Types of Information in a Data Inventory
A data inventory can include the following types of personal information, depending on an organization’s business and the privacy laws for which it is subject to compliance:
- Personal Identifiable Information (PII), which includes data that directly identifies individuals, such as names, Social Security Numbers, and passport numbers – all subject to strict privacy protection.
- Biographical data, such as data of birth, gender and marital status.
- Contact information, including email addresses, phone numbers, and IP addresses.
- Financial data, such as credit card numbers and transaction histories.
- Health information, encompassing health records and medical history data that require special protection under healthcare privacy laws such as the Health Insurance Portability and Accountability Act (HIPAA).
- Employment data, including job applications and personnel records, which must be handled in accordance with employment privacy laws and practices.
- Geolocation data that reveals individuals’ geographical location, such as GPS coordinates.
- Web tracking data related to online behavior, such as cookies and browsing history.
- Social media data collected from social media accounts, including posts and connections.
- Consent and preferences that reflect individuals’ choices regarding their data.
The level of detail and specific data categories will vary depending on the business activity and industry in which an organization engages, as well as the relevant privacy regulations. With these types of data in a data inventory, an organization will be able to manage data responsibly, promptly respond to data subject requests (DSRs) or regulatory inquiries, and comply with privacy laws.
Process for Creating a Data Inventory
Organizations can establish a solid foundation for managing a data inventory that complies with privacy laws by following these five key steps:
- Data identification: Identify all data sources and data repositories within the organization, including databases, file servers, cloud storage, applications, and paper records. The goal is to begin with a comprehensive list of all locations where personal data is stored and processed.
- Data categorization: Categorize the data to distinguish personal data from non-personal data. The goal is to define the types of personal data the organization handles, such as PII, health data, financial information, and any other sensitive data categories.
- Data mapping: Map the flow of personal data within the organization, building an understanding of how data is collected, processed, transmitted and shared.
- Metadata collection: Gather metadata for each data asset. Metadata should include information about data sources, data categories, data owners, data subjects, data purpose, and data retention periods. This metadata is critical for tracking and managing data effectively.
- Documentation and records: Maintain detailed records of the data inventory, documenting the information about personal data assets, data sources, processing activities, data subject consents, and any relevant data retention and deletion policies. These records should be kept up to date and accessible for audits and compliance checks.
Creating a data inventory for privacy law compliance is an ongoing process that requires collaboration, process, and an in-depth knowledge of privacy regulations.
Managing a Data Inventory
Managing a data inventory requires a process to maintain, update, and ensure the accuracy of the data to meet the requirements of privacy laws. In addition to the data identification and categorization, and data mapping and documentation that are part of the data inventory development process, organizations should undertake these additional steps:
- Privacy risk assessment and security measures: Conduct privacy impact assessments (DPIAs), implement data security measures, and develop incident response plans to protect personal data.
- Data subject rights: Establish procedures for managing data subject requests (DSRs), including data retention and deletion policies.
- Employee awareness and training: Create a culture of privacy within the organization, promoting collaboration among privacy stakeholders, including Legal, IT and Privacy, among other functional areas involved with the privacy program or that use data. Provide training on privacy policies throughout the organization, and continuously monitor and audit the data inventory to ensure compliance and data protection.
By ensuring personal data is properly managed, secure, and used in accordance with applicable privacy regulations, organizations can feel confident they’re safeguarding privacy rights and reducing legal risks.
Value of a Data Inventory
While a data inventory is not explicitly required by privacy laws, it is a valuable tool for organizations to help them comply with obligations under various privacy regulations. For example, the information from a data inventory flows directly into a data map, which identifies and documents the types of data an organization collects, processes and stores. Without a data map – and the information from the data inventory – an organization would struggle to comply with many existing privacy regulations.
A data inventory delivers additional value:
- Transparency and accountability regarding the personal data an organization holds.
- Compliance assurance by demonstrating adherence to data protection requirements.
- Efficient data subject rights management, including consent and preferences.
- Risk mitigation support to prevent potential data incidents and breaches.
- Operational efficiency and cost savings through improved data management processes.
Relationship Between Data Inventory and Data Governance
A data inventory serves as the foundation of effective data governance, providing the necessary visibility and understanding of data assets, which is essential for creating and enforcing data governance policies and practices. Data governance encompasses policies, procedures, and controls that ensure data is used, managed, and protected effectively. The data inventory supports the enforcement of these policies by guiding organizations to track, classify and manage data that aligns with governance guidelines.
In addition, data governance often includes data lifecycle management, and a data inventory is critical for tracking and managing the entire data lifecycle, from data creation to archiving or deletion. It ensures data is handled in a manner consistent with data governance principles and legal requirements.
Data Inventory and Best Practices
Managing a data inventory using a data privacy management platform is an efficient way to ensure compliance with data privacy regulations and protect personal data. The use of automation provides significant advantages over manual processes, including best practices that include:
- Centralized data collection: The centralized collection of information about personal data assets, including data sources, data categories, data subjects, and processing activities ensures all relevant data is documented in a single location, making it easier to manage and maintain.
- Automated data discovery: Data discovery tools within a platform scan an organization’s data repositories and identifies all personal data, reducing the risk of missing critical data assets and helping to maintain an up-to-date inventory.
- Data classification and tagging: A data classification and tagging system assigns labels to data assets based on sensitivity, purpose, and legal requirements, making it easier to enforce access controls and track data throughout its lifecycle.
- Data mapping and visualization: A real-time data map and visualization helps privacy professionals understand how data moves within an organization, identify potential risks, and demonstrate compliance with privacy regulations, including cross-border data transfer requirements.
- Auditing and reporting: Regular auditing and reporting processes track changes in the data inventory, identify compliance issues, and create immediate alerts to any discrepancies, ensuring the data inventory remains accurate and up to date.
Difference Between a Data Inventory and Data Catalog
While a data inventory is primarily focused on compliance with privacy regulations, a data catalog is designed to make data more accessible and usable for a broader audience within an organization. The data inventory serves as a detailed record of all data assets, emphasizing the identification and documentation of personal data, sensitive information, and related metadata. Its primary goal is to ensure an organization understands how personal data is collected, processed and retained in accordance with privacy laws.
While a data catalog may include information about data sensitivity and classifications, its primary purpose is not privacy compliance but facilitating data discovery and collaboration. Data catalogs are user-centric and provide user-friendly interfaces for searching and accessing data assets, with a focus on enhancing data usability and promoting self-service analytics.
Enabling Innovation And Achieving Compliance
A data inventory is a foundational element of effective data management and a strong privacy program. It provides organizations with visibility into their data assets, supports data governance, and enables efficient data management. By following best practices and maintaining an up-to-date inventory, organizations can harness the full potential of their data, ensuring it remains a valuable asset that can be used responsibly to power its innovation while respecting privacy regulations.