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Summary

The demand for GDPR compliance tools is growing. Technology vendors, eager to carve out a piece of this burgeoning market, are offering a diverse swath of solutions that tackle various aspects of the broad regulation. However, two primary approaches are emerging in the solution market: those that depend more on technology and those that depend more on existing organizational processes and workflows. The better approach is a matter of debate.

Technology versus process: Which solution approach is best?

As a rule, GDPR is technology-agnostic and process-centric. Aside from a few references to standard security measures such as encryption and high availability of systems, the regulation makes scant mention of specific technology. There is good reason for this: technology evolves much more quickly than regulatory and legal frameworks. If the regulation were to endorse or depend on the viability of specific technologies, it would quickly become obsolescent and unable to adequately fulfill its role of protecting the information and rights of data subjects. Nevertheless, technology will be a critical component to fulfilling GDPR's requirements. After all, the regulation pertains to the protection of data, and data is stored and processed in technology-based systems.

In reality, compliance with GDPR requires two major components: direct technical control of data assets, and the existence and documentation of repeatable human processes. Neither can exist in isolation.

Given this mix of needs, the landscape of vendors offering GDPR-related solutions is largely evolving into two camps: those that take a technology-based approach and those that take a process-based approach. Both methodologies depend on software to typically provide a centralized interface for task management and human interaction with data, but they tend to differ in their objectives and execution. While broad generalizations are not entirely useful, as some products use an overlapping approach, the general distinction is as follows:

  • A technology-based approach depends on technology-based mechanisms to meet specific technical requirements, such as the encryption of data. Automation of data handling and data manipulation is common. These solutions are likely to assign rigid roles to product users, and typically come with their own preconfigured workflows and templates. Direct technical control of data assets is often the primary objective.

  • A process-based approach largely relies on existing roles, workflows, and processes within the enterprise, with technology as a facilitator rather than as the primary mechanism. Manual handling of data, such as assignment of policies to data, is often required. These solutions are likely to offer flexible, customizable workflows and are likely to adopt existing roles within the enterprise rather than imposing their own within the product. Documentation and record-keeping of processes, instead of direct data control, is often the primary objective.

Neither approach is right nor wrong; a technology-based solution may excel at automatically applying policies to data that has been identified as personal, whereas a process-based solution would be far better suited to Article 35's requirements for repeatedly conducting data protection impact assessments (DPIAs). Given that the regulation is broad and encompasses a mix of technical and process requirements, an organization would benefit from using a mix of solutions that are either technology or process-based, depending on which articles of the regulation are being addressed.

However, for any GDPR solution to be successful in the enterprise, it needs to piggyback off existing human processes and roles. Otherwise, it is bound to become siloed and underused. Two camps may be forming in the GDPR compliance landscape, but the ultimate winners will likely be solutions that successfully adopt aspects of both approaches, applying each for their respective strengths.

Appendix

Further reading

GDPR and the Critical Importance of Locating Personal Data, IT0014-003324 (August 2017)

"GDPR compliance will require an integrated, multi-solution approach," INT002-000035 (December 2017)

"For GDPR compliance, documentation is just as important as execution," IT0014-003271 (May 2017)

Author

Paige Bartley, Senior Analyst, Data and Enterprise Intelligence

paige.bartley@ovum.com

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