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

• US 10,754,981 B2
• Filed: 02/14/2020
• Issued: 08/25/2020
• 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:
  US16/791,348
• Publication Number:
  US 20200184104A1
• Time in Patent Office: 193 Days
• CPC Class Codes: G06F 21/31 User authentication
• CPC Class Codes: G06F 21/6245 Protecting personal data, e.g. for financial or medical purposes
• 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

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 computer system for processing a request to delete personal data from a plurality of computing devices associated with a particular organization, the computer system comprising:

one or more computer processors;

computer memory embodied in one or more computer storage locations operatively coupled to the one or more computer processors that stores particular computer code, wherein the computer system is configured for;

receiving a plurality of delete personal data requests, each delete personal data request of the plurality of delete personal data requests being a request, from a respective data subject, to delete personal data associated with the data subject from one or more computer storage locations; and

at least partially in response to receiving each respective delete personal data request;

automatically using a data model to identify at least one computer storage location of the one or more computer storage locations on which first respective personal data associated with the respective data subject is stored, wherein;

the data model;

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

stores information regarding respective storage locations of the plurality of different items of personal data for each respective data subject; and

comprises a respective data inventory for each of the one or more computer storage locations and maps one or more relationships between one or more aspects of each data inventory and the one or more computer storage locations; and

automatically using the data model to identify the at least one computer storage location comprises using a unique identifier associated with the respective data subject in combination with the data model to identify the at least one computer storage location as storing the first respective personal data associated with the respective data subject; and

at least partially in response to identifying the at least one computer storage location as storing the first respective personal data associated with the respective data subject, facilitating the deletion of the first respective personal data from the at least one computer storage location, wherein using the unique identifier associated with the respective data subject in combination with the data model to identify the at least one computer storage location as storing the first respective personal data associated with the respective data subject comprises;

analyzing each respective data inventory to identify one or more data inventory attributes associated with each of the one or more computer storage locations; and

scanning the one or more data inventory attributes using the unique identifier to determine the at least one computer storage location.

2. The computer system of claim 1, wherein the system is further configured for concurrently processing at least five of the plurality of delete personal data requests in an automated manner.

3. The computer system 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 respective data subject.

4. The computer system of claim 1, wherein the system is further configured for facilitating the execution of multiple delete personal data requests in response to a single command from a user.

5. The computer system of claim 1, wherein the computer system is configured for at least partially in response to receiving each respective delete personal data request of the plurality of delete personal data requests:

obtaining metadata regarding each respective data subject;

using the metadata to determine whether a priority of each respective delete personal data request should be adjusted based on the metadata;

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

(A) a location from which each respective delete personal data request was made;

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

(C) a status of each respective data subject; and

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

6. The computer system of claim 1, wherein facilitating the deletion of the first respective personal data from the at least one computer storage location comprises the first respective personal data in computer memory associated with the at least one computer storage location.

7. The computer system of claim 1, wherein the unique identifier associated comprises a first unique identifier generated in response to receiving consent from the respective data subject for processing of the first respective personal data by the particular organization.

8. The computer system of claim 1 wherein:

the data model further defines at least one transfer location to which the plurality of different items of personal data are transferred from the at least one computer storage location; and

facilitating the deletion of the first respective personal data from the at least one computer storage location comprises facilitating the deletion of the first respective personal data from both at least one computer storage location and the at least one transfer location.

9. The computer system of claim 8, wherein the one or more computer storage locations comprise the at least one storage location.

10. A computer system for processing a request to delete personal data from a plurality of computing devices associated with a particular organization, the computer system comprising:

one or more computer processors;

computer memory embodied in one or more computer storage locations operatively coupled to the one or more computer processors that stores particular computer code, wherein the computer system is configured for;

receiving, by the one or more computer processors, a plurality of delete personal data requests, each delete personal data request being a request, from a respective data subject, to delete personal data associated with the data subject; and

at least partially in response to receiving each respective request of the plurality of requests;

automatically identifying, by the one or more computer processors, at least one computing device of the one or more computer storage locations on which the personal data associated with the respective data subject is stored, wherein identifying the at least one computing device comprises;

accessing, by the one or more computer processors, a data model defining;

 

at least one storage location where a plurality of pieces of personal data are stored as part of a processing activity;

 

at least one transfer location to which the plurality of pieces of personal data are transferred from the at least one storage location as part of the processing activity; and

using a unique identifier associated with the respective data subject, in combination with the data model, to identify the personal data associated with the respective data subject; and

in response to identifying, by the one or more computer processors, the at least one computing device on which the personal data associated with the respective data subject is stored, automatically facilitating deletion of the personal data associated with the respective data subject from the at least one storage location and the at least one transfer location, wherein;

the data model comprises a respective data inventory for each of the one or more computer storage locations and maps one or more relationships between one or more aspects of each data inventory and the one or more computer storage locations;

using the unique identifier associated with the respective data subject in combination with the data model to identify the personal data associated with the respective data subject comprises;

 

analyzing each respective data inventory to identify one or more data inventory attributes associated with each of the one or more computer storage locations; and

 

scanning the one or more data inventory attributes using the unique identifier to determine the at least one computing device of the one or more computer storage locations.

11. The computer system of claim 10, wherein the at least one computing device comprises both the at least one storage location and the at least one transfer location.

12. The computer system of claim 11, wherein the computer system is further configured for concurrently processing, by the one or more computer processors, at least five of the plurality of delete personal data requests in an automated manner.

13. The computer system of claim 11, wherein automatically facilitating the deletion of the personal data associated with the respective data subject from the at least one storage location and the at least one transfer location comprises overwriting the personal data associated with the respective data subject in computer memory associated with both the at least one storage location and the at least one transfer location.

14. The computer system of claim 10, wherein the unique identifier associated with the respective data subject comprises a unique identifier generated in response to receiving consent provided by the respective data subject for an initial storage of the personal data associated with the respective data subject as part of the processing activity.

15. The computer system of claim 10, wherein the at least one computing device on which the personal data associated with the respective data subject is stored comprises identifying the at least one computing device using one or more data modeling means.

16. The computer system of claim 10, wherein the method further comprises:

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

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 storage locations 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 respective data subject from the one or more computer storage locations by;

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

17. 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 an 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 a first data subject request associated with a first data subject from a remote computing device, the first data subject request comprising a request to delete one or more first pieces of personal data from the personal data processing and deletion system, one or more first pieces of personal data being associated with 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 first pieces of personal data on the one or more data assets; and

in response to identifying the respective storage location of each of the one or more pieces of personal data, automatically facilitating the deletion of each of the one or more first pieces of personal data from each respective storage location, wherein;

the one or more data models comprise a respective data inventory for each of the one or more data assets and maps one or more relationships between one or more aspects of each data inventory and the one or more data assets; and

the data processing and deletion system is further configured for using a unique identifier associated with the first data subject in combination with the one or more data models to identify the one or more first pieces of personal data data subject comprises;

 

analyzing each respective data inventory to identify one or more data inventory attributes associated with each of the one or more data assets; and

 

scanning the one or more data inventory attributes using the unique identifier to determine the respective storage location of each of the one or more first pieces of personal data on the one or more data assets.

18. The personal data processing and deletion system of claim 17, wherein automatically facilitating the deletion of each of the one or more first pieces of personal data from each respective storage location comprises overwriting each of the one or more first pieces of personal data at each respective storage location.

19. The personal data processing and deletion system of claim 17, wherein the personal data processing and deletion system is further configured for concurrently processing, by the one or more processors, a plurality of data subject requests simultaneously.