To be GDPR compliant is not an exercise of our legal unit only. We think that everybody should be sensitive if it comes to personal identifiable information (PII), be it our Engineering or our Marketing department. That is why we are using the collaborative features of LeanIX to gather all relevant information and keep this up-to-date at the source of the information.
This document describes how LeanIX as an organization captures GDPR relevant information in a LeanIX Workspace.
The following paragraph describes how we modeled the information in LeanIX to be able to generate a directory of all procedures.
Each application that processes data has a unique ID, in UUID format, and can be retrieved via the LeanIX workspace, e.g. b21d68b9-e404-46c0-88b7-5679c0d921e2
You can copy and paste this into the External ID field to establish direct linkage to external systems.
Description of the processing
The relation to the Business Capability defines the area of processing. In case of need for more information, this can be captured in the description field of an Application Fact Sheet
First description of an automated procedure
This information should be reflected in the Lifecycle of an Application Fact Sheet:
If this is not sufficient we use a Tag for this kind of information.
In the Application factsheet, we created a section in which the Data Management details can be added, stored, and edited.
We created two subsections Data Objects and GDPR.
The first section captures the Data Objects whit which the application deals, using the following scheme.
The affected Data Objects must be linked to the Application Fact Sheet. The CRUD information at this relation shows the type of processing. The associated Data Object must be the lowest available hierarchy.
We wanted to avoid a fine granular data model to make the assignment as easy as possible. This is our list of key data objects:
Here the users can specify how the application affects the Data Object.
Space provided to add additional specifications of data usage within the application, including the purpose of the processing and any “other” categories of personal data.
Categories of Personal Data
This is only relevant if the Data Objects are different per User Group. Otherwise, it is defined in the relations Application / User Group and Application / Data Object.
Users can prick from a predefined list of the most common options:
Special Categories of Personal Data
Users can indicate if there are special personal data involved in the usage of this application.
Time Limit for Erasure of Personal Data
Users can indicate when personal data will be deleted.
The second section captures the GDPR aspects of the data
This only needs to be completed if personal data is being processed by the application.
Space where users can indicate which LeanIX entity uses personal data for its own purposes, i.e the data controller.
Users can select from a Country list the Location of Servers and any service personnel processing our data.
Justification for processing/hosting in non-EU countries
Transfer of data to non-EU countries needs to be justified; Here the workspace users can select from a predefined list why the data is being processed or hosted outside the EU.
A recipient is anyone that has access to the data. In the Business Support Section, User Groups of the Application can be defined.
Usually, we expect “user groups” to be the recipient of personal data; but the recipient field allows to add any further recipients that are not part of a user group. Also, any relevant restrictions can be added (e.g. in general applicant data can be available to members of all departments – but this is limited to those involved in the hiring process)
As long as there are no external recipients, this will be "Data Owner Locations"
The users of LeanIX can add any additional external recipient locations from a list of countries.
Justification for transfer to Recipients in non-EU countries
In the case of the transfer of data to non-EU countries, the users can select a predefined reason for why this is happening.
Users of our workspace can select an entry out of a list of predefined options to make it easier for the responsible person to enter the appropriate legal basis (in our case within the LeanIX legal department):
Legal Basis Detail Information
Please provide more information about the legal basis of this Application if necessary.
Technical and Organizational Measures
General description of the technical and organizational security measures
Data Processing Information confirmed by Legal
If all GDPR-related data is completed, this will be confirmed by legal
Note: This selection requires that attributes were created on the respective Fact Sheet (Config Basic add on required)
We are using the Business Capability structure to primarily capture the area of processing. In our case, we have Capabilities like Demand, Marketing, Sales, Engineering, and Operations. A good start is to capture the functional structure of the company, even if this is not reflecting true business capabilities.
A basic User Group can be a legal entity of the corporation - in our case, we have LeanIX GmbH and LeanIX, Inc., our US-based subsidiary. Other User Groups are Legal Advisor, Tax Consultant, Auditor and Third Party Data Processor in general.
We distinguish between internal and external User Groups which we tag with 'Internal' or 'External'.
Guess what, we have more than 100 Applications. Yes, we are a very small company but have a lot of processes automated to be more efficient. We count every Excel Spreadsheet that is used in a business process a single Application, but this does not lead to the high number because we are very restrictive in using LeanIX for business-critical operations.
With only two Tags we manage the progress of our compliance project - SSO (needed/not needed, urgency) and DPA (in Germany: ADV) to know where we have an actual DPA in place. A nice side-effect is that we can show the progress on our Home Screen Dashboard.
This is the tricky part for non-IT experts. An IT Component can be a Hardware, a Software product or a Service. We create first for a Cloud Service an IT Component Type Service with the name SaaS. In the second step, we add the Provider to it. So we can create unique names for every service but comparable names for the SaaS services. The same applies to Hosting Services.
LeanIX contains collaboration features that may be useful for the GDPR use case and more information can be found here
Updated about 1 month ago