Data Privacy is everywhere. The awareness is increasing day by day and we see organizations spending a huge amount of money on procuring privacy automation tools. While privacy automation tools ease the life of a Privacy Office, they may complicate the privacy compliance process of the organization if it is not used properly or are operated with little knowledge. This short blog will specify a few key points to consider before adopting a privacy automation tool.
- Availability of Privacy framework – Without the availability of a developed privacy framework, onboarding a tool may not make much sense. An organization needs to perform a consulting engagement before or along with the implementation of the privacy automation tool to ensure that the tool configuration is in alignment with the compliance requirements.
- Hosting location of the tool – This is one of the key elements to consider especially if the privacy law mandates data localization. In such cases, organizations must ensure local cloud hosting of the tool or must consider on-prem installation. Also, for on-prem installation of the privacy tool, technical requirements must be met before onboarding the tool.
- Type of data handled – Many privacy automation tools operate only on the metadata. However, some tools consume personal data processed by the organization to help in compliance. For example, in cases where the tool stores a copy of the personal data in the DSAR reports, caution should be exercised by implementing additional privacy controls. Another consideration is if the tool can operate on both structured and unstructured data as an organization might use documents, file servers, data lakes, etc.
- Scope of the tool operation – An organization may not need all the modules of a tool for demonstrating privacy compliance. This also may cause an operational overhead. Thus it is important to understand the complete scope of the program and decide which modules to adopt for automation. For example, an organization may automate personal data discovery exercises but may manage privacy notices manually without a tool.
- Vendor Audit/ Regulatory compliance reports – Privacy automation tool vendors must be able to demonstrate compliance with the applicable regulations to the organization. For example, if a vendor is based out of Europe, the vendor must be able to demonstrate compliance with UAE regulations for UAE organizations. This is very important as laws differ across regions.
- Integration feasibility – Although most privacy automation vendors provide support for integration to personal data stores, there may be some restrictions. Thus it is a good idea to identify all the electronic data stores and check for integration feasibility with the vendors before onboarding them. Integration with third-party tools such as GRC/reporting tools to create customized reports for management and regulators’ review may also be important.
- Support requirement – Post-implementation support is key to onboarding a vendor. In the privacy compliance journey, Privacy Office may face multiple technical issues. Thus the vendor must be able to provide continuous support as any delay may lead to regulatory implications. For example, if the breach reporting module is not working as expected, it becomes difficult to document the breach in a timely and defined manner.
While there are many more considerations for onboarding a privacy tool, the above few will help an organization in deciding the approach to be taken for privacy compliance. It is essential to understand the privacy risks arising out of onboarding another vendor and accordingly, a due diligence must be conducted.