Data processing systems and communication systems and methods for the efficient generation of privacy risk assessments

• US 9,892,444 B2
• Filed: 06/10/2017
• Issued: 02/13/2018
• Est. Priority Date: 04/01/2016
• Status: Active Grant

• Current Assignee: OneTrust LLC
• Original Assignee: OneTrust LLC
• Inventors: Barday, Kabir A.
• Primary Examiner(s): Ouellette, Jonathan P
• Application Number:
  US15/619,459
• Publication Number:
  US 20170287034A1
• Time in Patent Office: 248 Days
• Field of Search: 705 11-912
• CPC Class Codes: G06Q 10/063114 Status monitoring or status determination for a person or group
• CPC Class Codes: G06Q 10/0635 Risk analysis of enterprise or organisation activities
• CPC Class Codes: G06Q 30/0609 Buyer or seller confidence or verification
• CPC Class Codes: G06Q 50/265 Personal security, identity or safety

Abstract

Data processing computer systems, in various embodiments, are adapted for: (1) presenting a threshold privacy assessment that includes a first set of privacy-related questions for a privacy campaign (2) receiving respective answers to the first set of questions; (3) using this initial set of answers to calculate an initial privacy risk score for the privacy campaign; (4) determining whether the privacy risk score exceeds the threshold privacy risk value; (5) in response to the privacy risk score exceeding the threshold privacy risk value, providing one or more supplemental questions to the user to facilitate the completion of a full privacy impact assessment. In some embodiments, in response to determining that the privacy risk score does not exceed the threshold privacy risk value, the systems and methods provide an indication that the particular privacy campaign is a relatively low privacy campaign.

Claims

1. A computer-implemented data processing method for efficiently conducting privacy risk assessments for a plurality of privacy campaigns, the method comprising, for each of the plurality of privacy campaigns:

presenting, by one or more processors, a threshold privacy assessment to a user that includes a first set of one or more questions for a first plurality of question/answer pairings that identify one or more privacy characteristics of a particular privacy campaign;

receiving, by one or more processors, respective answers for the first plurality of question/answer pairings regarding the one or more privacy characteristics of the particular privacy campaign;

determining, by one or more processors, a threshold privacy risk score for the particular privacy campaign that identifies a level of risk for one or more of the privacy characteristics indicated in the question/answer pairings, wherein determining the threshold privacy risk score for the particular privacy campaign comprises;

electronically determining a risk level based at least in part on the one or more privacy characteristics, wherein the one or more privacy characterisitics include an indication of a nature of personal data collected by the particular privacy campaign;

comparing, by one or more processors, the threshold privacy risk score to a threshold privacy risk value, the threshold privacy risk value indicating a pre-determined level of risk regarding the one or more privacy characteristics of the particular privacy campaign;

determining, by one or more processors, whether the threshold privacy risk score exceeds the threshold privacy risk value;

in response to determining that the threshold privacy risk score exceeds the threshold privacy risk value;

providing, by one or more processors, a privacy impact assessment to the user that includes a second set of questions for a second plurality of question/answer pairings that identify one or more privacy characteristics of the particular privacy campaign, the second set of one or more questions including one or more questions that are different from questions within the first set of one or more questions; and

determining by one or more processors, a second risk score based at least in part on the second plurality of question answer parings by;

determining a weighting factor for each of the second plurality of question/answer parings, the second plurality of question/answer parings including;

an indication of a physical storage location of the personal data collected as part of the particular privacy campaign; and

an indication of a length of time that the personal data collected as part of the particular privacy campaign will be stored in the physical storage location;

electronically determining a relative risk rating for each of the second plurality of question/answer pairings;

electronically calculating the second risk score based upon, for each of the second plurality of question/answer pairings, the relative risk rating and the weighting factor; and

electrically associating the second risk score with the particular privacy campaign; and

in response to determining that the privacy risk score does not exceed the threshold privacy risk value, storing, by one or more processors, an indication that the particular privacy campaign is a low privacy risk campaign.

2. The computer-implemented data processing method of claim 1, wherein the threshold privacy risk score is determined by associating a weight for each question in the first set of questions.

3. The computer-implemented data processing method of claim 2, wherein associating a weight for each question in the first set of questions further comprises:

determining that a first question in the first set of questions identifies a greater privacy impact than a second question in the first set of questions; and

assigning a weight to the first question in the first set of questions that is greater than a weight to be assigned to the second question in the first set of questions.

4. The computer-implemented data processing method of claim 1, wherein determining the threshold privacy risk score for the particular campaign further comprises:

determining that a question in a particular question/answer pairing for the first plurality of question/answer pairings includes an answer, for the particular question/answer pairing, that provides a particular response; and

automatically determining that the threshold privacy risk score for the particular privacy campaign exceeds the threshold privacy risk value.

5. The computer-implemented data processing method of claim 1, wherein in response to determining that the threshold privacy risk score exceeds the threshold privacy risk value, the method further comprises:

providing, by the one or more processors, a notification to one or more privacy officers associated with the privacy campaign to indicate that the threshold privacy risk score exceeds the threshold privacy risk value.

6. The computer-implemented data processing method of claim 1, further comprising:

in response to determining that the threshold privacy risk score exceeds the threshold privacy risk value, providing, by the one or more processors, the privacy impact assessment to the user that includes a second set of questions for a second plurality of question/answer pairings that identify one or more privacy characteristics of the particular privacy campaign;

receiving, by the one or more processors, respective answers for the second plurality of question/answer pairings regarding the one or more privacy characteristics of the particular privacy campaign;

determining, by the one or more processors, an updated privacy risk score for the particular privacy campaign that identifies a level of risk for one or more of the privacy characteristics indicated in the second plurality of question/answer pairings;

comparing, by the one or more processors, the updated privacy risk score to the threshold privacy risk value, the threshold privacy risk value indicating a pre-determined level of risk regarding the one or more privacy characteristics of the particular privacy campaign;

determining, by the one or more processors, whether the updated privacy risk score exceeds the threshold privacy risk value;

in response to determining that the privacy risk score exceeds the threshold privacy risk value, providing, by the one or more processors, a notification to one or more privacy officers associated with the privacy campaign that the particular privacy campaign is a high privacy risk campaign; and

in response to determining that the privacy risk score does not exceed the threshold privacy risk value, storing, by the one or more processors, the indication that the particular privacy campaign is a low privacy risk campaign.

7. The computer-implemented data processing method of claim 1, wherein the threshold privacy risk value is configured to be set by one or more privacy officers associated with the privacy campaign.

8. The computer-implemented data processing method of claim 7, wherein the threshold privacy risk value is configured to be adjusted based on a type of campaign for the particular privacy campaign.

9. A computer-implemented data processing method for efficiently conducting privacy risk assessments for a plurality of privacy campaigns, the method comprising, for each of the plurality of privacy campaigns:

presenting, by one or more processors, a threshold privacy assessment to a user that includes a first set of one or more questions for a first plurality of question/answer pairings that identify one or more privacy characteristics of the particular privacy campaign;

receiving, by one or more processors, respective answers for the first plurality of question/answer pairings regarding the one or more privacy characteristics of the particular privacy campaign;

determining, by one or more processors, a privacy risk score for the particular privacy campaign that identifies a level of risk for one or more of the privacy characteristics indicated in the question/answer pairings;

comparing, by one or more processors, the privacy risk score to a threshold privacy risk value, the threshold privacy risk value indicating a pre-determined level of risk regarding the one or more privacy characteristics of the particular privacy campaign;

determining, by one or more processors, whether the privacy risk score exceeds the threshold privacy risk value;

providing, by one or more processors and to one or more privacy officers, (1) a first selection option to initiate a privacy impact assessment to be provided to the user that includes a second set of questions for a second plurality of question/answer pairings that identify one or more privacy characteristics of the particular privacy campaign, the second set of one or more questions includes one or more questions that are supplemental to the first set of one or more questions and (2) a second selection option to indicate that the particular privacy campaign is a low privacy risk campaign;

in response to receiving an indication of selection of the first selection option by the one or more privacy officers, providing, by one or more processors, the full privacy impact assessment to the user;

in response to providing the full privacy assessment to the user;

receiving, by one or more processors, respective answers for the second plurality of question/answer pairings regarding the one or more privacy characteristics of the particular privacy campaign;

using one or more computer processors, calculating a risk score based on the respective answers for the second plurality of question/answer parings and the one or more privacy characteristics of the particular privacy campaign, wherein calculating the risk score comprises;

electronically determining a weighting factor for each of the second plurality of question/answer parings, wherein the one or more privacy characteristics include;

a nature of personal data associated with the particular privacy campaign;

a physical location of the personal data associated with the particular privacy campaign;

a physical location of the personal data associated with the particular privacy campaign;

a number of individuals having access to the personal data associated with the particular privacy campaign;

a length of time that the personal data associated with the particular privacy campaign will be retained in storage; and

a type of individual from which the personal data associated with the particular privacy campaign originated; and

electronically determining a relative risk rating for each of the second plurality of question/answer pairings; and

electronically calculating the risk score based upon, for each respective one of the second plurality of question/answer pairings, the relative risk rating, and the weighting factor;

in response to receiving an indication of selection of the second selection option by the one or more privacy officers, storing, by one or more processors, an indication that the particular privacy campaign is a low privacy risk campaign.

10. The computer-implemented data processing method of claim 9, wherein the privacy risk score is determined by associating a weight factor with each question in the first set of questions.

11. The computer-implemented data processing method of claim 10, wherein associating a weight factor for each question in the first set of questions further comprises:

determining that a first question in the first set of questions identifies a greater privacy impact than a second question in the first set of questions; and

assigning a weight to the first question in the first set of questions that is greater than a weight to be assigned to the second question in the first set of questions.

12. The computer-implemented data processing method of claim 9, wherein determining the privacy risk score for the particular campaign further comprises:

determining that a question in a particular question/answer pairing for the first plurality of question/answer pairings includes an answer, for the particular question/answer pairing, that provides a particular response; and

automatically determining that the privacy risk score for the particular privacy campaign exceeds the threshold privacy risk value.

13. The computer-implemented data processing method of claim 9, wherein upon receiving an indication of selection of the first selection option by the one or more privacy officers further comprising, the method further comprises:

in response to determining that the privacy risk score exceeds the threshold privacy risk value, providing, by the one or more processors, the privacy impact assessment to the user that includes a second set of questions for a second plurality of question/answer pairings that identify one or more privacy characteristics of the particular privacy campaign;

receiving, by the one or more processors, respective answers for the second plurality of question/answer pairings regarding the one or more privacy characteristics of the particular privacy campaign;

determining, by the one or more processors, an updated privacy risk score for the particular privacy campaign that identifies a level of risk for one or more of the privacy characteristics indicated in the second plurality of question/answer pairings;

comparing, by the one or more processors, the updated privacy risk score to the threshold privacy risk value, the threshold privacy risk value indicating a pre-determined level of risk regarding the one or more privacy characteristics of the particular privacy campaign;

determining, by the one or more processors, whether the updated privacy risk score exceeds the threshold privacy risk value;

in response to determining that the privacy risk score exceeds the threshold privacy risk value, providing, by the one or more processors, a notification to one or more privacy officers associated with the privacy campaign that the particular privacy campaign is a high privacy risk campaign; and

in response to determining that the privacy risk score does not exceed the threshold privacy risk value, storing, by the one or more processors, the indication that the particular privacy campaign is a low privacy risk campaign.

14. The computer-implemented data processing method of claim 9, wherein the threshold privacy risk value is configured to be set by one or more privacy officers associated with the privacy campaign.

15. The computer-implemented data processing method of claim 14, wherein the threshold privacy risk value is configured to be adjusted based on a type of campaign for the particular privacy campaign.

16. A computer-implemented data processing method for efficiently conducting privacy risk assessments for a plurality of privacy campaigns, the method comprising, for each of the plurality of privacy campaigns:

presenting, by one or more processors, a threshold privacy assessment to a user that includes a first set of one or more questions for a first plurality of question/answer pairings that identify one or more privacy characteristics of the particular privacy campaign;

receiving, by one or more processors, respective answers for the first plurality of question/answer pairings regarding the one or more privacy characteristics of the particular privacy campaign;

determining, by one or more processors, a first privacy risk score for the particular privacy campaign that identifies a level of risk for one or more of the privacy characteristics indicated in the first plurality of question/answer pairings;

comparing, by one or more processors, the first privacy risk score to a first threshold privacy risk value, the first threshold privacy risk value indicating a pre-determined level of risk regarding the one or more privacy characteristics of the particular privacy campaign;

determining, by one or more processors, that the first privacy risk score exceeds the first threshold privacy risk value;

in response to determining that the first privacy risk score exceeds the first threshold privacy risk value, providing, by one or more processors, a privacy impact assessment to the user that includes a second set of questions for a second plurality of question/answer pairings that identify one or more privacy characteristics of the particular privacy campaign, the second set of one or more questions includes a greater number of questions than the first set of one or more questions;

receiving, by one or more processors, respective answers for the second plurality of question/answer pairings regarding the one or more privacy characteristics of the particular privacy campaign;

determining, by one or more processors, a second privacy risk score for the particular privacy campaign that identifies a level of risk for one or more of the privacy characteristics indicated in the second plurality of question/answer pairings, wherein determining the second privacy risk score comprises;

identifying a weighting factor for each of the second plurality of question/answer pairings, the second plurality of question/answer pairings including;

an indication of a physical storage location of personal data collected as part of the particular privacy campaign; and

an indication of a length of time that the personal data collected as part of the particular privacy campaign will be stored in the physical storage location;

electronically determining a relative risk rating for each of the second plurality of question/answer pairings;

electronically calculating the second privacy risk score based upon, for each of the second plurality of question/answer parings, the relative risk rating and the weighting factor; and

electronically associating the second risk score with the particular privacy campaign;

comparing, by one or more processors, the second privacy risk score to a second threshold privacy risk value, the second threshold privacy risk value indicating a pre-determined level of risk regarding the one or more privacy characteristics of the particular privacy campaign;

determining, by one or more processors, whether the second privacy risk score exceeds the second threshold privacy risk value;

in response to determining that the second privacy risk score exceeds the second threshold privacy risk value, providing, by one or more processors, an advanced privacy impact assessment to the user that includes a third set of questions for a third plurality of question/answer pairings that identify one or more privacy characteristics of the particular privacy campaign, the third set of one or more questions includes a greater number of questions than the second set of one or more questions; and

in response to determining that the second privacy risk score does not exceed the second threshold privacy risk value, storing, by one or more processors, an indication that the particular privacy campaign is a low privacy risk campaign.

17. The computer-implemented data processing method of claim 16, wherein the first threshold privacy risk value is different from the second threshold privacy risk value.

18. The computer-implemented data processing method of claim 16, wherein the step of determining the second privacy risk score includes incorporating the first privacy risk score in the determining of the second privacy risk score.

19. The computer-implemented data processing method of claim 16, wherein in response to determining that the first privacy risk score exceeds the first threshold privacy risk value, the method further comprises:

providing, by the one or more processors, a notification to one or more privacy officers associated with the privacy campaign to indicate that the first privacy risk score exceeds the first threshold privacy risk value.

20. The computer-implemented data processing method of claim 16, wherein the threshold privacy risk value is configured to be set by one or more privacy officers associated with the privacy campaign.