Data processing systems and methods for automatically detecting and documenting privacy-related aspects of computer software

• US 10,642,870 B2
• Filed: 09/09/2019
• Issued: 05/05/2020
• Est. Priority Date: 06/10/2016
• Status: Active Grant

• Current Assignee: OneTrust LLC
• Original Assignee: OneTrust LLC
• Inventors: Malhotra, Priya, Barday, Kabir A., Karanjkar, Mihir S., Finch, Steven W., Browne, Ken A., Heard, Nathan W., Patel, Aakash H., Sabourin, Jason L., Daniel, Richard L., Patton-Kuhl, Dylan D., Brannon, Jonathan Blake
• Primary Examiner(s): Deng, Anna C
• Application Number:
  US16/565,261
• Publication Number:
  US 20200004762A1
• Time in Patent Office: 239 Days
• Field of Search: 717101
• 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 16/254 Extract, transform and load [ETL] procedures, e.g. ETL data flows in data warehouses
• CPC Class Codes: G06F 16/288 Entity relationship models
• 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 40/169 Annotation, e.g. comment data or footnotes
• CPC Class Codes: G06F 40/186 Templates
• CPC Class Codes: G06N 20/00 Machine learning
• CPC Class Codes: G06N 3/006 based on simulated virtual individual or collective life forms, e.g. social simulations or particle swarm optimisation [PSO]
• CPC Class Codes: G06Q 30/018 Certifying business or products
• CPC Class Codes: G06Q 50/265 Personal security, identity or safety
• CPC Class Codes: H04L 63/0428 wherein the data content is protected, e.g. by encrypting or encapsulating the payload
• CPC Class Codes: H04L 63/101 Access control lists [ACL]
• CPC Class Codes: H04W 12/02 Protecting privacy or anonymity, e.g. protecting personally identifiable information [PII]

Abstract

Data processing systems and methods according to various embodiments are adapted for automatically detecting and documenting privacy-related aspects of computer software. Particular embodiments are adapted for: (1) automatically scanning source code to determine whether the source code include instructions for collecting personal data; and (2) facilitating the documentation of the portions of the code that collect the personal data. For example, the system may automatically prompt a user for comments regarding the code. The comments may be used, for example, to populate: (A) a privacy impact assessment; (B) system documentation; and/or (C) a privacy-related data map. The system may comprise, for example, a privacy comment plugin for use in conjunction with a code repository.

Claims

1. A data processing computer system for automatically analyzing computer code to determine whether computer software associated with the computer code collects personal data, the system comprising:

at least one computer processor; and

computer memory storing computer-executable instructions for;

analyzing, by the at least one computer processor, at least one segment of the computer code to determine whether the at least one segment of computer code comprises instructions for collecting one or more pieces of personal data, wherein determining whether the at least one segment of computer code comprises instructions for collecting the one or more pieces of the personal data comprises extracting one or more comments from a file containing the at least one segment of the computer code and using information from the one or more comments to determine whether the at least one segment of computer code comprises instructions for collecting the one or more pieces of the personal data;

in response to determining that the at least one segment of the computer code comprises instructions for collecting the one or more pieces of personal data, prompting, by the at least one computer processor, a user to input particular information selected from a group consisting of;

(1) where the system stores the one or more pieces of the personal data, (2) how long the system stores the one or more pieces of personal data, (3) whether the one or more pieces of personal data will include the personal data of minors, and (4) whether the at least one segment of computer code comprises instructions for facilitating the transfer of the one or more pieces of personal data across geographic borders, wherein the user is an author of the at least one segment of computer code;

receiving the particular information from the user; and

at least partially in response to receiving the particular information from the user;

(A) using the particular information to at least partially answer one or more questions within one or more questionnaires that are used in conducting a privacy impact assessment for the computer software associated with the computer code; and

(B) populating, by the at least one computer processor, at least a portion of a privacy-related data map using the particular information, wherein the privacy-related data map identifies one or more electronic associations between two or more data assets within a data model comprising a respective digital inventory for each of the two or more data assets, each of the respective digital inventories comprising one or more respective inventory attributes selected from a group consisting of;

(i) one or more processing activities associated with each of the respective data assets, (ii) transfer data associated with each of the respective data assets, and (iii) respective identifiers of the one or more pieces of personal data associated with each of the respective data assets.

2. The data processing computer system of claim 1, wherein the computer memory stores computer-executable instructions for:

automatically, by the at least one computer processor, analyzing the at least one segment of the computer code to determine what particular type of personal data the at least one segment of computer code collects; and

automatically, by the at least one computer processor, prompting a user to input specific information as to why the at least one segment of computer code comprises instructions for collecting the particular type of personal data.

3. The data processing computer system of claim 2, wherein the computer memory stores computer-executable instructions for:

at least partially in response to receiving the specific information from the user, using the particular information to automatically write at least a portion of the specific information to an electronic record that is used to document the functionality of the code.

4. The data processing computer system of claim 2, wherein the computer memory stores computer-executable instructions for at least partially in response to receiving the specific information from the user, using the specific information to populate at least a portion of a privacy-related data map.

5. The data processing computer system of claim 1, wherein the step of analyzing the at least one segment of computer code occurs at least substantially in real time as the author is writing the at least one segment of computer code.

6. The data processing computer system of claim 1, wherein the step of prompting a user to input particular information occurs at least substantially in real time as the author is writing the at least one segment of computer code.

7. The data processing computer system of claim 1, wherein the computer memory stores computer-executable instructions for, in response to determining that the at least one segment of the computer code comprises instructions for collecting the one or more pieces of personal data, prompting, by the at least one computer processor, a user to input where the system stores the one or more pieces of the personal data.

8. The data processing computer system of claim 1, wherein the computer memory stores computer-executable instructions for, in response to determining that the at least one segment of the computer code comprises instructions for collecting the one or more pieces of personal data, prompting, by the at least one computer processor, a user to input how long the system stores the one or more pieces of personal data.

10. The computer-implemented data processing method of claim 1, wherein the step of analyzing the at least one segment of the computer code occurs at least substantially in real time as the author is writing the at least one segment of the computer code.

11. The computer-implemented data processing method of claim 10, wherein the step of prompting a user to input particular information occurs at least substantially in real time as the author is writing the at least one segment of the computer code.

9. A computer-implemented data processing method for automatically analyzing computer code to determine whether computer software associated with the computer code collects personal data, the method comprising:

analyzing, by at least one computer processor, at least one segment of the computer code associated with the computer software to determine whether the at least one segment of the computer code comprises instructions for collecting one or more pieces of the personal data, wherein determining whether the at least one segment of the computer code comprises instructions for collecting the one or more pieces of the personal data comprises extracting one or more comments from a file containing the at least one segment of the computer code and using information from the one or more comments to determine whether the at least one segment of the computer code comprises instructions for collecting the one or more pieces of the personal data;

in response to determining that the at least one segment of the computer code comprises instructions for collecting the one or more pieces of the personal data, prompting, by the at least one computer processor, a user to input particular information selected from a group consisting of;

(1) where system stores the one or more pieces of personal data, (2) how long the system stores the one or more pieces of personal data, (3) whether the one or more pieces of personal data will include the personal data of minors, and (4) whether the at least one segment of computer code comprises instructions for facilitating the transfer of the one or more pieces of personal data across geographic borders, wherein the user is an author of the at least one segment of computer code;

receiving, by the at least one computer processor, the particular information from the user, and saving the particular information in a memory; and

in response to receiving the particular information from the user;

(A) using the particular information to at least partially answer one or more questions within one or more questionnaires that are used in conducting a privacy impact assessment for the computer software associated with the computer code; and

(B) populating, by the at least one computer processor, at least a portion of a privacy-related data map using the particular information, wherein the privacy-related data map identifies one or more electronic associations between at least two data assets within a data model comprising a respective digital inventory for each of the at least two data assets, each respective digital inventory comprising one or more respective inventory attributes selected from a group consisting of;

(i) one or more processing activities associated with each of the respective data assets, (ii) transfer data associated with the each of the respective data assets, and (iii) respective identifiers of the one or more pieces of the personal data associated with the each of the respective data assets.

12. The computer-implemented data processing method of claim 9, wherein the step of prompting a user to input particular information is done by generating a graphical user interface that includes at least one prompt;

and

receiving the particular information from the user via the graphical user interface.

13. The computer-implemented data processing method of claim 9, wherein the step of prompting a user to input particular information is done via a personal digital assistant.

14. The computer-implemented data processing method of claim 9, wherein the computer-implemented method further comprises, at least partially in response to receiving the particular information from the user, automatically writing at least a portion of the particular information to a document that is used to document the functionality of the code.

15. The computer-implemented data processing method of claim 9, wherein the method further comprises:

analyzing the at least one segment of computer code to determine whether the computer code comprises instructions for storing the one or more pieces of personal data in a particular location; and

at least partially in response to determining that the computer code comprises instructions for storing the one or more pieces of personal data in a particular location, prompting the user to input at least one reason why the one or more pieces of personal data are being stored in the particular location.

16. The computer-implemented data processing method of claim 9, further comprising, in response to determining that the at least one segment of the computer code comprises instructions for collecting the one or more pieces of personal data, prompting, by the at least one computer processor, a user to input where the system stores the one or more pieces of the personal data.

17. The computer-implemented data processing method of claim 9, further comprising, in response to determining that the at least one segment of the computer code comprises instructions for collecting the one or more pieces of personal data, prompting, by the at least one computer processor, a user to input how long the system stores the one or more pieces of personal data.

18. A non-transitory computer-readable medium storing computer-executable instructions for:

analyzing, by at least one computer processor, at least one segment of computer code associated with particular computer software to determine whether the at least one segment of the computer code comprises instructions for collecting a particular type of personal data, wherein determining whether the at least one segment of the computer code comprises instructions for collecting a particular type of the personal data comprises extracting one or more comments from a file containing the at least one segment of the computer code and using information from the one or more comments to determine whether the at least one segment of computer code comprises instructions for collecting the one or more pieces of the personal data;

in response to determining that the at least one segment of the computer code comprises instructions for collecting the particular type of the personal data, prompting, by the at least one computer processor, a user to input particular information selected from a group consisting of;

(1) where a system stores the one or more pieces of the personal data;

(2) how long the system stores the one or more pieces of the personal data;

(3) whether the one or more pieces of the personal data will include personal data of minors; and

(4) whether the at least one segment of the computer code comprises instructions for facilitating a transfer of the one or more pieces of the personal data across geographic borders, wherein the user is an author of the at least one segment of computer code;

receiving, by the at least one computer processor, the particular information from the user; and

at least partially in response to receiving the particular information from the user;

(A) using the particular information to at least partially answer one or more questions within one or more questionnaires that are used in conducting a privacy impact assessment for the computer software associated with the computer code; and

(B) populating, by the at least one computer processor, at least a portion of a privacy related data map using the one or more types of information, wherein the privacy-related data map identifies one or more electronic associations between two or more data assets within a data model comprising a respective digital inventory for each of the two or more data assets, each of the respective digital inventory comprising one or more respective inventory attributes selected from a group consisting of;

(i) one or more processing activities associated with each of the respective data assets, (ii) transfer data associated with each of the respective data assets, and (iii) respective identifiers of the one or more pieces of the personal data associated with each of the respective data assets.

19. The non-transitory computer-readable medium of claim 18, wherein the non-transitory computer-readable medium stores computer-executable instructions for, in response to determining that the at least one segment of the computer code comprises instructions for collecting the particular type of personal data, automatically, by the at least one computer processor, prompting a user to input specific information as to how the particular type of personal data is used by the software.

20. The non-transitory computer-readable medium of claim 19, wherein the step of analyzing the at least one segment of computer code occurs at least substantially in real time as an author of the at least one segment of computer code is writing the at least one segment of the computer code.

21. The non-transitory computer-readable medium of claim 20, wherein the step of prompting a user to input specific information occurs at least substantially in real time as the author is writing the at least one segment of the computer code.

22. The non-transitory computer-readable medium of claim 18, wherein the non-transitory computer-readable medium stores computer-executable instructions for, at least partially in response to receiving the particular information from the user, using the particular information to populate at least one question within a questionnaire of a privacy impact assessment.

23. The non-transitory computer-readable medium of claim 18, wherein:

the non-transitory computer-readable medium stores computer-executable instructions for, at least partially in response to receiving the particular information from the user, automatically writing at least a portion of the particular information to the electronic document.

24. The non-transitory computer-readable medium of claim 18, wherein the non-transitory computer-readable medium stores computer-executable instructions for:

analyzing the at least one segment of the computer code to determine whether the computer code comprises instructions for storing the one or more pieces of personal data in a particular location; and

at least partially in response to determining that the computer code comprises instructions for storing the one or more pieces of personal data in a particular location, prompting the user to input at least one reason why the one or more pieces of personal data are being stored in the particular location.

25. The non-transitory computer-readable medium of claim 18, wherein the computer-executable instructions comprise computer-executable instructions associated with a plugin for use in a particular source code repository, which is adapted to store source code and to manage version control for source code stored within the repository.