To be GDPR compliant is not an exercise of our legal unit only. We think that everybody should be sensitive if it comes to personal identifiable information (PII), be it our Engineering or our Marketing department. That is why we are using the collaborative features of LeanIX to gather all relevant information and keep this up-to-date at the source of the information.
This document describes how LeanIX as an organization captures GDPR relevant information in a LeanIX Workspace. The content is reflecting the content of the procedures directory. We keep all information in English.
The following paragraph describes how we modeled the information in LeanIX to be able to generate a directory of all procedures.
Each processing has a unique ID, in UUID format, and can be retrieved via the LeanIX workspace, e.g. b21d68b9-e404-46c0-88b7-5679c0d921e2
Please copy and paste this into the External ID field.
Description of the processing
The relation to the Business Capability defines the area of processing. In case of need for more information, this can be captured in the description field of an Application Fact Sheet
First description of an automated procedure
This information should be reflected in the Lifecycle of an Application Fact Sheet:
- Phase-In, in case of a new release. As an alternative, this can be even reflected in a cloned successor application
If this is not sufficient we use a Tag for this kind of information
Type of processing
The affected Data Objects must be linked to the Application Fact Sheet. The CRUD information at this relation shows the type of processing. The associated Data Object must be the lowest available hierarchy.
Available Data Objects are:
- Employee / Contact & Login
- Employee / Full data
Responsible Business Area
We store the Domain at a Fact Sheet.
Please select one or many of the below:
- Fulfilment of contractual obligations towards customers
- Usage of application by employees in order to fulfill their tasks
- HR Administration
Use the select field with a list of predefined options to make it easier for the responsible person to enter the appropriate legal basis (will be completed by LeanIX legal department):
- Art. 88 GDPR, § 26 BDSG -> All employee and applicant related data
- Art 6 (1) (b) GDPR -> Existing Customers and Prospects
- § 7 UWG -> Electronic Direct Marketing with a consent
- Art 6 (1) (f) GDPR -> Direct Marketing without consent, e.g. targeting (category should be avoided as far as possible)
Categories of affected persons and data categories
This is only relevant if the Data Objects are different per User Groups. Otherwise it is defined in the relations Application / User Group and Application / Data Object.
Origin of data
Describe how and from whom we get the data at the relation between Application and Data Object. Please select one of the two options:
- Data provided by data subject itself
- Data provided by LeanIX
A recipient is an organization that has access to the data because they need the data to fulfill their services. Due to the size of your company we don't split User Groups in Departments, but distinguish between LeanIX GmbH and LeanIX, Inc. All other parties are named with their service e.g. Accounting, Legal Services or Third-party data processing.
Mark the User Group with a Tag "Internal"
Mark the User Group with a Tag "External"
Third countries / international organizations
To identify the transmission to a third party the party must be defined as an IT Component with a defined location where they provide the service (in terms of data processing).
Name and Address of Recipient
The name and full address of the Provider of the service (legal entity) is entered in the location field of the Provider Fact Sheet.
Documentation of reasonable warranties
This service gets Tags like "ADV", "EU Model clauses", "ISO 27001", ...
This information will be kept in the Deadlines field at the relation Application / Data Object (will be completed by LeanIX legal department)
Reference either to LeanIX own TOMs or link to supplier TOMs in data processing agreements (will be completed by LeanIX legal department)
We are using the Business Capability structure to primarily capture the area of processing. In our case, we have Capabilities like Demand, Marketing, Sales, Engineering, and Operations. A good start is to capture the functional structure of the company, even if this is not reflecting true business capabilities.
A basic User Group can be a legal entity of the corporation - in our case, we have LeanIX GmbH and LeanIX, Inc., our US-based subsidiary. Other User Groups are Legal Advisor, Tax Consultant, Auditor and Third Party Data Processor in general.
We distinguish between internal and external User Groups which we tag with Internal or External.
We wanted to avoid a fine granular data model to make the assignment as easy as possible. This is our list of data objects.
Persons in recruiting process.
Customers after contract signing (incl. churned).
Employee / Contact & Login
Active and former personnel. Login Data for Applications only
Employee / Full Data
Active and former personnel. Complete information such as address
Work with LeanIX to consult or sell.
Organizations and persons in pre-sales phase.
Deliver services for LeanIX processes (both product and internal).
Guess what, we have more than 100 Applications. Yes, we are a very small company but have a lot of processes automated to be more efficient. We count every Excel Spreadsheet that is used in a business process a single Application, but this does not lead to the high number because we are very restrictive in using LeanIX for business-critical operations.
With only two Tags we manage the progress of our compliance project - SSO (needed/not needed, urgency) and DPA (in Germany: ADV) to know where we have an actual DPA in place. A nice side-effect is that we can show the progress on our Home Screen Dashboard.
This is the tricky part for non-IT experts. An IT Component can be a Hardware, a Software product or a Service. We create first for a Cloud Service an IT Component Type Service with the name SaaS. In the second step, we add the Provider to it. So we can create unique names for every service but comparable names for the SaaS services. The same applies to Hosting Services.
soon to come