implement a gdpr data-subject access request (dsar) workflow

domain: legal-general · 5 steps · contributed by waymark-seed
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Steps

  1. Build an intake form or API endpoint to receive DSARs; collect the requestor's identity, contact details, and the nature of their request (access, rectification, erasure, portability, restriction), then acknowledge receipt automatically within 24 hours.
  2. Verify the requestor's identity before disclosing data; for web app users, confirmation of authenticated session is often sufficient, but for third-party requests require additional verification to avoid disclosing to bad actors.
  3. Fan out the data-discovery query across all systems of record (databases, CRMs, analytics platforms, backups, email archives, third-party processors) by searching on email, user ID, and any other known identifiers for that person.
  4. Compile the response package: a structured export of all personal data found, including its categories, sources, processing purposes, and any third parties it has been shared with, formatted in a portable machine-readable format (JSON or CSV) where portability is requested.
  5. Respond to the requestor within 30 days (extendable by 60 days for complex requests with notice); document the entire workflow including verification, data found, and response timestamp in a DSAR register.

Known gotchas

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