Data processing systems for fulfilling data subject access requests and related methods

• US 10,452,866 B2
• Filed: 05/13/2019
• Issued: 10/22/2019
• 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): Bui, Hanh Thi-Minh
• Application Number:
  US16/410,566
• Publication Number:
  US 20190266130A1
• Time in Patent Office: 162 Days
• 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 21/6227 where protection concerns the structure of data, e.g. records, types, queries
• CPC Class Codes: G06F 21/6254 by anonymising data, e.g. decorrelating personal data from the owner's identification
• CPC Class Codes: G06F 2221/2141 Access rights, e.g. capability lists, access control lists, access tables, access matrices
• CPC Class Codes: G06F 2221/2143 Clearing memory, e.g. to prevent the data from being stolen
• CPC Class Codes: H04L 63/08 for authentication of entities cryptographic mechanisms or cryptographic arrangements for entity authentication H04L9/32
• CPC Class Codes: H04L 63/101 Access control lists [ACL]
• CPC Class Codes: H04L 63/102 Entity profiles
• CPC Class Codes: H04L 63/108 when the policy decisions are valid for a limited amount of time
• CPC Class Codes: H04L 63/20 for managing network security; network security policies in general filtering policies H04L63/0227
• CPC Class Codes: H04W 12/33 using wearable devices, e.g. using a smartwatch or smart-glasses

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 non-transitory computer-readable medium storing computer-executable instructions for processing a request to delete a data subject'"'"'s personal data from a plurality of computer systems associated with a particular organization by:

receiving a request from a data subject to delete personal data associated with the data subject; and

at least partially in response to receiving the request;

automatically using a data model to identify;

(A) a first computing device on which first personal data associated with the data subject is stored; and

(B) a second computing device on which second personal data associated with the data subject is stored, wherein;

the data model defines;

at least one storage location utilized in the storage of a plurality of different items of personal data for the data subject as part of a processing activity; and

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

automatically using the data model to identify the first computing device and the second computing device comprises scanning, using a unique identifier associated with the data subject, the plurality of different items of personal data for the data subject to identify the first personal data associated with the data subject and the second personal data associated with the data subject;

at least partially in response to identifying the first computing device on which the first personal data associated with the data subject is stored, facilitating the deletion of the first personal data from the first computing device; and

at least partially in response to identifying the second computing device on which the second personal data associated with the data subject is stored, facilitating the deletion of the second personal data from the second computing device, wherein;

the data model stores information regarding respective storage locations of the plurality of different items of personal data for the data subject.

2. The non-transitory computer-readable medium of claim 1, wherein:

the plurality of different items of personal data for the data subject comprises both the first personal data associated with the data subject and the second personal data associated with the data subject; and

the respective storage locations comprise both the first computing device and the second computing device.

3. The non-transitory computer-readable medium of claim 2, wherein the data model stores information regarding respective storage locations of a plurality of different respective items of personal data for each of a plurality of individuals other than the data subject.

4. The non-transitory computer-readable medium of claim 1, wherein the non-transitory computer-readable medium stores computer-executable instructions for facilitating deletion of multiple data subject access requests in response to a single command from a user.

5. The non-transitory computer-readable medium of claim 1, wherein the non-transitory computer-readable medium stores computer-executable instructions for:

automatically verifying an identity of the data subject; and

at least partially in response to verifying the identity of the data subject, processing the request to delete the data subject'"'"'s personal data from the plurality of computer systems.

6. The non-transitory computer-readable medium of claim 1, wherein the non-transitory computer-readable medium stores computer-executable instructions for:

at least partially in response to receiving the request, obtaining metadata regarding the data subject;

using the metadata to determine whether a priority of the request should be adjusted based on the obtained metadata; and

in response to determining that the priority of the request should be adjusted based on the obtained metadata, adjusting the priority of the request, wherein the metadata comprises metadata selected from a group consisting of;

(A) a location from which the request was made;

(B) one or more current sensitivities to world events; and

(C) a status of the data subject; and

fulfilling the request according to the adjusted priority of the request.

7. The non-transitory computer-readable medium of claim 6, wherein the metadata comprises the location from which the request was made.

8. The non-transitory computer-readable medium of claim 6, wherein the metadata comprises the status of the data subject.

9. The non-transitory computer-readable medium of claim 1, wherein each of the first and second computing devices is associated with a different respective corporate entity of a plurality of corporate entities.

10. The non-transitory computer-readable medium of claim 1, wherein the plurality of corporate entities are sub-organizations of a parent organization.

11. 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 an organization, the method comprising:

receiving, by one or more computer processors, a request from a data subject to delete the personal data associated with the data subject from one or more computer systems of an organization; and

at least partially in response to receiving the request;

processing the request by one or more computer processors;

automatically identifying, by one or more computer processors, one or more computing devices on the one or more computer systems on which the personal data associated with the data subject is stored, wherein identifying the one or more computing devices on which the personal data associated with the data subject is stored comprises;

using a data model to make the identification, the data model comprising information regarding a respective storage location of a plurality of different items of personal data associated with the data subject;

accessing, by one or more computer processors, the data model, the data model 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 computer processors, using a unique identifier associated with the data subject, the plurality of personal data to identify the personal data associated with the data subject; and

in response to determining, by one or more computer processors, the one or more computing devices storing the personal data associated with the data subject, automatically facilitating the deletion of the personal data associated with the data subject from the one or more computing devices.

12. The computer-implemented data processing method of claim 11, wherein automatically facilitating the deletion of the personal data associated with the data subject from the one or more computing devices comprises overwriting the personal data associated with the data subject from computer memory associated with the one or more computing devices.

13. The computer-implemented data processing method of claim 11, wherein facilitating the deletion of the personal data associated with the data subject from the one or more computing devices comprises facilitating the deletion from the at least one storage location and the at least one transfer location.

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

15. The computer-implemented data processing method of claim 11, wherein one or more computing devices on the one or more computer systems on which the personal data associated with the data subject is stored comprises identifying the one or more computing devices using one or more data modeling means.

16. The computer-implemented data processing method of claim 11, wherein:

processing the request comprises identifying a first processing activity under which the data subject has previously provided consent for the collection of personal data;

the method further comprises;

electronically accessing a first data inventory associated with the first processing activity, the first data inventory identifying;

a first data asset of the one or more computer systems on which the personal data collected as part of the first processing activity is stored;

transfer data associated with the first data asset; and

access data associated with the first data asset; and

facilitating the deletion of the personal data associated with the data subject from the one or more computing devices by;

automatically assigning a first task to delete the personal data associated with the data subject from the first data asset;

identifying a second data asset based at least in part on the transfer data;

automatically assigning a second task to delete the personal data associated with the data subject from the second data asset;

identifying a third data asset based at least in part on the access data; and

automatically assigning a third task to delete the personal data associated with the data subject from the third data asset.

17. 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;

accessing, using one or more electronic access means, a data model defining;

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

at least one transfer location to which the at least one storage location transfers the plurality of personal data, wherein the data model comprises information regarding a respective storage location of each of one or more pieces of personal data associated with the requestor; and

processing the request by identifying, using one or more data mapping means, the 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, wherein identifying the respective storage location of each of the one or more pieces of personal data associated with the requestor comprises;

scanning, using one or more electronic scanning means using a unique identifier associated with the requestor, the plurality of personal data to identify the one or more pieces of personal data associated with the requestor; and

using the data model to make the identification;

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.

18. The computer-implemented data processing method of claim 17, 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; and

processing the request further comprises identifying the respective storage location of each of the one or more pieces of personal data based at least in part on storage data associated with the one or more processing activities.