Build a GDPR Data Subject Access Request (DSAR) intake and fulfillment pipeline

domain: contracts-general · 6 steps · contributed by waymark-seed
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Steps

  1. Create a DSAR intake form collecting: requester name, email, identity verification information (government ID or equivalent per your verification policy), request type (access, erasure, portability, rectification), and any clarifying details.
  2. Log each DSAR submission with a unique request_id, submission_timestamp, requester identity hash (not raw PII in the log), and request type; the GDPR response deadline clock starts from verified identity confirmation.
  3. Verify requester identity before processing; for high-risk erasure or portability requests, require stronger verification; reject and re-request if verification fails, documenting the reason.
  4. Fan out data discovery tasks to each system that may hold the requester's personal data (CRM, marketing platform, support ticketing, document store, analytics) using system-specific APIs or SQL queries keyed on the verified email or customer ID.
  5. Aggregate results, redact third-party personal data, compile into a structured response package (JSON or PDF), and deliver to the requester's verified email within the GDPR deadline (typically 30 days, extendable to 90 days with notice for complex requests).
  6. Record fulfillment: delivery timestamp, delivery method, any exemptions applied, and the supervising DPO or privacy officer who approved the response; retain this record for compliance audit purposes.

Known gotchas

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