Why and How to Implement GDPR Compliance with Robotic Process Automation

Original post from https://www.cigen.com.au/cigenblog/

Data security is definitely one of the top priority problems on the present agenda of many organisations and governments. We have witnessed a number of large data breaches from large firms in 2017 and 2018 that have affected people all over the world.

As an attempt to deal with cyber breaches that might perturb essential human rights such as the right to privacy or the right to protection of one’s image and personal data, the European Union has approved the General Data Protection Regulation (GDPR) which will apply from May 25th 2018. The act is meant to boost consumers’ trust in online services, trust which has been greatly diminished lately due to events such as the above mentioned.

Australian companies that have an office in the EU, that offer online goods and services in the EU, or that monitor the behaviour of individuals in the EU (e.g., for preference prediction purposes), should make sure to abide to the new regulations by May 25th. Automation is among the procedures that can help, so we will give you some tips for how to implement GDPR compliance with robotic process automation.

The Australian legal equivalent of GDPR is the Australian Privacy Act from 1988. The two share the requirement of a “privacy by design” approach to compliance with privacy principles, of data anonymity, or the adoption of transparent handling practices of personal data (i.e., “personal information” in the terminology of the Privacy Act). The name or online identifier, location or bank account data, more generally – any physical, mental, economic, cultural, social, or cultural factors that identify a person, are examples of personally identifiable information (PII).

What’s new in GDPR?

The inclusion of the right to “data portability” (an additional individual right), the necessity to comply with all principles of processing personal data, or to implement data protection policies like ‘data protection by design and by default’ (Article 25).

“Data processing” (a phrase that doesn’t appear in the Privacy Act) refers to the collection, storage, use and transfer of PII. In a nutshell, GDPR offers stronger warrants of the right to be forgotten. For a deeper understanding the new GDPR requirements, you can consult the resources offered by the Office of the Australian Information Commissioner.

How does GDPR affect you?

Fine, so what does this actually mean for your company which is doing business in the EU? In the first place, it means that you should go through an audit to decide which of the new regulations actually apply to you.

Afterwards, upon familiarisation with European terminology and regulations, you should make sure that your business practices comply with GDPR. Last and most importantly, you should prove with proper documentation that all the customer PII can be removed from the system when no longer necessary. And you should do this quite fast, that is, before the 25th of May, when the GDPR comes into effect.

The right to be forgotten ought to be guaranteed by implementation of the required practices in the usual functioning of your business. This should be done by the end of May, so you should act fast to ensure compliance with GDPR.

To this end, you can rely on software robots since you know that:

automated processes run much quicker and error-free
RPA is a trustworthy ally when it comes to minimising security risks
RPA can help with a modern approach to legal compliance in general

Compliance with the new regulations for the EU is just one illustration of the generic beneficial effect of software robots in minimising the nightmarish efforts from the part of human employees and surpassing their lack of scalability.

Why Implement GDPR Compliance with Robotic Process Automation?

Let us now look at some more concrete reasons that call for the implementation of GDPR compliance with robotic process automation. We list 5 types of actions that bots can perform, thereby rendering GDPR compliance more accessible. The list should be read as arguments advocating software robots’ efficacy in compliance.

Handle customer data in conformity with GDPR regulations meant to ensure safety. Managing customer data is not only operationally simplified (compared with manual management, done by means of cross-system shares with the all-mighty copy-paste procedure) when performed by software robots, but also less expensive.
Handle customer consent. For instance, software robots could create the double data entries involved in checking customer data against consent and revocation databases. The fleet of robots can check customers’ consent and revoke requests, and further, even implement high-level decision making in order to act in accordance with the results of the requests check. RPA can handle customer consent consistently, across various systems where bits of that data are located. This potential of RPA is a gold mine for marketing functions, because it mitigates the risk of consent related non-compliance.
Align with data security measures. RPA easily complies with the requirement of data anonymity by, e.g., use of pseudonyms instead of real names and storage of the pseudonyms in the system. More, it can spontaneously inform customers about potential data breaches, thereby minimising the inconvenience in case of such a disaster scenario.
Streamline adherence to GDPR. The tasks involved in the manual implementation of compliance are highly repetitive, time-consuming and dull. Moreover, as reported by McKinsey & Company, the process is burdensome, and has high running costs. Use of RPA for GDPR compliance is thus a much needed simplification. Especially when the future demand for services such as data protection by design and by default is expected to be high, it is fully justified to bear the costs of RPA implementation and maintenance. On the long run, the return on investment should make automation a more cost-competitive solution than manual data processing.
Automatically prove compliance. The generation of reports and audit logs is a default outcome of GDPR compliance with robotic process automation. This benefit is peculiar to enterprise-wide automation platforms.

How to Implement GDPR Compliance with Robotic Process Automation

This is a very brief algorithm comprising the points that must be touched upon on the way towards GDPR compliance:

Compile a database with all details about Personally Identifiable Information (PII) storage (what data, where, for how long, etc.);
Discuss with relevant persons (e.g., other stakeholders, direct responsibles with data protection) which part of the records in the database must be really forgotten, and which may be saved (if any);
Design the software infrastructure accordingly. For instance, you could implement a rule of the kind “if data element is PII and relevant stakeholder(s) not active, then overwrite with §§§§§§§”;
Acknowledge system constraints regarding the permission for PII manipulation (who, to what extent);
Assess the data network with the aim of deciding what other data may identify people;
Decide what data can be saved in the robots’ logs. The outcome will be the generation of audit logs and reports.

Conclusion

We conclude with a larger scale perspective of the “how” question in the title. Yet we remain on the practical side of things. The UiPath Enterprise RPA Platform is one system that encompasses all the above mentioned compliance measures that are among software robots’ capacities.

By streamlining GDPR compliance with robotic process automation, it also gives a concrete example of how RPA supports enterprise compliance modernisation. That is, it improves and simplifies customer data management, and, in the long run, it contributes to cost reduction. Therefore the platform seems to be an adaptive “must” in the dynamic and increasingly complex information society.