Privacy Risk Analysis
Risks in how personal data is processed, used and moved
For organisations that handle personal data directly or indirectly, we analyse from several angles the risks that can arise as data is processed, used and moved, and provide guidance on how to improve.
We follow personal data from where it is collected and stored, along the routes it travels, into analytics and development environments and on to outsourced and connected services. Along the way we look at access without permission, things left open, data left behind, and small pieces that combine into something sensitive. It is not a check on whether personal data has already leaked.
Where in the way we process, use and move personal data could risks arise?
We follow the data from collection to deletion, analyse where the risks lie, and set out what to fix first as guidance for improvement.
Reviewed
When it fits
- You hold a lot of sensitive data
You handle sensitive data such as member, payment or health records, or large customer datasets, and want a clear picture of how far that data has actually spread.
- You put data to use in analytics, development or new business
You copy customer data into analytics and development environments or build a business on it, and want to know that pseudonymisation and access control hold at every step.
- You outsource processing, or process data for others
You hand personal data processing to others, or process data on another company's behalf, and want to check what data is exchanged and how it is looked after.
- You are under privacy rules and want to know the real state
Your organisation is subject to privacy rules, and you want to see where the risks are in your actual systems and data flows, not only in policies and documents.
What we look at
The places data passes through from collection to deletion, in four groups. We pick and combine them to fit your data and how it flows.
- STORECollection and storage
- What personal and sensitive data is collected
- How it is stored in apps, servers and the cloud
- Logs, error messages and debug output
- Caches, temporary files and backups
- FLOWTransfer and movement
- How it travels over APIs and the network
- Data copied into analytics and development environments
- Data passed to outsourced and connected services
- ACCESSAccess and exposure
- Whether users without permission can reach it
- Share links and storage left open
- Access still held by leavers and dormant accounts
- RETAINRetention, deletion and combined data
- Data left behind after retention periods or deletion
- Small pieces that combine into sensitive information
‘Personal data does not reach the analytics environment without pseudonymisation’
‘A leaver's account cannot reach customer data’
‘Data past its retention period is left neither in production nor in backups’
How it runs
Map the data and its flows
Together we decide which personal data and systems to look at and how the data flows between them, and set the conditions that must hold.
Agree access and safety
We agree the accounts, material and scope we need, what is permitted and when to stop, before we start.
Analyse each flow
At each step, collection, storage, transfer, use and deletion, we check whether the conditions hold and, where needed, confirm whether the data can really be reached.
Guidance for improvement
For each point of risk: the evidence, the impact, what to fix first and how.
How any personal data seen during the work is handled, and how much of it appears in the results, is agreed with you before we start.
What you receive
Data flows and points of risk
Where personal data actually sits and travels, and which of those places carry risk.
Evidence and impact
For each risk, the evidence we found, and whose data, and what kind, it would affect if it happened.
Priorities and how to improve
What to fix first, and how to change the rules for collection, retention, access and deletion.
What was not covered
Which data and systems this round did not examine, so the next round can start from there.
It does not replace a statutory privacy impact assessment, ISMS-P or other certification audits and consulting, or legal advice. Whether data has already leaked is checked in Leaked Information Analysis.