Difference between revisions of "Privacy Impact Assessments"

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== Introduction to Privacy Impact Assessments ==
 
== Introduction to Privacy Impact Assessments ==
In Privacy-Now®, ''Privacy Impact assessments'' are focused on ''processinprovide the mean for data subjects to exercise their right to access information about the processing of their
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In Privacy-Now®, ''Privacy Impact assessments'' are focused to assess the risks associated with data processing activities (actually they are ''Data Protection Impact Assessments'').
''personal data'' (e.g. according to section 2, article 13 of ''GDPR Regulation'').
 
  
The process enables to record ''access requests'' and to support their fulfilment.
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The process enables to record ''Privacy Impact Assessments'' and to support their fulfilment. ''Privacy Impact Assessments'' are typically related to one or more ''processing activities'', those to which they refer to.  
  
 
== Workflow ==
 
== Workflow ==
A new ''access request'' can be created using the '''Add New''' functionality and choosing "New Access Request".
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A new ''Privacy Impact Assessment'' can be created using the '''Add New''' functionality and choosing "New Privacy Impact Assessment".
  
A workflow enables to move the ''access request" in several statuses as shown in the following picture.
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A workflow enables to move the ''Privacy Impact Assessment" in several statuses as shown in the following picture.
  
[[File:Access Requests Workflow ENG v1.0.JPG|centre|thumb|800x800px|Access Requests workflow and statuses.]]
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[[File: Privacy_Impact_Assessment_workflow_ENG_v1.0.JPG|centre|thumb|800x800px|Privacy Impact Assessments workflow and statuses.]]
  
  
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! Status !! Description
 
! Status !! Description
 
|-
 
|-
|Default || A temporary status when the ''access request'' is initially created before the first save
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|Default || A temporary status when the ''Privacy Impact Assessment'' is initially created before the first save.
 
|-
 
|-
|Opened || An ''access request'' in this status is draft and it is not actioned.
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|Opened || A ''Privacy Impact Assessment'' in this status is draft.
 
|-
 
|-
|Requested || An ''access request'' in this status is confirmed and it is waiting to be actioned.
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|Detailed Assessment || This status means that a detailed assessment needs to be executed. If a significant risk is found during the preliminary assessment, the transition through this status is required before closing the ''Privacy Impact Assessment''.
 
|-
 
|-
|In charge || In this status, the ''access request'' has been taken in charge and it is being actioned.  
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|Suspended || Activities concerning the ''Privacy Impact Assessment'' are temporarily suspended.
 
|-
 
|-
|Cancelled || ''Access request'' cancelled. This is an end of life status.
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|Closed || In this status, the assessment is completed.  
 
|-
 
|-
|Completed || In this status, all activities related to the ''action request'' were completed and closure is expected after confirmation.
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|Cancelled || ''Privacy Impact Assessment'' cancelled. This is an end of life status.
|-
 
|Suspended || Activities concerning the ''access request'' are temporarily suspended, meaning no further status transitions are allowed.
 
|-
 
|Closed || In this status, all activities related to the ''access request'' are completed and confirmed. This is an end of life status, meaning no further status transitions are allowed.
 
 
|-
 
|-
 
|}
 
|}
  
 
== Information ==
 
== Information ==
''Access request'' records information are organized in four sections:
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''Privacy Impact Assessment'' records are organized in four sections:
  
* <u>''Identification''</u>, where identification data of the ''access request'' are recorded,
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* <u>''Identification''</u>, where identification data of the ''Privacy Impact Assessment'' are recorded,
* <u>''Ownership & Organization''</u>, containing the assignment of the key roles enabled to manage the ''access request'';
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* <u>''Ownership & Organization''</u>, containing the assignment of the key roles enabled to manage the ''Privacy Impact Assessment'';
* <u>''Access Request Details''</u>, with the details of the ''access request'';
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* <u>''Risk Assessment Questions''</u>, containing the preliminary assessment questions;
* <u>''Data Subject Details''</u>, with the details of the ''data subject'' issuing the ''access request'';
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* <u>''Impact Assessment Questions''</u>, if any significant risk is found in the <u>''Risk Assessment Questions''</u> section, it contains detailed impact assessment questions (''DPIA'');
* <u>''Data Subject Representative''</u>, containing the details of the representative of the ''data subject'', if any.
 
  
 
Detailed information on the meaning and use of every field can be found by pointing the mouse on the (i) next to each field. This will activate a tooltip with a brief description of the field.  
 
Detailed information on the meaning and use of every field can be found by pointing the mouse on the (i) next to each field. This will activate a tooltip with a brief description of the field.  
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== Privileges ==
 
== Privileges ==
''Access request'' can be created by the ''users'' to whom the corresponding privilege is granted (see [[Users & Groups]] for more information on how to set this privilege).
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''Privacy Impact Assessments'' can be created by the ''users'' to whom the corresponding privilege is granted (see [[Users & Groups]] for more information on how to set this privilege).
  
The lifecycle of the ''access request'' is managed by the roles described in the table below. ''Groups'' are pre assigned to the roles according to the ''settings'' (see [[Settings]] for more information on how to set these defaults). Initial assignments can be modified according to privileges choosing among the enabled ''groups'' (see once again [[Settings]] for more information on how to enable ''groups'').
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The lifecycle of the ''Privacy Impact Assessment'' is managed by the roles described in the table below. ''Groups'' are pre assigned to the roles according to the ''settings'' (see [[Settings]] for more information on how to set these defaults). Initial assignments can be modified according to privileges choosing among the enabled ''groups'' (see once again [[Settings]] for more information on how to enable ''groups'').
  
 
{| class="wikitable"
 
{| class="wikitable"
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|<u>Data Processor Group</u> || Members of the ''group'' assigned to this role have view (read) privileges.
 
|<u>Data Processor Group</u> || Members of the ''group'' assigned to this role have view (read) privileges.
 
|-
 
|-
|<u>Working Team</u> || Members of this ''group'' have several privileges. They can manage the entire lifecycle, being enabled to:
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|<u>Assessment Team</u> || Members of this ''group'' have several privileges. They can manage the entire lifecycle, being enabled to:
 
* transition records to any compatible status,
 
* transition records to any compatible status,
 
* update fields when possible.
 
* update fields when possible.
 
|-
 
|-
|<u>Audit Team</u> || Members of the ''group'' assigned to this role have view (read) privileges.
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|<u>Auditors Team</u> || Members of the ''group'' assigned to this role have view (read) privileges.
 
|-
 
|-
|<u>Owner</u> || This role can be assigned to a single user among members of the ''groups'' previously described. The <u>Owner</u> has several privileges:
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|<u>PIA Owner</u> || This role can be assigned to a single user among members of the ''groups'' previously described. The <u>Owner</u> has several privileges:
 
* transition to any compatible status,
 
* transition to any compatible status,
 
* update fields when possible.
 
* update fields when possible.
 
|}
 
|}
 
== Warning and alerts ==
 
TBC
 
  
 
== Reports ==
 
== Reports ==
The list of ''access requests'' can be filtered and exported to excel format from the ''view'' '''''Access Requests'''''.
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The list of ''Privacy Impact Assessments'' can be filtered and exported to excel format from the ''view'' '''''Privacy Impact Assessments'''''.
  
 
== Related processes ==
 
== Related processes ==
''Access Requests'' can be related to ''processing activities''.
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''Privacy Impact Assessments'' can be related to ''processing activities'', ''risks'' and ''issues / non conformities''.

Latest revision as of 10:44, 10 October 2018

Introduction to Privacy Impact Assessments

In Privacy-Now®, Privacy Impact assessments are focused to assess the risks associated with data processing activities (actually they are Data Protection Impact Assessments).

The process enables to record Privacy Impact Assessments and to support their fulfilment. Privacy Impact Assessments are typically related to one or more processing activities, those to which they refer to.

Workflow

A new Privacy Impact Assessment can be created using the Add New functionality and choosing "New Privacy Impact Assessment".

A workflow enables to move the Privacy Impact Assessment" in several statuses as shown in the following picture.

Privacy Impact Assessments workflow and statuses.


The following table explains the meaning of each status:

Status Description
Default A temporary status when the Privacy Impact Assessment is initially created before the first save.
Opened A Privacy Impact Assessment in this status is draft.
Detailed Assessment This status means that a detailed assessment needs to be executed. If a significant risk is found during the preliminary assessment, the transition through this status is required before closing the Privacy Impact Assessment.
Suspended Activities concerning the Privacy Impact Assessment are temporarily suspended.
Closed In this status, the assessment is completed.
Cancelled Privacy Impact Assessment cancelled. This is an end of life status.

Information

Privacy Impact Assessment records are organized in four sections:

  • Identification, where identification data of the Privacy Impact Assessment are recorded,
  • Ownership & Organization, containing the assignment of the key roles enabled to manage the Privacy Impact Assessment;
  • Risk Assessment Questions, containing the preliminary assessment questions;
  • Impact Assessment Questions, if any significant risk is found in the Risk Assessment Questions section, it contains detailed impact assessment questions (DPIA);

Detailed information on the meaning and use of every field can be found by pointing the mouse on the (i) next to each field. This will activate a tooltip with a brief description of the field.

Additional information can be found in the secondary forms of the record: attachments, related items, messages and history. See How To for more information.

Privileges

Privacy Impact Assessments can be created by the users to whom the corresponding privilege is granted (see Users & Groups for more information on how to set this privilege).

The lifecycle of the Privacy Impact Assessment is managed by the roles described in the table below. Groups are pre assigned to the roles according to the settings (see Settings for more information on how to set these defaults). Initial assignments can be modified according to privileges choosing among the enabled groups (see once again Settings for more information on how to enable groups).

Role Description
DPO Group Members of the group assigned to this role have full privileges. They can:
  • transition records to any compatible status,
  • update fields when possible,
  • update data sources directly in record management.
Data Controller Group Members of the group assigned to this role have view (read) privileges.
Data Processor Group Members of the group assigned to this role have view (read) privileges.
Assessment Team Members of this group have several privileges. They can manage the entire lifecycle, being enabled to:
  • transition records to any compatible status,
  • update fields when possible.
Auditors Team Members of the group assigned to this role have view (read) privileges.
PIA Owner This role can be assigned to a single user among members of the groups previously described. The Owner has several privileges:
  • transition to any compatible status,
  • update fields when possible.

Reports

The list of Privacy Impact Assessments can be filtered and exported to excel format from the view Privacy Impact Assessments.

Related processes

Privacy Impact Assessments can be related to processing activities, risks and issues / non conformities.