Subject Rights Request Management

Subject rights request management refers to receiving, processing, and responding to requests from data subjects to exercise their data privacy rights, such as the right to access, rectify, delete, or restrict the processing of their personal data. Data subject rights requests can be one of the most visible aspects of your organization’s data privacy operations. Consumers (and, depending on the governing law, employees or other commercial partners) won’t always be aware of what work you do on a day-to-day basis, but they will notice if your privacy program is unable to meet their request within required timeframes or if your response contains errors. A streamlined subject rights request management process is critical to both complying with the law and preserving your organization’s reputation for trustworthiness.

Less Mature

With immature subject rights request management, your organization may not fully understand the relevant details associated with data subject rights under governing law, such as response deadlines, the requirements for fulfilling subject rights requests, individual rights held by data subjects, and more. Data subject requests may be received through general-purpose email inboxes, and information about rights may not be provided to data subjects. There may be no established process or system for tracking and fulfilling requests, leading to inconsistent handling and potential noncompliance.

More Mature

In a monitored or proactive process, you’ll have established procedures for receiving and processing requests and regularly measure those procedures and the subject rights management workflow for efficacy. This includes everything from disclosing data subject rights to accepting requests via a dedicated channel, verifying identities, tracking and prioritizing requests, automating requests, discovering data, transmitting data, and communicating with the requestor in a clear and timely fashion.

Keep in mind the importance of timely and accurate responses to subject rights requests—delayed responses serve as a signal to data subjects and authorities that your organization is noncompliant and can’t be trusted with personal information.

Recommended Next Steps

To mature your subject rights request workflow, consider taking the following actions:

• Transition from manual processes relying on email and spreadsheets to more automated workflow management solutions. Manually tracking and managing data subject rights requests contributes to missing deadlines, delivering erroneous or incomplete information to the data subject, and generating yet more data to manage.
• Implement a system for tracking and prioritizing requests.
• Train your colleagues who interact with stores of personal data on how they can help fulfill data subject rights requests.
• Establish a dedicated channel for accepting requests and communicating with requesters.
• Conduct a thorough data inventory to ensure you’re aware of where personal data is stored in your organization.
• Automate common request types, like data summaries, but retain an expert in the loop to verify and review.
• Provide appropriate information about data subjects’ rights in your privacy policy.
• Track metrics related to subject rights requests. Analyze and present trends to management for improving the subject rights request process on an ongoing basis.