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      Data Processing Lifecycle Overview and Guidance

      *This is a procedural-level supporting document to the Data Privacy - Classification and Handling Policy.

      Introduction

      The purpose of this document is to provide procedural guidance aligned with the Data Processing Lifecycle diagram. This document ensures consistent application and understanding of data processing phases (Collection, Storage, Use, Transfer, and Disposal) across all privacy-related activities. It serves as a framework-agnostic guide for implementing privacy lifecycle processes and can be used alongside tools like Jira, spreadsheets, or dedicated data inventory systems.


      *This is a procedural-level supporting document to the Data Privacy - Classification and Handling Policy, specifically addressing the sections "Classification of Information" and "Labeling of Information," which directly references the Data Processing Lifecycle Tracker.

      Objective

      The primary objective of this document is to:

      1. Establish a clear and actionable procedural approach to the Data Processing Lifecycle.
      2. Ensure alignment with privacy frameworks while remaining agnostic to any specific framework.
      3. Provide a reference tool to internal stakeholders for managing Personally Identifiable Information (PII) effectively.

      Data Processing Lifecycle Phases

      The Data Processing Lifecycle consists of five key phases: Collection, Storage, Use, Transfer, and Disposal. Each phase involves specific stakeholders and activities that are critical to managing Personally Identifiable Information (PII). Refer to the diagram below for a visual representation of the lifecycle and the interactions between stakeholders:

      1. Collection:
          • Stakeholders/Actors: Data Subject, Data Controller, Data Processor, Third Party.
          • Activities: User registration, PII collection, and transfer from third parties.
          • Tools/References: Input data into spreadsheets, Jira tickets, or inventory tools.
      2. Storage:
          • Stakeholders/Actors: Data Controller, Data Processor.
          • Activities: Secure storage of PII with documented access controls.
          • Tools/References: Use encrypted storage mechanisms and maintain records in tools.
      3. Use:
          • Stakeholders/Actors: Data Controller, Data Processor, Data Subject.
          • Activities: Processing and consumption of PII.
          • Tools/References: Ensure usage complies with consent and documented policies.
      4. Transfer:
          • Stakeholders/Actors: Data Controller, Data Processor, Third Party.
          • Activities: Secure transfer of PII to authorized parties.
          • Tools/References: Use secure transfer protocols (e.g., TLS).
      5. Disposal:
        • Stakeholders/Actors: Data Controller, Data Processor.
        • Activities: Secure deletion of PII when no longer required.
        • Tools/References: Document disposal procedures and confirm completion.

      Guidance Outline

      1. Interpret the Lifecycle Diagram:
        • Understand each phase’s key activities, stakeholders, and data flow as shown in the attached diagram.
        • Use the arrow key to differentiate between data flow, instructions, and services.
      2. Referencing Tools:
        • Leverage the accompanying spreadsheet to map activities within each phase.
        • Utilize Jira or other data inventory tools for tracking and compliance management.

      Implementation Steps

      1. Preparation:
        • Familiarize yourself with the Data Processing Lifecycle diagram.
        • Ensure access to required tools (e.g., spreadsheets, Jira, data inventory tools).
      2. Collection Phase:
        • Identify sources of PII.
        • Record data collection methods and associated consent.
      3. Storage Phase:
        • Implement secure storage protocols.
        • Maintain an audit trail for all stored PII.
      4. Use Phase:
        • Verify PII usage aligns with the defined purpose and legal basis.
        • Monitor and document PII usage.
      5. Transfer Phase:
        • Use encrypted transfer methods and document transfers.
        • Ensure third parties adhere to data protection agreements.
      6. Disposal Phase:
        • Follow secure deletion protocols.
        • Validate and document the successful deletion of PII.

      References

      1. Data Processing Lifecycle Tracker Template
      2. Trustero curated privacy content for additional guidance
      3. Tools: Jira, data inventory systems, and spreadsheets

      This document is intended to support internal stakeholders in effectively managing the Data Processing Lifecycle and ensuring alignment with privacy principles.