GDPR – Individual Rights
1. Right to be informed
2. Right to access (SAR)
3. Right to rectification
4. Right to erasure ( right to be ‘forgotten’)
5. Right to restrict processing
6. Right to data portability
7. Right to object
8. Right related automated decision making and
profiling
Elements of data portability
• Access to personal data based on consent or contract (which data
subject is a party)
• Strictly limited to automated processing by Data Controller
• Data must be structured, commonly used and machine readable
• Access to data subject’s personal data without ‘hindrances’ by
other data controllers
• Limited to information provided by data subject
• Includes information generated due to use of service
• Excludes inferred information generated by data controller
• Must consider third party personal data during transfer - individual
rights/personal use and
• Data transfer between data controllers ought to be ‘interoperable’
GDPR – Data Portability
Access Request Data portability
Time One month One month
Type of data All personal data •Personal data provided to a controller;
•Processing based on consent or for the
performance of a contract; and
•Processing is carried out by automated means.
fee Possibly ( excessive and repetitive) Free of charge
Proof of identity Yes – drivers licence, recent utility bill etc. Yes – password or unique identifier
Procedure Individual/third party Individual/third party (other than solicitors firm).
Request extension Two months ( write to explain reason for
extension within a month)
Two months ( write to explain reason for
extension within a month)
Way forward
• Check your business areas for data portability
and inform team leader
• Website and Intranet will be updated re:
changes ( before the end of the next financial
year i.e. 2017 - 18)
• Develop templates to support process?

GDPR – Data Portability

  • 1.
    GDPR – IndividualRights 1. Right to be informed 2. Right to access (SAR) 3. Right to rectification 4. Right to erasure ( right to be ‘forgotten’) 5. Right to restrict processing 6. Right to data portability 7. Right to object 8. Right related automated decision making and profiling
  • 2.
    Elements of dataportability • Access to personal data based on consent or contract (which data subject is a party) • Strictly limited to automated processing by Data Controller • Data must be structured, commonly used and machine readable • Access to data subject’s personal data without ‘hindrances’ by other data controllers • Limited to information provided by data subject • Includes information generated due to use of service • Excludes inferred information generated by data controller • Must consider third party personal data during transfer - individual rights/personal use and • Data transfer between data controllers ought to be ‘interoperable’
  • 3.
    GDPR – DataPortability Access Request Data portability Time One month One month Type of data All personal data •Personal data provided to a controller; •Processing based on consent or for the performance of a contract; and •Processing is carried out by automated means. fee Possibly ( excessive and repetitive) Free of charge Proof of identity Yes – drivers licence, recent utility bill etc. Yes – password or unique identifier Procedure Individual/third party Individual/third party (other than solicitors firm). Request extension Two months ( write to explain reason for extension within a month) Two months ( write to explain reason for extension within a month)
  • 4.
    Way forward • Checkyour business areas for data portability and inform team leader • Website and Intranet will be updated re: changes ( before the end of the next financial year i.e. 2017 - 18) • Develop templates to support process?