In our last post regarding GDPR, Jens outlined important aspects of the new regulation. Keeping these aspects in mind the GDPR implementation can turn out to be a challenging task.
The easiest way to save thousands on becoming GDPR compliant is to simply exclude all European users from visiting your website. This is a rather risky step and should not actually be considered. We did some real consideration and we help you to save time and money by using our guidelines and implementations to achieve GDPR compliance.
Basically the GDPR gives all internet users more rights to protect and control their personal data. Starting May 25th a natural person has the right to request information about what data was collected and for what reason. Furthermore a customer has the right to request the deletion of the entire user account including all data that could be used to identify her or him. In this article I want to show you how we implemented this request handling.
As the request handling gives data subjects the possibility to receive information about their processed data and to delete all data subject related information, you are facing 3 main challenges on your way to GDPR compliance:
You have to ensure,
- all collected data is consolidated and prepared in a commonly used machine-readable format,
- all data is exported and delivered to the person who requested it,
- if an account deletion is requested it has to be the account of the person who actually requested it and
- all data or the account deletion is processed without harming the system infrastructure.
We met all 3 challenges and implemented the needed functionalities into our ICM. In the following I will give you an overview how users can request their Personal Data or their Account Deletion via the storefront and how these requests are processed in the backoffice:
(GDPR request handling scheme for registered and unregistered users)
As shown in the request handling scheme, customers can request their data as registered and unregistered users. Thereby the process flow for unregistered users outlines the necessary extra effort to verify customer requests to prevent malpractice. The Customer Service Representative (CSR) needs to check the requests and to receive the customer confirmation before personal data is exported or an account is deleted. Now I will show you how we realized the request handling within our Intershop Commerce Management.
Request Handling for Registered Useres
At first we will take a closer look on the request handling for registered users:
(Screenshot 1 – data request as registered users via My Account)
As you can see in the screenshot above, users can request their personal data or the deletion of their account simply via the profile settings in their account section. Now a backoffice manager
very probably the CSR can process the personal data request by exporting all personal data into a zip-file and sending it to the customer who requested the data. Independently or additionally the CSR can delete the customer account if it is requested:
(Screenshot 2 – data request processing for registered users via backoffice)
This is how we enable consumers to get a record of all of their personal data or to delete their entire account including all personal information. Regarding registered users it is comparatively simple to verify the request origin.
Request Handling for Unregistered Users
When it comes to unregistered users the request verification needs a bit more effort. For unregistered users it is possible to request personal data or an account deletion via the Contact Us form:
(Screenshot 3 – data request as unregistered users via Contact Us)
This will trigger a process that is used to verify the request is coming from the right person and to prevent a malpractice of this function. To do so, the CSR will create the personal data or account deletion request in the backoffice:
(Screenshot 4 – data request processing for unregistered users via backoffice)
Now the respective user needs to confirm this request. This step is necessary to prevent an unintended deletion or data export. After the user verified the request the CSR can proceed and export and/or delete the customer data.
No matter how often these requests will be used, using our implementations will ensure your business to be GDPR compliant. And regarding the administrative fines, psosible compensation claims and/or reputational damage, GDPR compliance will save you more money than the achievement eventually costs.