U.S. patent application number 12/831035 was filed with the patent office on 2011-11-03 for international cross border data movement.
This patent application is currently assigned to Bank of America Corporation. Invention is credited to Tammy Alvarez, Scott Margolis.
Application Number | 20110270768 12/831035 |
Document ID | / |
Family ID | 44859011 |
Filed Date | 2011-11-03 |
United States Patent
Application |
20110270768 |
Kind Code |
A1 |
Alvarez; Tammy ; et
al. |
November 3, 2011 |
International Cross Border Data Movement
Abstract
In some embodiments, a data movement system comprises a memory
and a workflow manager. The memory is operable to store a request
to move data from one or more jurisdictions, the request comprising
(a) a data type, (b) a jurisdiction from which the data is to be
moved, and (c) a purpose for moving the data. The workflow manager
is configured to identify a set of data movement rules based at
least in part upon the request. The set of data movement rules are
associated with regulations of the jurisdiction identified in the
request. The workflow manager is configured to apply at least one
rule of the set of data movement rules to identify an action item
to be completed in order to comply at least in part with the
regulations.
Inventors: |
Alvarez; Tammy; (Waxhaw,
NC) ; Margolis; Scott; (Coppell, TX) |
Assignee: |
Bank of America Corporation
Charlotte
NC
|
Family ID: |
44859011 |
Appl. No.: |
12/831035 |
Filed: |
July 6, 2010 |
Related U.S. Patent Documents
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Application
Number |
Filing Date |
Patent Number |
|
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61329724 |
Apr 30, 2010 |
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Current U.S.
Class: |
705/301 |
Current CPC
Class: |
G06F 17/00 20130101;
G06Q 10/103 20130101; G06Q 10/06313 20130101; G06Q 10/06
20130101 |
Class at
Publication: |
705/301 |
International
Class: |
G06Q 10/00 20060101
G06Q010/00 |
Claims
1. A data movement system comprising: a memory operable to store a
request to move data from one or more jurisdictions, the request
comprising (a) a data type, (b) a jurisdiction from which the data
is to be moved, and (c) a purpose for moving the data; and a
workflow manager configured to: identify a set of data movement
rules based at least in part upon the request, wherein the set of
data movement rules are associated with regulations of the
jurisdiction identified in the request; and apply at least one rule
of the set of data movement rules to identify an action item to be
completed in order to comply at least in part with the
regulations.
2. The system of claim 1, wherein applying the at least one rule
identifies a second data movement rule, the method further
comprising applying the second data movement rule to identify a
second action item.
3. The system of claim 1, the workflow manager further configured
to generate a response to the request, wherein the response to the
request is one of an approval to move the data, a disapproval to
move the data, and an approval conditional on completion of the
action item.
4. The system of claim 1, wherein the memory is further configured
to store information regarding the request and the action item and
the workflow manager is further configured to store information in
response to execution of the action item.
5. The system of claim 1, wherein the memory is further configured
to: store the identified set of data movement rules; store an
identification of the regulations associated with the identified
set of data movement rules; and store copies of documents created
during execution of the action item.
6. The system of claim 1, wherein: the request comprises a first
request, the action item comprises a first action item, and the
data comprises a first set of data, wherein the organization
performed a first action to execute the first action item; the
memory is further configured to store the first request and the
first action item; and the workflow manager is further configured
to: receive a second request to move a second set of data out of
the first jurisdiction; apply the at least one data movement rule
to the second request to identify a second action item, the second
action item requiring the organization to perform a second action
to execute the second action item; and determine that the first
action with respect to the first set of data is the same as the
second action with respect to the second set of data.
7. A requirements computer comprising: a memory operable to store a
request to move data from one or more jurisdictions, the request
comprising (a) a data type, (b) a jurisdiction from which the data
is to be moved, and (c) a purpose for moving the data; and a
processor configured to: identify a set of data movement rules
based at least in part upon the request, wherein the set of data
movement rules are associated with regulations of the jurisdiction
identified in the request; and apply at least one rule of the set
of data movement rules to identify an action item to be completed
in order to comply at least in part with the regulations.
8. The computer of claim 7, wherein applying the at least one rule
identifies a second data movement rule, the method further
comprising applying the second data movement rule to identify a
second action item.
9. The computer of claim 7, the processor further configured to
generate a response to the request, wherein the response to the
request is one of an approval to move the data, a disapproval to
move the data, and an approval conditional on completion of the
action item.
10. The computer of claim 7, wherein: the memory is further
configured to store information regarding the request and the
action item; and the processor is further configured to store
information in response to execution of the action item.
11. The computer of claim 7, wherein the memory is further
configured to: store the identified set of data movement rules;
store an identification of the regulations associated with the
identified set of data movement rules; and store copies of
documents created during execution of the action item.
12. The computer of claim 7, wherein: the request comprises a first
request, the action item comprises a first action item, and the
data comprises a first set of data, wherein the organization
performed a first action to execute the first action item; the
memory is further configured to store the first request and the
first action item; and the processor is further configured to:
receiving a second request to move a second set of data out of the
first jurisdiction; applying the at least one data movement rule to
the second request to identify a second action item, the second
action item requiring the organization to perform a second action
to execute the second action item; and determining that the first
action with respect to the first set of data is the same as the
second action with respect to the second set of data.
13. A method for determining requirements for moving data from one
or more jurisdictions, the method comprising: receiving a request
to move data, the request comprising (a) a data type, (b) a
jurisdiction from which the data is to be moved, and (c) a purpose
for moving the data; identifying a set of data movement rules based
at least in part upon the request, wherein the set of data movement
rules are associated with regulations of the jurisdiction
identified in the request; and applying at least one rule of the
set of data movement rules to identify an action item to be
completed in order to comply at least in part with the
regulations.
14. The method of claim 13, wherein applying the at least one rule
identifies a second data movement rule, the method further
comprising applying the second data movement rule to identify a
second action item.
15. The method of claim 13, further comprising generating a
response to the request, wherein the response to the request is one
of an approval to move the data, a disapproval to move the data,
and an approval conditional on completion of the action item.
16. The method of claim 13, further comprising: storing information
regarding the request and the action item; and updating the stored
information in response to execution of the action item.
17. The method of claim 13, further comprising: storing the
identified set of data movement rules; storing an identification of
the regulations associated with the identified set of data movement
rules; and storing copies of documents created during execution of
the action item.
18. The method of claim 13, wherein the request comprises a first
request, the action item comprises a first action item, and the
data comprises a first set of data, wherein the organization
performed a first action to execute the first action item, the
method further comprising: recording the first request and the
first action item; receiving a second request to move a second set
of data out of the first jurisdiction; applying the at least one
data movement rule to the second request to identify a second
action item, the second action item requiring the organization to
perform a second action to execute the second action item; and
determining that the first action with respect to the first set of
data is the same as the second action with respect to the second
set of data.
Description
RELATED APPLICATIONS
[0001] Pursuant to 35 U.S.C. .sctn.119(e), this application claims
priority to U.S. Provisional Patent Application Ser. No.
61/329,724, entitled INTERNATIONAL CROSS BORDER DATA MOVEMENT,
filed Apr. 30, 2010. U.S. Provisional Patent Application Ser. No.
61/329,724 is hereby incorporated by reference in its entirety.
TECHNICAL FIELD
[0002] The present disclosure relates to data movement generally
and more specifically to international cross border data
movement.
BACKGROUND
[0003] Some jurisdictions may restrict an organization's ability to
export certain types of data. These jurisdictions may promulgate
regulations that either prohibit exportation of certain types of
data or allow exportation subject to specified requirements. The
extent and complexity of these regulations may differ among
jurisdictions.
SUMMARY
[0004] In some embodiments, a data movement system comprises a
memory and a workflow manager. The memory is operable to store a
request to move data from one or more jurisdictions, the request
comprising (a) a data type, (b) a jurisdiction from which the data
is to be moved, and (c) a purpose for moving the data. The workflow
manager is configured to identify a set of data movement rules
based at least in part upon the request. The set of data movement
rules are associated with regulations of the jurisdiction
identified in the request. The workflow manager is configured to
apply at least one rule of the set of data movement rules to
identify an action item to be completed in order to comply at least
in part with the regulations.
[0005] Certain embodiments may provide one or more technical
advantages. A technical advantage of one embodiment may include the
capability to identify inherent risk associated with moving data
out of one or more jurisdictions. A technical advantage of one
embodiment may include the capability to identify action items
required for regulatory compliance. A technical advantage of one
embodiment may include the capability to reduce risk associated
with moving data out of a jurisdiction by identifying and
completing action items. A technical advantage of one embodiment
may include the capability to provide a quantitative expression of
inherent risk that may allow an organization to appropriately
allocate resources towards minimizing the organization's risk in
that jurisdiction. A technical advantage of one embodiment may
include the capability to improve organization knowledge of project
history and provide a trail for evaluators to assess the
organization's compliance with jurisdictional regulations.
[0006] Various embodiments of the invention may include none, some,
or all of the above technical advantages. One or more other
technical advantages may be readily apparent to one skilled in the
art from the figures, descriptions, and claims included herein.
BRIEF DESCRIPTION OF THE DRAWINGS
[0007] For a more complete understanding of the present disclosure
and its advantages, reference is now made to the following
description taken in conjunction with the accompanying drawings, in
which:
[0008] FIG. 1 shows a data movement system according to one
embodiment;
[0009] FIG. 1A shows an example project file of FIG. 1 according to
one embodiment;
[0010] FIG. 1B shows an example project snapshot of FIG. 1
according to one embodiment;
[0011] FIG. 2 shows a risk workflow according to one
embodiment;
[0012] FIG. 3 shows an action item workflow according to one
embodiment;
[0013] FIG. 4 shows an update workflow according to one
embodiment;
[0014] FIGS. 5A-5D show example request forms according to one
embodiment;
[0015] FIG. 6 shows a jurisdictional matrix according to one
embodiment;
[0016] FIGS. 7A and 7B shows example decision grids for applying
rules to a request according to several embodiments; and
[0017] FIG. 8 shows an example project summary according to one
embodiment.
DETAILED DESCRIPTION
[0018] It should be understood at the outset that, although example
implementations of embodiments of the invention are illustrated
below, the present invention may be implemented using any number of
techniques, whether currently known or not. The present invention
should in no way be limited to the example implementations,
drawings, and techniques illustrated below. Additionally, the
drawings are not necessarily drawn to scale.
[0019] An organization may conduct activities and store data in
multiple jurisdictions throughout the world. An organization may
include any social arrangement that pursues collective goals. One
example of an organization is a business. A business is an
organization designed to provide goods or services, or both, to
consumers, governmental entities, and other businesses. Examples of
a business may include, but are not limited to, agriculture and
mining businesses, financial institutions, manufacturers, real
estate companies, retailers and distributors, service businesses,
transportation companies, and utility companies. A business may
include both for-profit and not-for-profit businesses. An
organization may also include multiple businesses. For example, an
organization may control businesses in multiple jurisdictions
throughout the world. Examples of organizations are not limited to
businesses. For example, an organization can itself be a government
entity.
[0020] Some jurisdictions may restrict an organization's ability to
export certain types of data. These jurisdictions may promulgate
regulations that either prohibit exportation of certain types of
data or allow exportation subject to specified requirements. The
extent and complexity of these regulations may differ among
jurisdictions. For example, an organization may store
personally-identifiable information in ten different jurisdictions,
and each of them may have different restrictions on the
organization's ability to move the personally-identifiable
information. In another example, the ten different jurisdictions
may have different definitions as to what constitutes
personally-identifiable information (e.g., jurisdictions may
disagree as to whether an individual's job title is
personally-identifiable information).
[0021] Teachings of certain embodiments recognize the ability for
an organization with a past, current, or future data-movement
project to identify inherent risk associated with moving data out
of one or more jurisdictions. Returning to the last example,
teachings of certain embodiments recognize the ability to
quantitatively assess risk associated with exporting data out of
one or all of the ten jurisdictions. Teachings of certain
embodiments also recognize the ability to identify action items in
furtherance of regulatory compliance. Returning to the last
example, teachings of certain embodiments recognize the ability to
identify actions that the organization may take in a step toward
compliance with governing regulations (e.g., actions required for
compliance with a jurisdiction's data-movement regulations).
[0022] As used throughout, a data-movement project may include any
project that involves moving data out of at least one jurisdiction.
A data-movement project may be associated with one or more requests
to move data. A request to transfer data may include any
information regarding a past, present, or proposed movement of data
out of a jurisdiction. A request to transfer data may include both
one-time and recurring data movements. A jurisdiction includes any
territory or legal division that may have regulations restricting
exportation of data out of the jurisdiction. Examples of
jurisdictions may include, but are not limited to, countries,
states, dependencies (e.g., the Isle of Man), territories (e.g.,
the Cayman Islands), unions (e.g., the European Union), and other
national and international organizations. Data may refer to either
plural data or singular datum.
[0023] FIG. 1 shows a data movement system 1000 according to one
embodiment. FIG. 1 A shows an example project file 210 of FIG. 1
according to one embodiment. FIG. 1B shows an example project
snapshot 710 of FIG. 1 according to one embodiment.
[0024] In general, system 1000 receives requests to transfer data
out of one or more jurisdictions and then aids in determining
jurisdictional requirements for transferring the data. These
requests to transfer data are associated with data-movement
projects, which may include any effort by the organization to move
data.
[0025] In some embodiments, system 1000 may identify inherent risk
associated with moving data out of one or more jurisdictions. Two
example types of risk are jurisdiction risk and project risk.
Jurisdiction risk may approximately express the inherent risk
associated with moving data out of a jurisdiction. For example, a
jurisdiction with a highly complex regulatory structure may add to
inherent risk because of the possibility that the organization
fails to comply with the regulations of the jurisdiction. A
jurisdiction in which the organization's exposure is high may add
to inherent risk because of the ramifications to the organization
for failure to comply with the regulations of the jurisdiction.
Teachings of certain embodiments recognize that a quantitative
expression of inherent risk may allow an organization to
appropriately allocate resources towards minimizing the
organization's risk in that jurisdiction. If the inherent risk
associated with a jurisdiction is unmanageable, the organization
may even decide to abandon efforts to move data out of the
jurisdiction.
[0026] Project risk may approximately express the inherent risk
associated with moving data out of each of the jurisdictions
identified in the data-movement project. For example, a project
with a higher project risk may indicate that the project includes a
large number of jurisdictions with a highly complex regulatory
structure and/or a large number of jurisdictions where the
organization's exposure is high. Teachings of certain embodiments
recognize that a quantitative expression of inherent project risk
may allow an organization to appropriately allocate resources
towards minimizing the organization's risk associated with that
project. If the inherent project risk associated with the project
is unmanageable, the organization may even decide to abandon the
project.
[0027] In some embodiments, system 1000 may also identify action
items required for regulatory compliance. As one example, if a
jurisdiction requires outsourcing agreements with third parties to
include certain terms, then system 1000 may analyze a project to
determine whether the organization needs to include the certain
terms in its outsourcing agreements. Teachings of certain
embodiments recognize that identifying action items and completing
those action items may reduce risk associated with moving data out
of a jurisdiction. Thus, if a jurisdiction has a high inherent
jurisdiction risk or a project has a high inherent project risk,
identifying and completing action items may mitigate risk. In this
manner, identifying and completing action items may be analogous to
an internal control system for minimizing risk.
[0028] An internal control may include any process effected by an
organization that is designed to accomplish specific goals or
objectives, such as reducing risk. Teachings of certain embodiments
also recognize the ability to manage and track execution of action
items as an additional mechanism for monitoring and mitigating
risk. Action items may include specific actions that an
organization may take to comply with a rule or regulation, or to
otherwise mitigate risk associated with moving data out of a
jurisdiction. Action items may be managed and tracked over time.
For example, action items may include recurring actions to be
completed, and action items may change over time due to changes in
the project or changes in any governing regulations. Teachings of
certain embodiments also recognize that tracking execution of
action items may allow an evaluator to later confirm that the
project is complying with any governing regulations.
[0029] The example system 1000 of FIG. 1 features an interface 100,
a request repository 200, a workflow manager 300, a rules engine
400, a regulation repository 500, external systems 600, and a
document management repository 700, that may be implemented by one
or more computer systems 10.
[0030] Computer system 10 may include processors 12, input/output
devices 14, communications links 16, and memory 18. In other
embodiments, computer system 10 may include more, less, or other
components. Computer system 10 may be operable to perform one or
more operations of various embodiments. Although the embodiment
shown provides one example of computer system 10 that may be used
with other embodiments, such other embodiments may utilize
computers other than computer system 10. Additionally, embodiments
may also employ multiple computer systems 10 or other computers
networked together in one or more public and/or private computer
networks, such as one or more networks 30.
[0031] Processors 12 represent devices operable to execute logic
contained within a medium. Examples of processor 12 include one or
more microprocessors, one or more applications, and/or other logic.
Computer system 10 may include one or multiple processors 12.
[0032] Input/output devices 14 may include any device or interface
operable to enable communication between computer system 10 and
external components, including communication with a user or another
system. Example input/output devices 14 may include, but are not
limited to, a mouse, keyboard, display, and printer.
[0033] Network interfaces 16 are operable to facilitate
communication between computer system 10 and another element of a
network, such as other computer systems 10. Network interfaces 16
may connect to any number and combination of wireline and/or
wireless networks suitable for data transmission, including
transmission of communications. Network interfaces 16 may, for
example, communicate audio and/or video signals, messages, internet
protocol packets, frame relay frames, asynchronous transfer mode
cells, and/or other suitable data between network addresses.
Network interfaces 16 connect to a computer network or a variety of
other communicative platforms including, but not limited to, a
public switched telephone network (PSTN); a public or private data
network; one or more intranets; a local area network (LAN); a
metropolitan area network (MAN); a wide area network (WAN); a
wireline or wireless network; a local, regional, or global
communication network; an optical network; a satellite network; a
cellular network; an enterprise intranet; all or a portion of the
Internet; other suitable network interfaces; or any combination of
the preceding.
[0034] Memory 18 represents any suitable storage mechanism and may
store any data for use by computer system 10. Memory 18 may
comprise one or more tangible, computer-readable, and/or
computer-executable storage medium. Examples of memory 18 include
computer memory (for example, Random Access Memory (RAM) or Read
Only Memory (ROM)), mass storage media (for example, a hard disk),
removable storage media (for example, a Compact Disk (CD) or a
Digital Video Disk (DVD)), database and/or network storage (for
example, a server), and/or other computer-readable medium.
[0035] In some embodiments, memory 18 stores logic 20. Logic 20
facilitates operation of computer system 10. Logic 20 may include
hardware, software, and/or other logic. Logic 20 may be encoded in
one or more tangible, non-transitory media and may perform
operations when executed by a computer. Logic 20 may include a
computer program, software, computer executable instructions,
and/or instructions capable of being executed by computer system
10. Example logic 20 may include any of the well-known OS2, UNIX,
Mac-OS, Linux, and Windows Operating Systems or other operating
systems. In particular embodiments, the operations of the
embodiments may be performed by one or more computer readable media
storing, embodied with, and/or encoded with a computer program
and/or having a stored and/or an encoded computer program. Logic 20
may also be embedded within any other suitable medium without
departing from the scope of the invention.
[0036] Various communications between computers 10 or components of
computers 10 may occur across a network, such as network 30.
Network 30 may represent any number and combination of wireline
and/or wireless networks suitable for data transmission. Network 30
may, for example, communicate internet protocol packets, frame
relay frames, asynchronous transfer mode cells, and/or other
suitable data between network addresses. Network 30 may include a
public or private data network; one or more intranets; a local area
network (LAN); a metropolitan area network (MAN); a wide area
network (WAN); a wireline or wireless network; a local, regional,
or global communication network; an optical network; a satellite
network; a cellular network; an enterprise intranet; all or a
portion of the Internet; other suitable communication links; or any
combination of the preceding. Although system 1000 shows one
network 30, teachings of certain embodiments recognize that more or
fewer networks may be used and that not all elements may
communicate via a network. Teachings of certain embodiments also
recognize that communications over a network is one example of a
mechanism for communicating between parties, and any suitable
mechanism may be used.
[0037] Interface 100 may include any interface accessible by a
user, such as a user 50. User 50 may include any individual, group
of individuals, entity, machine, and/or mechanism that interacts
with interface 100. Examples of users 5 include, but are not
limited to, a manager, executive, review board, accountant,
engineer, technician, contractor, agent, and/or employee or
representative of an organization.
[0038] Interface 100 may include one or more forms for receiving
information from user 50 and/or providing information to user 50
relating to a data-movement project. A data-movement project may
include any project that involves moving data out of at least one
jurisdiction. As one example, a data-movement project may involve
moving data from a first jurisdiction to a second jurisdiction. As
another example, a data-movement project may involve sharing data
among multiple jurisdictions. Data-movement projects may include
both one-time and recurring movements of data.
[0039] Data-movement projects may move data for any suitable
purpose. As one example, a data-movement project may allow multiple
business units or lines of business of an organization to share
data housed in different jurisdictions. In this example, interface
100 may receive any information useful in determining whether and
how the data-movement project implicates data privacy regulations
promulgated by the different jurisdictions. Data privacy involves
the relationship between collection and dissemination of data,
technology, the public expectation of privacy, and the legal and
political issues surrounding them. Example data privacy regulations
may include, but are not limited to, regulations restricting the
collection and movement of personally identifiable information,
which may be received from sources such as healthcare records,
criminal justice investigations and proceedings, financial
institutions and transactions, biological traits and genetic
material, residence and geographic records, and ethnicity.
[0040] As another example, data may be moved out of a jurisdiction
in order to comply with a request from outside the organization,
such as a subpoena. In this example, interface 100 may receive any
information useful in determining whether and how the data-movement
project implicates data secrecy regulations promulgated by the
jurisdiction. Data secrecy involves ensuring that information is
accessible only to those authorized to have access. One example of
data secrecy is bank secrecy. Bank secrecy is a legal principle in
some jurisdictions under which financial institutions are not
allowed to provide to authorities personal and account information
about their customers unless certain conditions apply. For example,
bank secrecy regulations are prevalent in countries such as
Switzerland, Singapore, and Luxembourg.
[0041] As yet another example, a data-movement project may involve
outsourcing data out of a jurisdiction to an external organization,
such as a third-party data processor. In this example, interface
100 may receive any information useful in determining whether and
how the data-movement project implicates outsourcing regulations
promulgated by the jurisdiction. Outsourcing involves the practice
of hiring an external organization to perform some functions using
an organization's data. Outsourcing regulations may include
restrictions on what data may be outsourced and requirements
stipulating how outsourced data must be handled.
[0042] In one embodiment, interface 100 includes one or more
request forms 110a and 110b and one or more project summaries 120.
Example request forms 110a and 110b are shown in FIGS. 5A-5D, and
an example project summary 120 is shown in FIG. 8.
[0043] Request forms 110a and 110b provide a form for receiving
information regarding requests to transfer data out of one or more
jurisdictions. In one embodiment, information received through
request forms 110a and 110b is stored in a project file 210 in
request repository 200. In this example embodiment of FIG. 1A, the
information received through request forms 110a and 110b includes
project information 212, data movement information 214, and
jurisdiction information 216. Project information 212 may include
any information regarding a data-movement project, such as a
project name, a project identifier, a requestor name and contact
information, and a project type. Data movement information 214 may
include any information regarding the proposed data movement, such
as a type of data to be moved, a purpose for the data movement, and
information identifying whether the data movement will be one-time
or recurring. Examples of data type may include personal data
(e.g., customer, client, or associate specific identifiable data),
background data, transaction data (e.g., individual transaction
level data), government data (e.g., data about or controlled by a
sovereign entity), medical data (e.g., information containing
personal medical records), sensitive data (e.g., religious or
political affiliations), and anti-money laundering information
(e.g., trending to identify anti-money laundering transactions).
Teachings of certain embodiments recognize that categories of data
types may differ among jurisdictions. As one example, some
jurisdictions consider an individual's job title to be
personally-identifiable information, whereas other jurisdictions do
not. Examples of movement purposes include anti-money laundering,
sales, servicing, marketing, financial reporting, fulfillment, data
storage, testing, associate access, reporting, processing, and
document storage. Jurisdiction information 216 may include
information identifying one or more jurisdictions hosting the data
to be moved. Additional examples of request forms 110a and 110b,
project information 212, data movement 214, and jurisdiction
information 216 are described with respect to FIGS. 5A-5D.
[0044] Referring back to FIG. 1, project summary 120 provides a
form for reporting information regarding requests to transfer data
out of one or more jurisdictions. In one example, such reported
information includes the project information 212, the data movement
information 214, the jurisdiction information 216, and results
information 218. Results information 218 may include any
information regarding jurisdictional requirements for transferring
the data, such as information regarding regulations promulgated by
one or more jurisdictions, actions that facilitate with the
regulations promulgated by one or more jurisdictions (e.g., action
items), and actions completed towards compliance with the
regulations promulgated by one or more jurisdictions. Examples of
the regulations promulgated by one or more jurisdictions include
current regulations 510 and past regulations 520, which is
described in greater detail with regard to regulation repository
500. Additional examples of project summary 120, project
information 212, data movement 214, jurisdiction information 216,
and results information 218 are described with respect to FIG.
8.
[0045] Request repository 200 may include any repository for
storing information regarding requests to transfer data out of one
or more jurisdiction. In the illustrated embodiment, request
repository 200 stores one or more project files 210. Each project
file 210 includes information regarding one request to transfer
data out of one or more jurisdictions. Each project file 210 may
also be assigned a unique record locator for identifying the
project file 210. In the illustrated embodiment, project file 210
information includes project information 212, data movement
information 214, jurisdiction information 216, and results
information 218. Request repository 200 may receive project
information 212, data movement information 214, and jurisdiction
information 216 from interface 100 and may receive results
information 218 from workflow manager 300.
[0046] In some embodiments, project files 210 may be ordered in a
queue for processing. Project files 210 may be arranged in any
suitable order. In one embodiment, project files 210 are arranged
according to a time stamp (e.g., in the order received). In some
embodiments, a user 50 associated with the organization may
manually change the order of project files 210 within queue 215. In
another embodiment, project files 210 are automatically prioritized
according to factors such as project type (e.g., proposed or
active), data type, project deadlines, line of business, number of
jurisdictions, regulation complexity, project purpose, project
phase and/or project risk. One example of overall project risk is
described with regards to FIG. 2, which shows a risk workflow 2000
for calculating jurisdictional risk and project risk.
[0047] In one embodiment, request repository 200 may provide T-P-J
information 220 to workflow manager 300. In this example, T-P-J
information 220 includes three types of information about a
project: a data type, a project purpose, and a jurisdiction hosting
the data. T-P-J information 220 may be extracted from one or more
project files 210. Workflow manager 300 may use at least some of
the T-P-J information 220 as inputs to one or more workflows.
[0048] The illustrated embodiment features three example workflows:
risk workflow 2000, an action item workflow 3000 for identifying
action items that facilitate regulatory compliance, and an update
workflow 4000 for updating jurisdictional requirements for a
project. As one example, risk workflow 2000 may assess risk for a
project that involves moving first data from a first jurisdiction
and second data from a second jurisdiction. The first and second
jurisdictions may be identified by T-P-J information 220, and the
regulations of those jurisdictions may be collected from current
regulations 510 stored on regulatory repository 500. Risk workflow
2000 may also use rules 410 in lieu of or in addition to current
regulations 510. In this example, the project may be determined
based on the jurisdictional complexity of the project and the
jurisdictional exposure of the project. The jurisdictional
complexity of the project may be determined based on the
regulations of the first jurisdiction and the second jurisdiction.
The jurisdictional exposure of the project may also be determined
based on the organization's volume of business activity in the
first jurisdiction and the second jurisdiction.
[0049] As another example, action item workflow 3000 may determine
information for moving data from one or more jurisdictions. T-P-J
information 220 may identify request information including a data
type, a jurisdiction from which the data is to be moved, and a
purpose for moving the data. A set of data movement rules may be
identified and applied against the request to identify an action
item to be completed in order to comply at least in part with the
regulations.
[0050] As yet another example, update workflow 4000 may update
jurisdictional information for a project that involves moving data
from a first jurisdiction. T-P-J information 220 may identify
request information including a data type, a jurisdiction from
which the data is to be moved, and a purpose for moving the data.
An update to the request may be received changing some part of the
T-P-J information 220. A set of data movement rules may be
identified and applied against the updated request to identify an
updated action item to be completed in order to comply at least in
part with the regulations.
[0051] As yet another example, update workflow 4000 may update
jurisdictional information for moving data across jurisdictional
borders. T-P-J information 220 may identify request information
including a data type, a jurisdiction from which the data is to be
moved, and a purpose for moving the data. An update to the rules
associated with the jurisdiction may be received. The update may
represent a change to at least one regulation of the jurisdiction.
The updated data movement-rules may be applied against the request
to identify an updated action item to be completed in order to
comply at least in part with the regulations.
[0052] Risk workflow 2000, action item workflow 3000, and update
workflow 4000 are described in greater detail with regards to FIGS.
2, 3, and 4.
[0053] Rules engine 400 stores and applies rules 410. Rules 410 are
associated with regulations of a jurisdiction. In the illustrated
embodiment, rules 410 are developed from current regulations 510
stored in a regulation repository 500. Rules 410 may be developed
dynamically from regulations 510 or may be compiled ahead of time
based on regulations 510. In one embodiment, rules 410 may include
if/then/else scenarios developed from regulations 510 to identify
whether and/or how the regulations restrict movement of data out of
a jurisdiction. Teachings of certain embodiments recognize that
rules 410 may provide a structured mechanism for applying
regulations of a jurisdiction to a project and may reduce the need
to refer to the regulations directly. In one example, a regulation
may be relevant if the project involves moving "data type A" data.
In this example, a regulation may apply to data type A, and a
corresponding rule may be applied against those projects that have
data type=data type A. Thus, in this example, the relevant rule may
be identified without searching the regulations for regulations
that may implicate "data type A" data. Example rules 410 are
described in greater detail with regard to FIGS. 7A and 7B.
[0054] Rules engine 400 may also store a jurisdiction matrix 420.
Jurisdiction matrix 420 provides a snapshot view of multiple
jurisdictions, the jurisdiction risk scores associated with the
multiple jurisdictions, and a list of those factors and
corresponding weights that are used to determine the jurisdiction
risk scores. Thus, a jurisdiction matrix 420 may aggregate
information assessing inherent risk associated with an organization
that operates in a jurisdiction and may move data out of that
jurisdiction. Jurisdiction matrix 420 includes at least two
categories of information: jurisdiction information 422 and
organization information 424. Jurisdiction information 422 includes
information regarding regulatory complexity of the jurisdiction
and/or the jurisdiction's penalties for failing to comply with the
jurisdiction's regulations. Organization information 424 includes
information regarding an organization's exposure in the
jurisdiction. Organization information 424 may include, for
example, the organization's volume of business activity in the
jurisdiction and/or the organization's volume of data in the
jurisdiction. In some embodiments, jurisdiction matrix 420 may be
populated dynamically by reference to rules 410 or compiled ahead
of time based on rules 410 or regulations 510. For example, in one
embodiment, rules 410 are applied to jurisdiction information in a
manner similar to that described with regard to action item
workflow 3000 to determine whether rules exist restricting data
movement in a variety of regulatory arenas but without actually
analyzing individual project information to identify action items.
An example jurisdiction matrix 420 is described in greater detail
with regard to FIG. 6.
[0055] Regulatory repository 500 may include any repository for
storing regulations promulgated by one or more jurisdictions. In
the illustrated embodiment, regulatory repository 500 stores
current regulations 510 and past regulations 520. Current
regulations 510 are regulations promulgated by a jurisdiction and
that are either in effect or expected to be in effect in the
future. Past regulations 520 are regulations once promulgated by a
jurisdiction but that are no longer effective.
[0056] In some embodiments, external systems 600 may facilitate
transmitting or receiving information from an organization's
information systems. As one example, request forms 110a and 110b
may use external systems 600 to auto-populate information fields.
As another example, project snapshots 710 may include references to
an organization's document management system, and external systems
600 may be used to access documents stored on the document
management system. As yet another example, external systems 600 may
transmit information regarding a project to other organizational
software tools. As one example, external systems 600 may include an
email server configured to send information regarding a project to
organizational employees associated with the project.
[0057] Document management repository 700 may include any
repository for storing project snapshots 710 and completion
documents 720. Project snapshots 710 are data records that archive
information relating to a project, as described below. Each project
snapshot 710 may be associated with a project identifier, a
timestamp, and/or a snapshot identifier. Completion documents 720
are documents created during execute of an action item. Each
completion document 720 may be associated with a project snapshot
710. For example, a project snapshot 710 that lists completed
action items may identify the completion documents 720 that provide
evidence that the action items were indeed completed. Project
snapshots 710 and completion documents 720 together represent a
searchable collection of organizational knowledge regarding past
and current projects.
[0058] Teachings of certain embodiments recognize that archiving
information relating to a project may improve organizational
knowledge of project history and provide a trail for evaluators to
assess the organization's compliance with jurisdictional
regulations. For example, one project may be associated with
multiple project snapshots 710 that allow evaluators to review the
project at different points at time, such as after set periods of
time or after the project or regulations change. An evaluator may
review project snapshots 710 for any purpose, such as ascertaining
the validity and reliability of the information contained in the
project snapshots 710 or evaluating the organization's internal
controls.
[0059] Returning to FIG. 1B, information archived in project
snapshots 710 may include, but is not limited to, regulations
applied to the project (e.g., current regulations 510 or past
regulations 520), rules applied to the project (e.g., rules 410),
action items identified for the project (e.g., action items
identified through action item workflow 3000), actions performed in
response to the identified action items (e.g., references to
completion documents 720), and other project details (e.g., project
information 212, data-movement information 214, and jurisdiction
216). Project snapshots 710 may also include references identifying
archived information stored elsewhere. As used throughout,
references may include any identification of documents or
information. As one example, project snapshots 710 may include a
reference to current regulations 710 or past regulations 720
without necessarily including copies of those regulations; such
references may identify the regulations and/or provide information
on how to locate copies of the regulations. As another example,
project snapshots 710 may include references to completion
documents 720 instead of actual copies of those documents.
[0060] Returning back to FIG. 1, completion documents 720 represent
documents created during execution of an action item. As one
example, if an action item requires the organization to obtain
customer consents, then completion documents 720 may include copies
of the customer consents. As another example, if an action item
requires the organization to enter into outsourcing agreements with
third parties subject to certain terms, then completion documents
720 may include a copy of the outsourcing agreements. Teachings of
certain embodiments recognize that storing completion documents 720
may allow an evaluator to efficiently assess the organization's
compliance with regulations 510. Teachings of certain embodiments
also recognize that completion documents 720 may be reused in
future projects. For example, if an action item requires the
organization to obtain customer consents, a future project may
reuse some or all of the stored customer consent documents if
facing a similar action item. For example, if the customer consents
include language requested by a jurisdiction, then future customer
consents used in that jurisdiction may reuse the that language.
[0061] A project may be associated with multiple project snapshots
710. For example, a project snapshot 710 may be stored every time a
project is updated. Update events may include, but are not limited
to, times when action items are identified, when action items are
completed, when action items are changed, when regulations or rules
have changed, and when any other project information has changed.
As one example, if a project is directed to moving data out of a
first jurisdiction, a first project snapshot 710 may include a
reference to current regulation 510. If the referenced current
regulation 510 is replaced with a new regulation, the current
regulation 510 may be stored as a past regulation 520, and the new
regulation may be stored as a current regulation 510. The first
project snapshot 710 would then have a reference to the stored past
regulation 520, and a second project snapshot 710 would have a
reference to the new current regulation 510.
[0062] In operation, according to one embodiment, request forms
110a and 110b are prepared. A user 50 may complete request forms
110a and 110b by providing project information 212, data-movement
information 214, and jurisdiction information 216, which may then
be stored in a project file 210 on request repository 200. Project
files may be organized in a queue 215, and a user 50 may review and
prioritize the project files 210 before projects proceed to
workflow manager 300. Workflow manager 300 selects a project from
project file 210 and receives T-P-J information 220. Using this
T-P-J information 220, workflow manager 300 may initiate different
workflows. Risk workflow 2000 may populate jurisdiction matrix 420
to calculate jurisdictional risk and project risk based on the
organization and the jurisdictions identified by jurisdiction
information 216. Action item workflow 3000 may apply rules 410 to
the T-P-J information 220 to identify action items required for the
project to comply with each jurisdiction's regulations. Update
workflow 4000 may update rules 410 and/or action items for the
project in response to changes to the jurisdiction's regulations or
changes to the T-P-J information 220. Identified action items may
be reviewed and validated by a user 50 to ensure they accurately
represent the governing regulations. Document management repository
700 may store project snapshots 710, which archive changes and
developments to the projects.
[0063] FIG. 2 shows risk workflow 2000 according to one embodiment.
FIG. 3 shows action item workflow 3000 according to one embodiment.
FIG. 4 shows update workflow 4000 according to one embodiment.
Workflows 2000, 3000, and 4000 are described with reference to an
example data-movement project. The example data-movement project
includes an organization's request to move data out of an example
Jurisdiction A and an example Jurisdiction B. Workflows 2000, 3000,
and 4000 are also described with reference to FIGS. 6-8.
[0064] According to one embodiment, workflow 2000 may assess
jurisdictional risk and project risk associated with a project that
involves moving first data from a first jurisdiction and second
data from a second jurisdiction. Jurisdictional risk may
approximately express the inherent risk associated with moving data
out of a jurisdiction. Project risk may approximately express the
inherent risk associated with moving data out of each of the
jurisdictions identified in the project.
[0065] Risk workflow 2000 starts at step 2100. At step 2200,
jurisdiction information 216 is received. In this example,
jurisdiction information 216 identifies Jurisdiction A and
Jurisdiction B. At step 2300, the complexity of the regulations of
Jurisdiction A and Jurisdiction B is determined. In this example,
jurisdiction matrix 6000 of FIGS. 6A-6B may be used to determine
regulatory complexity. FIGS. 6A-6B will be described in the
following paragraphs.
[0066] FIGS. 6A-6B shows jurisdictional matrix 6000 according to
one embodiment. Jurisdictional matrix 6000 represents one example
of the jurisdictional matrix 420 of FIG. 1. In this example
embodiment, jurisdictional matrix 6000 includes rows of
jurisdictions 6100 and columns of matrix factors 6200. Example
jurisdictions 6100 include Jurisdiction A and Jurisdiction B.
[0067] Example matrix factors 6200 include regulatory information
6210, regulatory oversight factors 6220, data volume factors 6230,
and business criticality factors 6240. Regulatory information 6210
identify whether each jurisdiction 6100 restricts movement of data
in the areas of data privacy, secrecy, and outsourcing. Example
regulatory information 6210 include requirements related to the
regulatory areas of data privacy, data secrecy, and
outsourcing.
[0068] Regulatory oversight factors 6220 identify the regulatory
activity of each jurisdiction 6100 and the penalties that may be
incurred for failing to obey regulations of each jurisdiction 6100.
Example regulatory oversight factors 6220 include the civil and
criminal penalties for failure to comply with data movement
regulations and the activity level of the jurisdiction's regulatory
body. For example, a jurisdiction that requires many regulatory
filings and has an enforcement division may increase the chances
that an organization would be prosecuted for failure to comply as
compared to a jurisdiction that has a passive regulatory
structure.
[0069] Data volume factors 6230 assess the volume of an
organization's data within each jurisdiction. Example data volume
factors 6230 may include the number of data centers located in a
jurisdiction, whether there are any large-volume data operations in
the jurisdiction, and whether the organization considers the
jurisdiction to be a "critical outsourcing location." Business
criticality factors 6240 assess the criticality of the jurisdiction
to the organization's overall business. Example business
criticality factors 6240 may include the number of lines of
business the organization has in the jurisdiction, the
organization's revenue attributable to activities in the
jurisdiction, and whether the organization is considering new
market entry or expansion into the jurisdiction.
[0070] Jurisdictional matrix 6000 also includes weights 6300.
Weights 6300 define a relative value for each matrix factor 6200.
As one example, acquiring customer consent may be more complex than
providing customer notification; accordingly, the weight assigned
to the customer consent regulatory information 6210 is higher than
the weight assigned to the customer notification regulatory
information 6210. Applying weights 6300 to regulatory information
6210, regulatory oversight factors 6220, data volume factors 6230,
and business criticality factors 6240 yield corresponding
regulatory information scores 6410, regulatory oversight scores
6420, data volume scores 6430, and business criticality scores
6440, as shown in FIG. 6. Additionally, in this example, regulatory
information scores 6410 may be added to yield an overall regulatory
information score 6510; regulatory oversight scores 6420 may be
added to yield overall regulatory oversight score 6520; data volume
scores 6430 may be added to yield overall data volume score 6530;
and business criticality scores 6440 may be added to yield overall
business criticality score 6540.
[0071] In addition, for each jurisdiction, the regulatory
information scores 6410, regulatory oversight scores 6420, data
volume scores 6430, and business criticality scores 6440 may be
added to yield a jurisdiction risk score 6600. Teachings of certain
embodiments recognize that a jurisdiction risk score 6600 may
approximately express the inherent risk associated with moving data
out of a jurisdiction. In this example, a higher jurisdiction risk
score 6600 indicates that a jurisdiction has a highly complex
regulatory structure and/or the organization's exposure in the
jurisdiction is high. Teachings of certain embodiments recognize
that a quantitative expression of inherent risk may allow an
organization to appropriately allocate resources towards minimizing
the organization's risk in that jurisdiction.
[0072] In one embodiment, the jurisdiction risk scores 6600
identified in jurisdictional matrix 6000 may be compared to a break
value, set at 255 in the exemplary jurisdictional matrix 6000. The
break value represents a threshold that may be used to classify the
jurisdictional risk scores 6600 as either high or low. Although the
break value in this example is set at 255, teachings of certain
embodiments recognize that the break value may be set to any
suitable value. As one example, the break value may be set at the
median or mean of all jurisdiction risk scores 6600. In some
example embodiments, multiple threshold values may be used to
categorize jurisdictional risk scores 6600 into different
tiers.
[0073] Returning to risk workflow 2000 of FIG. 2, step 2300 may
include steps 2310 and 2320. At step 2310, weights 6300 may be
applied to regulatory information 6210 to yield regulatory
information scores 6310 and overall regulatory requirement score
6410. In one example, the regulatory information 6210 include "yes"
or "no" answers, with a "yes" answer having a value of 1 and a "no"
answer having a value of 0. In this example, applying weights 6300
to the regulatory information 6210 converts the yes/no answers into
numerical values that express both the existence of a factor in a
jurisdiction and the importance of that factor as compared to the
other factors.
[0074] At step 2320, weights 6300 may be applied to regulatory
oversight factors 6220 to yield regulatory oversight scores 6320
and overall regulatory oversight score 6420. In one example, the
regulatory oversight factors 6220 include "yes" or "no" answers,
with a "yes" answer having a value of 1 and a "no" answer having a
value of 0. In this example, applying weights 6300 to the
regulatory oversight factors 6220 converts the yes/no answers into
numerical values that express both the existence of a factor in a
jurisdiction and the importance of that factor as compared to the
other factors.
[0075] At step 2400, the organization's exposure in Jurisdiction A
and Jurisdiction B may be determined. In this example, step 2400
may include steps 2410 and 2420. At step 2410, weights 6300 may be
applied to data volume factors 6230 to yield data volume scores
6330 and overall data volume score 6430. In one example, the to
data volume factors 6230 include "yes" or "no" answers, with a
"yes" answer having a value of 1 and a "no" answer having a value
of 0. In this example, applying weights 6300 to the to data volume
factors 6230 converts the yes/no answers into numerical values that
express both the existence of a factor in a jurisdiction and the
importance of that factor as compared to the other factors.
[0076] At step 2420, weights 6300 may be applied to business
criticality factors 6240 to yield business criticality scores 6340
and overall business criticality score 6440. In one example, the
business criticality factors 6240 include "yes" or "no" answers,
with a "yes" answer having a value of 1 and a "no" answer having a
value of 0. In this example, applying weights 6300 to the business
criticality factors 6240 converts the yes/no answers into numerical
values that express both the existence of a factor in a
jurisdiction and the importance of that factor as compared to the
other factors.
[0077] At step 2500, jurisdiction risk scores 6600 for Jurisdiction
A and Jurisdiction B may be determined. As explained above, a
jurisdiction risk score 6600 may approximately express the inherent
risk associated with moving data out of a jurisdiction. In this
example, jurisdiction risk score 6600 may be determined by adding
regulatory information scores 6410, regulatory oversight scores
6420, data volume scores 6430, and business criticality scores
6440, as shown in FIG. 6.
[0078] At step 2600, a project risk score 6700 may be determined.
Teachings of certain embodiments recognize that a project risk
score 6700 may approximately express the inherent risk associated
with moving data out of each of the jurisdictions identified in the
project. In this example, a higher project risk score 6700
indicates that the project includes a large number of jurisdictions
with a highly complex regulatory structure and/or a large number of
jurisdictions where the organization's exposure is high. Teachings
of certain embodiments recognize that a quantitative expression of
inherent risk may allow an organization to appropriately allocate
resources towards minimizing the organization's risk associated
with that project.
[0079] An example project risk score 6700 is shown by reference to
example project summary 120, as shown in FIG. 8. Project summary
120 identifies different jurisdictional and organizational risk
factors 6710 and counts the number of jurisdictions that have a
high, medium, or low value for each risk factor. In the embodiment
shown in FIG. 8, the example jurisdictional and organizational risk
factors 6710 include overall regulatory information score 6410,
overall data volume score 6430, overall business criticality score
6440, and weighed revenue factor score (selected from among the
business criticality scores 6440). In this example, the project
risk score 6700 is calculated as a function of the number of
jurisdictions that have a high, medium, or low value for each of
the identified jurisdictional and organizational risk factors 6710.
In one example embodiment, the project risk score 6700 is
calculated by applying weights to the totals of high, medium, and
low values and then added to yield a composite score. The example
project summary 120 of FIG. 8 will be described in greater detail
below.
[0080] FIG. 3 shows action item workflow 3000 according to one
embodiment.
[0081] Action item workflow 3000 may determine requirements for
moving data from one or more jurisdictions. In some embodiments,
workflow 3000 may identify action items in an effort to reduce risk
associated with moving data out of a jurisdiction. For example, if
a jurisdiction has a high inherent risk or a project has a high
inherent risk, identifying and completing action items may mitigate
inherent risk. In addition, workflow 3000 may provide a structured
mechanism for applying regulations of a jurisdiction to a project
and may reduce the need to refer to the regulations directly
through the application of rules 410.
[0082] Action item workflow 3000 starts at step 3100. At step 3200,
T-P-J information 220 is received. In this example, T-P-J
information 220 identifies a request to move personally
identifiable information (PII) out of Jurisdiction A. At step 3300,
a set of data rules 410 are identified based on the T-P-J
information 220. In this example, data rules 410 corresponding to
Jurisdiction A regulations concerning data privacy are identified
because the T-P-J information 220 identified Jurisdiction A and an
intent to move PII data. The identified data rules 410 may include
if/then/else scenarios developed from regulations of Jurisdiction A
related to data privacy that identify whether and/or how the
Jurisdiction A restricts movement of PII data out of a
jurisdiction. In different embodiments, the identified data rules
410 may include all regulations of Jurisdiction A related to data
privacy or a subset. As one example, the identified data rules 410
may include initial rules that, when applied, will lead to other
rules and action items. At step 3400, the identified data rules 410
are applied against the request. FIG. 7A shows an example decision
grid 415a for applying rules 410 to the request at step 3400
according to one embodiment. FIG. 7A will be described in the
following paragraph.
[0083] FIG. 7A shows an example decision grid 415a. Decision grid
415a illustrates one example method for applying rules 410.
Applying rule 1.0 to the T-P-J information 220 reveals that data
privacy "regulatory restrictions [are] present" and that "specific
restrictions" should be determined at rule 2.0. Applying rule 2.0
to the T-P-J information 220 reveals that "sensitive data elements"
are involved, as that term is defined under the regulations of
Jurisdiction A, and that the "sensitive data elements" should be
determined at rule 2.1. Applying the rule 2.1 to the T-P-J
information 220 reveals that "sensitive data elements are present
in the project request" and that "regulatory compliance
requirements" should be determined at rule 2.2. Applying the rule
2.2 reveals that "compliance requirements exist" and should be
defined at rule 2.2a. Applying the rule 2.2a reveals that "customer
notice [is] required" and that the organization should complete an
action item: "deliver customer notice."
[0084] Returning to action item workflow 3000 of FIG. 3, step 3400
answered whether the request is allowed under the regulations of
Jurisdiction A and what action items may facilitate compliance. In
the example of FIG. 7A, decision grid 415a revealed that the
requested data movement is allowed if customer notice is
delivered.
[0085] At step 3500, the answer produced at step 3400 is analyzed
to determine whether the rules 410 allow the requested data
movement under any circumstances. In this example, the requested
data movement is allowed if customer notice is delivered, so the
action item workflow 3000 proceeds to step 3600. However, if the
requested data movement had been prohibited in all circumstances, a
response denying the request may be generated at step 3510. The
response may be provided in any suitable form. In one example, a
project summary 120 may indicate that the requested data movement
is denied under any circumstances. In another example, external
systems 600 may generate an email alerting the organization that
the requested data movement is denied under any circumstances.
[0086] At step 3600, the answer produced at step 3400 is analyzed
to determine whether the rules 410 require action items to be
completed for compliance. In this example, the rules 410 require
the organization to deliver customer notice to those customers
required by the jurisdiction, so the action item workflow 3000
proceeds to step 3700. However, if the requested data movement had
been allowed in all circumstances, a response allowing the request
may be generated at step 3610.
[0087] At step 3700, the request and the action item are stored. In
one example, the action item is stored as part of results 218. In
another example, a project snapshot 710 is generated and records
the request and the action item. In some embodiments, the results
218 and/or project snapshot 710 may be updated to record that the
action item is completed. In this example, when the organization
delivers the required customer notification, results 218 may be
updated, project snapshot 710 may be updated, and copies of the
customer notices may be stored at the document management
repository as completion documents 720. A response reporting that
the requested data movement is allowed subject to an action item
may also be generated.
[0088] Teachings of certain embodiments recognize the capability to
include verification steps to ensure that the identified action
items accurately reflect the requirements of the governing
regulations. As one example, a review board may determine whether a
project will comply with each jurisdiction's regulations once the
action items are completed. As an organization validates action
items for projects over time, the organization may develop
confidence that the action items and associated rules accurately
reflect the governing regulations. Accordingly, teachings of
certain embodiments recognize the capability to validate action
items without submitting the action items for human review. For
example, when an action item is generated, the request repository
200 may be searched for project records 210 that include similar
action items. In one example, two action items may be considered
similar if they require the organization to perform the same steps
but to different data sets. If the search of request repository 200
reveals a similar action item that has been verified, in some
embodiments the new generated action item may be deemed verified
without human review. In an alternative embodiment, a new generated
action item may be deemed verified without human review if
searching the request repository 200 revealed a sufficient number
of similar action items that have been verified (e.g., ten or
more).
[0089] FIG. 4 shows update workflow 4000 according to one
embodiment. Update workflow 4000 may update jurisdictional
information for a project that involves moving data from a first
jurisdiction. For example, action items may change over time due to
changes in project information and/or changes in jurisdictional
regulations. Teachings of certain embodiments recognize that update
workflow 4000 may provide a structured mechanism for updating,
adding, and removing action items through the application of rules
410 against existing projects and action items. Thus, workflow 4000
may update those actions that the organization should complete to
maintain compliance with governing regulations.
[0090] Update workflow 4000 starts at step 4100. At step 4200,
T-P-J information 220 and an associated action item are stored. In
this example, T-P-J information 220 identifies a request to move
personally identifiable information (PII) out of Jurisdiction A,
and the associated action item requires the organization to provide
customer notice, as identified by the decision grid 415a of FIG.
7A.
[0091] At step 4300, an update to the T-P-J information 220 or the
rules 410 corresponding to Jurisdiction A is received. In this
example, the update is to rules 410: as part of the update,
Jurisdiction A now requires "customer consent" instead of "customer
notice." Accordingly, in this example, step 4450 requires that
update workflow 4000 proceed to step 4550. At step 4550, projects
that involve moving data out of Jurisdiction A are identified. In
this example, request repository 200 and/or document management
repository 700 are searched to identify the T-P-J information 220
and action item stored at step 4200. At step 4650, the update to
rules 410 are applied against the request. FIG. 7B shows an example
method for applying updated rules 410 to the request at step 4650
according to one embodiment. FIG. 7B will be described in the
following paragraph.
[0092] FIG. 7B shows an example decision grid 415b. Decision grid
415b proceeds to rule 2.2a similar to the decision grid 415a of
FIG. 7A. However, rule 2.2a of decision grid 415b is different from
rule 2.2a of decision grid 415a. Applying rule 2.2a reveals that
"customer consent" is required and that the organization should
"validate [that] customer consent is on file." If the "customer
consent" is not on file, decision grid 415b proceeds to rule 2.2b,
which identifies a new action item: "obtain customer consent." If
"customer consent" is on file, decision grid 415b proceeds to rule
2.3. Applying rule 2.3 once "customer consent" is obtained reveals
another action item: "obtain regulatory notification." Once
"regulatory notification" is obtained, decision grid 415b proceeds
to rule 2.4, which identifies another action item: "file regulatory
notification with XYZ regulator." Once the "regulatory
notification" is filed, decision grid 415b ends.
[0093] Returning to update workflow 4000 of FIG. 4, step 4650
answered whether the request is allowed under the updated
regulations of Jurisdiction A and what action items may be required
for compliance. At step 4750, the request and the updated action
items are stored. In one example, the updated action items are
stored as part of results 218. In another example, a project
snapshot 710 is generated and records the request and the action
items; this second snapshot 710 may be in addition to any project
snapshot 710 generated at step 3700 of the action item workflow of
FIG. 3.
[0094] Returning to step 4300 of update workflow 4000, if the
received update is an update to T-P-J information 220, then step
4400 would indicate that the update workflow 4000 proceed to step
4500. At step 4500, a set of data rules 410 are identified in a
manner similar to that described above with regard to step 3300 of
action item workflow 3000. At step 4600, the identified data rules
410 are applied against the updated request in a manner similar to
that described above with regard to step 3400 of action item
workflow 3000. At step 4700, the request and the action item are
stored in a manner similar to that described above with regard to
step 3700 of action item workflow 3000 and/or step 4750 of update
workflow 4000.
[0095] FIGS. 5A-5D show example request forms 110a and 110b
according to one embodiment. In the illustrated example, request
forms 110a and 110b include intake form 110a and assessment form
110b. Together, request forms 110a and 110b include several fields
for receiving project information, including project information
212, data movement information 214, and jurisdiction information
216. As one example, data movement information 214 may be derived
in part from the identified "purpose of using the above mentioned
data" in Question 6 of intake form 110a. In this example, the
purpose information may be included in T-P-J information 220.
[0096] FIG. 8 shows an example project summary 120 according to one
embodiment. As explained above, project summary 120 may display
project risk score 6700 and organizational risk factors 6710.
Project summary 120 may also show action item summary information.
For example, FIG. 8 shows action item summary information derived
from decision grid 415b. In this example, Jurisdiction A included a
data privacy regulation requirement that "regulatory notification
be filed with XYZ regulation." According to this example project
summary 120, the task of filing the regulatory notification has
been assigned within the organization to "Mr. Person," and Mr.
Person has one month to complete the task. The example project
summary 120 also includes high, medium, and low values derived from
the overall regulatory information score 6510, the overall
regulatory oversight score 6520, the overall data volume score
6530, and the overall business criticality score 6540 of FIG. 6. As
explained above, these high, medium, and low values may be derived
by comparing each score to one or more threshold values.
[0097] In some embodiments, updates to a project may yield new
and/or updated project summaries 120. Update events may include,
but are not limited to, times when action items are identified,
when action items are completed, when action items are changed,
when regulations or rules have changed, and when any other project
information has changed. As one example, if updated action items
are identified through update workflow 4000, the updated action
items may be shown on updated project summaries 120. As another
example, if Jurisdiction A changes their regulatory requirements,
the changes may result in different values for: the project risk
score 6700; the organizational risk factors 6710; the identified
action items; and/or the high, medium, and low values derived from
the overall regulatory information score 6510, the overall
regulatory oversight score 6520, the overall data volume score
6530, and the overall business criticality score 6540 of FIG.
6.
[0098] Modifications, additions, or omissions may be made to the
systems and apparatuses described herein without departing from the
scope of the invention. The components of the systems and
apparatuses may be integrated or separated. Moreover, the
operations of the systems and apparatuses may be performed by more,
fewer, or other components. The methods may include more, fewer, or
other steps. Additionally, steps may be performed in any suitable
order. Additionally, operations of the systems and apparatuses may
be performed using any suitable logic. As used in this document,
"each" refers to each member of a set or each member of a subset of
a set.
[0099] Although several embodiments have been illustrated and
described in detail, it will be recognized that substitutions and
alterations are possible without departing from the spirit and
scope of the present invention, as defined by the appended
claims.
[0100] To aid the Patent Office, and any readers of any patent
issued on this application in interpreting the claims appended
hereto, applicants wish to note that they do not intend any of the
appended claims to invoke paragraph 6 of 35 U.S.C. .sctn.112 as it
exists on the date of filing hereof unless the words "means for" or
"step for" are explicitly used in the particular claim.
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