PRPO-10

Do you have a documented process for managing automated processing, including validations, monitoring, and data subject requests?

Explanation

This question is asking whether your organization has formalized procedures for handling automated data processing activities. Automated processing refers to any operations performed on personal data by automated means without human intervention, such as algorithmic decision-making, automated profiling, or batch processing of data. The question specifically asks about three key components: 1. Validations: Mechanisms to ensure the accuracy, quality, and integrity of data being processed automatically 2. Monitoring: Systems to oversee automated processes to detect errors, biases, or unauthorized processing 3. Data subject requests: Procedures for handling individuals' rights requests related to automated processing (such as the right to object to automated decision-making) This question is being asked in a security assessment because automated processing can introduce specific privacy and security risks. Without proper governance, automated systems might process data incorrectly, make biased decisions, or violate individuals' rights. Regulations like GDPR specifically address automated processing, including the right not to be subject to purely automated decisions with significant effects. To best answer this question, you should: - Describe your documented processes for managing automated processing - Explain how you validate data inputs and outputs in automated systems - Detail your monitoring approach for automated processing - Outline how you handle data subject requests related to automated processing - Reference any relevant policies, procedures, or technical controls - Mention compliance with applicable regulations (GDPR, CCPA, etc.)

Example Responses

Example Response 1

Yes, our organization maintains comprehensive documented processes for managing automated processing activities We have a formal Automated Processing Governance Policy that outlines requirements for all automated data processing systems For validations, we implement a multi-layered approach including input validation, data quality checks, and output verification for all automated processes Our Engineering and Data Science teams use a validation framework that tests automated processes against predefined test cases before deployment and periodically thereafter For monitoring, we utilize a combination of automated alerts, logging systems, and regular audits Our monitoring platform tracks processing metrics, error rates, and anomaly detection with dashboards reviewed daily by our operations team For data subject requests, we have implemented a dedicated workflow within our privacy management platform that allows our Privacy Office to identify where automated processing occurs for a specific individual and execute appropriate actions (providing information about logic involved, stopping processing, enabling human review of decisions, etc.) All these processes are documented in our Automated Processing Procedures manual, which is reviewed annually and updated as needed.

Example Response 2

Yes, we have established a documented Automated Processing Management Framework that governs all our automated data processing activities For validations, each automated process undergoes a three-stage validation protocol: (1) pre-implementation testing against synthetic data, (2) controlled parallel processing with manual verification, and (3) ongoing periodic validation checks Our Data Quality team oversees this validation process using our custom validation toolset For monitoring, we employ a real-time monitoring system that tracks all automated processing activities with alerts configured for anomalies, processing errors, or unusual patterns Weekly automated processing reports are generated and reviewed by our Security and Privacy teams For data subject requests, we have integrated automated processing considerations into our broader Data Subject Rights Procedure When we receive requests related to automated processing (such as requests for explanation or human intervention), our Privacy Coordinator routes these to the appropriate technical team who can temporarily pause processing, extract logic explanations, or implement human review as required All these processes are documented in our Data Processing Operations Manual and are subject to annual internal audit.

Example Response 3

No, we currently do not have a fully documented process specifically for managing automated processing While we do perform some validations on our automated systems through our general QA processes, and we have basic monitoring in place through our infrastructure monitoring tools, these are not specifically tailored to address the unique requirements of automated data processing Additionally, our data subject request handling process does not currently include specific provisions for automated processing scenarios We recognize this as a gap in our privacy program and have initiated a project to develop comprehensive automated processing governance We expect to have formal documentation and processes in place within the next quarter, including specific validation protocols, enhanced monitoring capabilities, and updated data subject request procedures that address automated processing concerns.

Context

Tab: Privacy
Category: Privacy Policies and Procedures