Within the upcoming EU General Data Protection Regulation (GDPR) the term data subject is used for the persons for whom we must protect the privacy.
These are the persons we handle as entities within party Master Data Management (MDM).
In the figure below the blue area covers the entity types and roles that are data subjects in the eyes of GDPR
While GDPR is of very high importance in business-to-consumer (B2C) and government-to-citizen (G2C) activities, GDPR is also of importance for business-to-business (B2B) and government-to-business (G2B) activities.
GDPR does not cover unborn persons which may be a fact of interest in very few industries as for example healthcare. When it comes to minors, there are special considerations within GDPR to be aware of. GDPR does not apply to deceased persons. In some industries like financial services and utility, the handling of the estate after the death of a person is essential, as well as knowing about that sad event is of importance in general as touched in the post External Events, MDM and Data Stewardship.
One tough master data challenge in the light of GDPR will be to know the status of your registered party master data entities. This also means knowing when it is a private individual, a contact at an organization or an organization or department hereof as such. From my data matching days, I know that heaps of databases do not hold that clarity as reported in the post So, how about SOHO homes.
Being ready for the EU GDPR (European Union – General Data Protection Regulation) is – or should be – a topic on the agenda for European businesses and international businesses operating with an European reach.
The finish date is fixed: 25th May 2018. What GDPR is about is well covered (perhaps too overwhelmingly) on the internet. But how do you get there?
Below is my template for a roadmap:
The roadmap has as all programs should have an as-is phase, here in concrete as a Privacy Impact Assessment covering what should have been done, if the regulation was already in force. Then comes the phase stating the needed to-be state with the action plan that fills the gaps while absorbing business benefits as well. And then implementation of the prioritized tasks.
GDPR is not only about IT systems, but to be honest, for most companies it will mostly be. Your IT landscape determines which applications will be involved. Most companies will have sales and marketing applications holding personal data. Human Resource Management is a given too. Depending on your business model there will be others. Remember, this is about all kind of personal data – that includes for example supplier contact data that identifies a person too.
The skills needed spans from legal, (Master) Data Management and IT security. You may have these skills internally or you may need interim resources of the above-mentioned kind in order to meet the fixed finish date and being sure things are done right.
By the way: My well skilled associates and I are ready to help. Get in contact:
The upcoming enforcement of the EU General Data Protection Regulation (GDPR) is an attempt to harmonize the data protection and privacy regulations across member states in the European Union.
However, there is room for deviance in ongoing national law enforcement. Probably article 87 concerning processing of the national identification number and article 88 dealing with processing in the context of employment is where we will see national peculiarities.
National identification numbers are today used in different ways across the member states. In The Nordics, the use of an all-purpose identification number that covers identification of citizens from cradle to grave in public (tax, health, social security, election and even transit) as well as private (financial, employment, telco …) registrations have been practiced for many years, where more or less unlinked single purpose (tax, social security, health, election …) identification numbers are the norm most places else.
How you treat the employment force and the derived ways of registering them is also a field of major differences within the Union, and we should therefore expect to be observant of national specialties when it comes to mastering the human resource part of the data domains affected by GDPR.
Do you see other fields where GDPR will become national within the Union?
In legal lingo data portability means: “Where the data subject has provided the personal data and the processing is based on consent or on a contract, the data subject shall have the right to transmit those personal data and any other information provided by the data subject and retained by an automated processing system, into another one, in an electronic format which is commonly used, without hindrance from the controller from whom the personal data are withdrawn.”
In other words, if you are processing personal data provided by a (prospective) customer or other kind of end user of your products and services, you must be able to hand these data over to your competitor.
I am sure, this is a new way of handling party master data to almost every business. However, sharing master data with your competitor is not new when it comes to product master data as examined in the post Toilet Seats and Data Quality.
As Ditte writes, the core implication of GDPR is: “Up until now, businesses have traditionally ‘owned’ the personal data of their customers, employees and other individuals. But from May 25th, 2018 individuals will be given several new personal data rights, putting the ownership right back in to the hands of each individual”.
I agree with Ditte that the GDPR coming into force can be seen as an opportunity for businesses instead of a burden. Adhering to GDPR will urge you to:
Have a clear picture about where you store personal data. This is not bad for business too.
Express a common understood idea about why you store personal data. Also very good for business.
Know who can access and update personal data. A basic need for risk handling in your business.
Document what kind of personal data you handle. Equally makes sense for doing your business.
Think through how you obtain consent to handle personal data. Makes your business look smart as well.
In fact, after applying these good habits to personal data you should continue with other kind of party master data and all other kinds of master data. The days of trying to keep your own little secret, even partly to yourself, versions of what seems to be the truth is over. Start working in the open as exemplified in the concept of Master Data Share.
When you buy stuff one of the characteristics you may emphasis on is where the stuff is made: The country of origin.
Buying domestic goods has always been both a political issue and something that in people’s mind may be an extra quality sign. When I lived in The UK I noticed that meat was promoted as British (maybe except from Danish bacon). Now when back in Denmark all meat seems to be best when made in Denmark (maybe except from an Argentinian beef). However, regulations have already affected the made in marking for meat, so you have to state several countries of origins in the product lifecycle.
Country of origin is a product data element that you need to handle for regulatory reasons not at least when moving goods across borders. Here it is connected with commodity codes telling what kind of product it is in the custom way of classifying products as examined in the post Five Product Classification Standards.
When working with product data management for products that moves cross border you are increasingly asked to be more specific about the country of origin. For example, if you have a product consisting of several parts, you must specify the country of origin for each part.
This survey points to that the main reason why this does that take place is that manufacturers need to mature in handling and consolidating product information internally, before they are confident in sharing the detailed data elements (in an automated way) with their downstream partners. This subject was elaborated in the post Product Information Sharing Issue No 1: We Need to Mature Internally.
Issue no 3 is the apparent absence of a good solution for sharing product information with trading partners that suites the whole business ecosystem. I guess it is needless to say to regular readers of this blog that, besides being able to support issue no 1 and issue no 2, that solution is Product Data Lake.