Our client’s subcontractor had millions of unspecified records containing personal data that they were concerned about storing. Our team of Consultants helped them to identify exactly the data they were storing and processing and advised on which data to safely remove or null data that should be retained.

Our Consultants discovered 18.5 million personal data records that were not required, much of it historical, which invalidated their data protection documentation and cyber insurance. During the discovery phase we uncovered data that the company was unaware they were storing, and in addition to this, due diligence and security assessment findings had not been followed up.

The supplier was providing support from outside the EU which had not been agreed to or covered by a data processing contract with them. Our client was sending unnecessary personal data to their supplier, and the security on their supplied scanners was inadequate.

Customers of our retail client scanned in personal codes to access discounts and exclusive deals. Their details were retained for processing and analytics purposes; however, data was not removed as it expired or was no longer needed. It was also discovered that data was being stored in test and development environments.

“It was an interesting challenge, and a complex technical, and legal environment. The data protection issues were resolved with great co-operation from a client that was keen to do the right thing. ”
Stef Kunzer
LR Lead Consultant

After carrying out an immediate documentation review, our Consultants interviewed key stakeholders, held detailed workshops, and made further enquiries. Working with the technical and data architects to make sure that removing or nulling of the data would have no impact on their retail systems, we carried out detailed data analysis with the technical team, their external technical support, and the supplier.

We then provided Data Protection as a Service for our client and in line with data governance, we reported on what data they needed to retain and what must be removed.

Solution

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Delivering a presentation to the board with observations, recommendations, and actions Leading Resolutions assisted in turning this into a detailed project plan with adequate testing and checks. We explained how Leading Resolutions would support the execution with Data Protection and Security assurances.

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Business Outcomes

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15 % Increase
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15 Million
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98 Transactions
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Experts
on the project

Class aptent taciti sociosqu ad litora torquent per conubia nostra, per inceptos himenaeos.

Delivering a presentation to the board with observations, recommendations, and actions Leading Resolutions assisted in turning this into a detailed project plan with adequate testing and checks. We explained how Leading Resolutions would support the execution with Data Protection and Security assurances.