Data processing systems for the identification and deletion of personal data in computer systems

• US 10,346,637 B2
• Filed: 08/03/2018
• Issued: 07/09/2019
• Est. Priority Date: 06/10/2016
• Status: Active Grant

• Current Assignee: OneTrust LLC
• Original Assignee: OneTrust LLC
• Inventors: Barday, Kabir A., Sabourin, Jason L., Brannon, Jonathan Blake, Karanjkar, Mihir S., Jones, Kevin
• Primary Examiner(s): Wu, Daxin
• Application Number:
  US16/054,780
• Publication Number:
  US 20180341784A1
• Time in Patent Office: 340 Days
• Field of Search: None
• CPC Class Codes: G06F 15/76 Architectures of general purpose stored program computers with program plugboard G06F15/08; multicomputers G06F15/16
• CPC Class Codes: G06F 21/552 involving long-term monitoring or reporting
• CPC Class Codes: G06F 21/6245 Protecting personal data, e.g. for financial or medical purposes
• CPC Class Codes: G06F 2221/2143 Clearing memory, e.g. to prevent the data from being stolen
• CPC Class Codes: G06F 3/0608 Saving storage space on storage systems
• CPC Class Codes: G06F 3/0611 in relation to response time
• CPC Class Codes: G06F 3/0652 Erasing, e.g. deleting, data cleaning, moving of data to a wastebasket
• CPC Class Codes: G06F 3/067 Distributed or networked storage systems, e.g. storage area networks [SAN], network attached storage [NAS]
• CPC Class Codes: G06F 9/4843 by program, e.g. task dispatcher, supervisor, operating system
• CPC Class Codes: H04L 63/20 for managing network security; network security policies in general filtering policies H04L63/0227

Abstract

In particular embodiments, in response a data subject submitting a request to delete their personal data from an organization'"'"'s systems, the system may: (1) automatically determine where the data subject'"'"'s personal data is stored; and (2) in response to determining the location of the data (which may be on multiple computing systems), automatically facilitate the deletion of the data subject'"'"'s personal data from the various systems (e.g., by automatically assigning a plurality of tasks to delete data across multiple business systems to effectively delete the data subject'"'"'s personal data from the systems).

Claims

1. A personal data processing and deletion system comprising;

one or more processors;

one or more data assets that store a plurality of personal data associated with a plurality of data subjects, each piece of the plurality of personal data being associated with a respective particular processing activity of a plurality of processing activities undertaken by a particular organization; and

computer memory, wherein;

the computer memory stores one or more data models defining one or more data transfers among the one or more data assets; and

the data processing and deletion system is configured for;

receiving, from a first data subject on a remote computing device, a first data subject request that is a request for the particular organization to delete, from the personal data processing and deletion system, one or more pieces of personal data associated with the first data subject that the particular organization has previously obtained on the first data subject;

in response to receiving the first data subject request, identifying, based at least in part on the one or more data models and the plurality of processing activities undertaken by the organization, a respective storage location of each of the one or more pieces of personal data associated with the first data subject on the one or more data assets;

in response to identifying the storage location of each of the one or more pieces of personal data associated with the first data subject, automatically determining that a first portion of the one or more of the pieces of personal data has one or more legal bases for continued storage;

in response to determining that the first portion of the one or more of the pieces of personal data associated with the first data subject has one or more legal bases for continued storage, automatically maintaining storage of the first portion of the one or more pieces of personal data;

automatically facilitating deletion of a second portion of the one or more pieces of personal data associated with the first data subject that do not have one or more legal bases for continued storage, wherein the first portion of the one or more pieces of personal data is different from the second portion of the one or more pieces of personal data; and

automatically marking one or more memory addresses associated with the second portion of the one or more pieces of personal data associated with the first data subject as free.

2. The personal data processing and deletion system of claim 1, wherein automatically facilitating the deletion of each of the one or more pieces of personal data of the second portion of the one or more pieces of personal data associated with the first data subject from each respective storage location comprises overwriting each of the one or more pieces of personal data of the second portion of the one or more pieces of personal data associated with the first data subject at each respective storage location.

3. The personal data processing and deletion system of claim 1, identifying the respective storage location of each of the one or more pieces of personal data associated with the first data subject on the one or more data assets comprises:

determining, for each of the plurality of processing activities, whether the first data subject provided valid consent for collection, by the personal data processing and deletion system, of the one or more pieces of personal data associated with the first data subject; and

in response to determining that the first data subject provided valid consent for the collection of the one or more pieces of personal data associated with the first data subject for a first particular processing activity of the plurality of processing activities, identifying one or more storage locations on the one or more data assets associated with the first particular processing activity.

4. The personal data processing and deletion system of claim 3, wherein determining whether the first data subject provided valid consent for the collection of the one or more pieces of personal data associated with the first data subject for a first particular processing activity of the plurality of processing activities comprises:

identifying a unique identifier associated with the first data subject generated in response to the first data subject providing the valid consent; and

scanning a consent receipt management system to identify the first particular processing activity based at least in part on the unique identifier.

5. The personal data processing and deletion system of claim 4, wherein the personal data processing and deletion system is further configured for scanning the one or more data assets using the unique identifier to identify the respective storage location of each of the one or more pieces of personal data associated with the first data subject on the one or more data assets.

6. The personal data processing and deletion system of claim 4, wherein the personal data processing and deletion system is further configured for, in response to receiving the first data subject request, electronically disassociating the unique identifier and each of the plurality of processing activities.

7. The personal data processing and deletion system of claim 1, wherein identifying, based at least in part on the one or more data models and the plurality of processing activities undertaken by the organization, the respective storage location of each of the one or more pieces of personal data associated with the first data subject on the one or more data assets comprises:

accessing each of the one or more data models;

scanning each of the one or more data assets based on the one or more data models to identify one or more data attributes associated with each of the one or more data assets; and

analyzing each of the one or more data attributes to identify the one or more pieces of personal data associated with the first data subject.

8. The personal data processing and deletion system of claim 7, wherein:

analyzing each of the one or more data attributes to identify the one or more pieces of personal data associated with the first data subject comprises scanning the one or more data attributes using an identifier associated with the first data asset to locate particular data attributes that contain any of the one or more pieces of personal data associated with the first data subject.

9. A computer-implemented data processing method for processing a request to delete personal data associated with a data subject from one or more computer systems of a particular organization, the method comprising:

receiving, by one or more computer processors, a data subject request from a data subject that is a request for the particular organization to delete, from the personal data processing and deletion system, one or more pieces of personal data associated with the first data subject that the particular organization has previously obtained on the first data subject; and

at least partially in response to receiving the data subject request;

processing the data subject request by one or more computer processors;

automatically identifying, by one or more computer processors, a respective storage location of each of the one or more pieces of personal data associated with the first data subject on the one or more data assets;

in response to identifying the storage location of each of the one or, more pieces of personal data associated with the first data subject, automatically determining that a first portion of the one or more of the pieces of personal pieces of personal data has one or more legal bases for continued storage;

in response to determining that the first portion of the one or more pieces of personal data associated with the first data subject has one or more legal bases for continued storage, automatically maintaining storage of the first portion of the one or more pieces of personal data;

automatically facilitating deletion of a second portion of the one or more pieces of personal data associated with the first data subject that do not have one or more legal bases for continued storage, wherein the first portion of the one or more pieces of personal data is different from the second portion of the one or more pieces of personal data; and

automatically marking one or more memory addresses associated with the second portion of the one or more pieces of personal data associated with the first data subject as free.

10. The computer-implemented data processing method of claim 9, wherein automatically facilitating the deletion of each of the one or more pieces of personal data of the second portion of the one or more pieces of personal data associated with the first data subject from each respective storage location comprises overwriting each of the one or more pieces of personal data of the second portion of the one or more pieces of personal data associated with the first data subject at each respective storage location.

11. The computer-implemented data processing method of claim 9, wherein identifying the respective storage location of each of the one or more pieces of personal data associated with the first data subject on the one or more data assets further comprises:

accessing, by one or more processors, one or more data models, the one or more data models defining;

at least one storage location utilized in the storage of a plurality of personal data as part of a processing activity;

at least one transfer location to which the at least one storage location transfers the plurality of personal data; and

scanning, by one or more processors, using a unique identifier associated with the first data subject, the plurality of personal data to identify the one or more of the pieces of personal data associated with the first data subject.

12. The computer-implemented data processing method of claim 11, wherein facilitating the deletion of the second portion of the one or more pieces of personal data associated with the first data subject comprises facilitating the deletion of the second portion of the one or more pieces of personal data associated with the first data subject from the at least one storage location and the at least one transfer location.

13. The computer-implemented data processing method of claim 11, wherein the unique identifier associated with the first data subject comprises a unique identifier generated in response to consent provided by the first data subject for the initial storage of the one or more pieces of personal data associated with the first data subject as part of the processing activity.

14. A computer-implemented data processing method for deleting one or more pieces of personal data in response to a data subject access request, the method comprising:

receiving, using one or more electronic receiving means, a data subject access request from a requestor comprising one or more request parameters;

processing the request by;

accessing a categorized one or more data elements and a data flow, wherein the categorized one or more data elements and the data flow comprises;

connecting, by one or more processors, via one or more computer networks to one or more databases;

scanning, by one of more processors, the one or more databases to generate a catalog of one or more individuals and one or more pieces of personal information associated with the one or more individuals;

storing the catalog in computer memory;

scanning one or more data repositories based at least in part on the generated catalog to identify one or more attributes of data associated with the one or more individuals by searching one or more data fields in the one or more databases for the one or more pieces of personal information;

analyzing and correlating the one or more attributes and metadata for the scanned one or more data repositories;

using one or more machine learning techniques to categorize one or more data elements from the generated catalog;

analyzing a data flow of the particular data attributes between the one or more data repositories; and

storing the categorized one or more data elements and the data flow in the computer memory;

identifying, using the categorized one or more data elements and the data flow, a respective storage location of each of the one or more pieces of personal data associated with the requestor, the one or more pieces of personal data being stored in one or more data repositories associated with a particular organization;

determining whether the one or more request parameters comprise a request to delete the one or more pieces of personal data; and

in response to determining that the one or more request parameters comprise the request to delete, automatically facilitating the deletion, using one or more data deletion means, the one or more pieces of personal data.

15. The computer-implemented data processing method of claim 14, wherein:

the method further comprises identifying, using one or more consent receipt management means, one or more processing activities undertaken by the particular organization that involved the storage of the one or more pieces of personal data.