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20 Sep 2024
In an era dominated by digital interactions, the protection of users and their data privacy rights has become paramount. With the proliferation of GDPR (General Data Protection Regulation), CCPA (California Consumer Privacy Act), and many other regulations across different regions of the globe, organizations are under increasing pressure to ensure compliance while respecting user privacy.
Achieving this delicate balance can be daunting without the right tools and strategies in place. This is where compliance-driven automation emerges as a game-changer, empowering both users and organizations to navigate the complex landscape of privacy rights management effectively.
What is a data subject access request?
Data Subject Access Requests (DSARs) enable individuals to exercise their rights over their personal data. DSARs provide users with the transparency, control, and accountability needed to manage the collection, processing, and storage of their personal information. As regulatory mandates, such as GDPR and CCPA, emphasize the importance of individual privacy rights, DSARs serve as a mechanism for individuals to access, rectify, and manage their personal data, ultimately contributing to a more privacy-centric digital ecosystem.
Depending on jurisdiction, life sciences organizations must provide their consumers with the ability to send different types of DSAR requests that will then need to be collected, verified, fulfilled, and stored. Although the response time is consistent for most of the US State Privacy Laws (45 days, with one 45-day extension totaling 90 days), it is important to note that both CCPA and CPRA require a 15-day response time for opt-out requests.
The data subjects (who can be consumers and, in the case of GDPR consent management, employees) may have the right to
Access the data that have been collected from them and/or the categories of data collected
Delete the personal data that companies have collected
Correct the data
Opt out of the sale of personal data
Opt out of data processing
Port personal data
They exercise these rights via DSAR requests through channels such as web forms, emails, phone calls, or physical mails to privacy offices.
Without the right solution to help, managing DSARs can be very challenging and costly. Gartner estimates that a DSAR could cost about $1400 if handled manually, but there are also potential indirect costs that could impact the total DSAR fulfillment cost.
How can life sciences organizations handle DSARs better?
Life sciences organizations face several key challenges when manually responding to DSARs. These include
Ensuring timely responses can be difficult because of the volume and complexity of requests received. Each request requires careful identification, gathering, and review of potentially vast amounts of data dispersed across multiple systems and departments. This process is not only resource-intensive but also increases the risk of errors in data compilation and interpretation.
Verifying the identity of the requester is crucial in preventing unauthorized disclosures of sensitive information. Manual verification processes can be cumbersome and prone to human error, potentially compromising life sciences data security, as well as regulatory risk and compliance.
Maintaining consistency and accuracy in responses across different requests and jurisdictions is challenging.
Failure to respond within the stipulated time frames can result in regulatory penalties and damage to the reputation of the organization.
Getting started: Empowering users and driving compliance for life sciences
Life sciences organizations must begin by deploying advanced compliance-driven automation tools tailored to their specific needs. The optimal approach to DSAR requests revolves around implementing a comprehensive and efficient system leveraging automation and structured processes.
Organizations must streamline the entire request lifecycle from initial receipt to final response, addressing key challenges effectively. Our approach at each step:
A practical case study
Indegene recently helped a global life sciences organization design, create, and enable streamlined workflows for handling DSARs related to data deletion. OneTrust’s range of out-of-the-box workflows was utilized to significantly speed up implementation and ensure compliance with GDPR and CCPA guidelines. These pre-configured workflows come with built-in states and substates, which help standardize processes and maintain consistency across requests.
Let’s examine a generalized workflow for a Data Deletion DSAR request. These workflows are fully configurable and can be changed to organizational requirements and regulation guidelines for any country or region.
When an individual submits a request, it is initially unverified. The user receives an email to confirm their identity, ensuring that the request is indeed from the individual. After the request is verified, it is assigned to a business owner, who then forwards the request to all relevant system owners for the deletion of the individual’s data. Once each system owner has completed the deletion, a notification is sent to the user, confirming that their data have been successfully removed from the organization.
Adding value to privacy rights implementations
Additional value can be drawn from using leading-edge compliance technology such as ready-made accelerators and quick-start guides designed to expedite the set-up of compliance-driven automation workflows. Leveraging these resources can help facilitate rapid deployment, empowering organizations to uphold privacy rights effectively while enhancing operational agility. Some of these additional drivers of value can include
Customized Accelerators: Ready-made accelerators that integrate seamlessly with your organization’s existing systems, accelerating the implementation of privacy workflows
Quick-start guides: Comprehensive guides that enable teams to swiftly set up and configure privacy management workflows, reducing deployment timelines significantly
Ready-made workflows: Pre-created workflows incorporate best practices and compliance requirements
Standard notification templates: Standardized ready-to-use email templates for notifying individuals about their DSARs. Hence, saving time and effort in drafting responses for each request
Reporting and dashboards: Pre-built reports that help track and analyze DSAR metrics to understand the state of DSAR operations and detect potential issues around many critical areas, such as
State/country-wise DSAR intake volume
Insights on drop-offs in the DSAR submission process
TAT for request fulfillment (speed and volume)
Insights on process bottlenecks
Enabling compliance-drive automation for life sciences
Compliance-driven automation is pivotal to navigating the complexities of privacy rights management. By leveraging advanced tools and structured processes, organizations can ensure compliance with regulations such as GDPR and CCPA while empowering users to exercise control over their personal data. An effective DSAR solution not only helps mitigate compliance risk and reduce costs associated with DSAR fulfillment but also enhances organizational agility in responding to evolving privacy laws.
Indegene brings decades of life science expertise, helping your life sciences organization successfully embrace data-centric security, as well as automation-driven trust and accountability. Our tailored DSAR solutions, combining people, processes, and platforms are designed make your life sciences organization agile and compliant. Talk to us to learn more.
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