The client faced the significant task of developing and implementing a global privacy program. This necessitated a comprehensive understanding and detailed mapping of their personal data processing activities across numerous decentralized systems and international operations.
The extensive scope involved documenting over 400 distinct processing activities within a stringent timeframe and a defined budget, requiring a proactive and efficient methodology.
OUR SOLUTION: STRATEGIC DATA MAPPING FOR GLOBAL COMPLIANCE
Myna partnered with the client to develop and deploy a tailored methodology that maximized efficiencies and delivered a comprehensive mapping of all data processing activities across their 30 global locations. Our strategic approach involved several key phases:
- Regional Segmentation & Pilot Program: We strategically defined five key geographical regions and identified pilot offices within each. This allowed for focused initial efforts and methodology refinement.
- Stakeholder Engagement & Intensive Data Gathering: We led data-gathering workshops with key stakeholders and process owners at the pilot offices. This hands-on approach ensured accurate and comprehensive data capture from the outset.
- Standardized Data Mapping: We completed and verified detailed, spreadsheet-based data maps for each processing activity within the pilot offices (averaging 30-35 maps per office). These served as validated templates.
- Guided Global Rollout: We facilitated weekly support and provided expert guidance to the non-pilot offices, region by region, empowering them to efficiently complete and verify their respective data maps using the established framework.
- Efficient Completion: The remaining 25 global offices successfully completed their data mapping by utilizing the pilot-tested data map templates, aligned to the specific needs of each region, ensuring consistency and quality.
Program Outcomes & IMPACT
The engagement delivered significant results, enabling the client to achieve its objectives:
- Global Privacy Comprehensive Data Visibility: All 30 global locations successfully completed data mapping. This captured the entire lifecycle of personal data for each process, crucially identifying associated IT assets and third-party processors.
- Foundation for Enhanced Privacy Governance: The detailed Data Maps directly supported essential updates to the client’s Privacy Notices and Data Subject Rights (DSR) processes. This formed the operational bedrock for their newly established global privacy program.
- Strategic Risk Mitigation & Executive Alignment: An executive presentation was delivered to senior stakeholders and outside counsel. This summarized high-level observations, identified potential gaps, and provided actionable recommendations to mitigate risks and ensure ongoing compliance.
