR: 

1. Data discovery & data collection

A fundamental aspect of data mapping is collecting personal data from different sources within an organization. Data assets can be housed in multiple data sources like the cloud, on-premise, SaaS software, or even physical documents. Consolidating all this information onto a single platform can be complex and daunting, as it involves centralizing vast amounts of data from multiple points within the organization.

2. Managing outdated personal data

Another major challenge of data mapping is ensuring information collected and processed is up-to-date. Relying on traditional data mapping methodologies like spreadsheets or physical documents is a bit tricky, as it makes regular updates cumbersome and prone to errors. 

Such sluggishness can severely impact operational efficiency and decision-making. Additionally, using outdated data maps for compliance purposes might attract sanctions.

3. Understanding legal and regulatory requirements  

Since GDPR is a relatively new regulatory framework; its legal and regulatory requirements are continually evolving. Companies are responsible for monitoring these changes and ensuring that they understand the legal and regulatory requirements in providing the data subject's privacy.

The major challenge with this is maintaining an up-to-date data map that accurately reflects ongoing changes in GDPR regulations and principles.

How Can Automating Data Mapping Address These Challenges?

One of the most effective ways to approach data mapping is by using automated data mapping software. Such software helps streamline the data mapping process, accelerates the pace of data collection and updating, reduces the likelihood of human error, and provides a comprehensive overview of data flows. Automation not only facilitates quicker compliance with GDPR but also enhances the overall accuracy and accessibility of the data map.

Streamline Data Mapping with Strac

As a leading Data Loss Prevention (DLP) software, Strac is designed to help companies protect sensitive data, avoid data breaches, and ensure compliance with GDPR regulations. The platform excels in detecting PII, PHI, and other sensitive information across cloud services, SaaS platforms, and other end-point devices, making data discovery and creating data maps very seamless.

Furthermore, Strac streamlines the identification and categorization of sensitive information within an organization, providing robust protection tailored to the data's sensitivity level. It also facilitates the generation of comprehensive reports that detail how data flows across your organization—essential for audits and regulatory compliance.

Ready to see how Strac can transform your data management practices? Book a 30-minute demo today!