Smart assessments in Privacy Management
Summarize
Summary of Smart assessments in Privacy Management
The Smart Assessment Engine (SAE) application in Privacy Management streamlines privacy screening and privacy impact assessments, enabling privacy teams to efficiently collect and evaluate information about personal data processing activities. There are two main types of assessments:
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- Privacy Screening Assessment: A high-level preliminary evaluation to determine if a processing activity involves personal data and whether detailed privacy reviews, such as privacy impact assessments, are necessary.
- Privacy Impact Assessment (PIA): A comprehensive analysis of privacy risks related to business applications, systems, or processes that handle personal data, including risk reassessment over time.
The Smart Assessment Engine supports these assessments by providing configurable templates, workflows, guided questions, and actionable insights for reviewing results.
Key Features
- Configurable Templates: Includes recommended [V4] versions for both screening and impact assessments, offering sections for general details, questions, criticality scoring, and automations.
- Automation Capabilities: Enables automatic creation of processing activities and application of risk statements and control objectives based on assessment responses, enhancing consistency and reducing manual effort.
- Data Flow and Lawful Basis Capture: Facilitates documentation of data sources, destinations, and the legal grounds for data processing.
- Guidance and Logical Grouping: Provides inline assistance for questions and allows grouping questions into multiple sections for clarity.
- Migration and Version Control: Supports migrating assessments from older systems and managing multiple template versions to maintain consistency in ongoing and new assessments.
- Review Process: Privacy managers and analysts can review assessments, view detailed data hierarchies, risk outcomes, and either approve or request revisions.
Practical Implications for ServiceNow Customers
By leveraging the Smart Assessment Engine in Privacy Management, customers can:
- Efficiently evaluate and document privacy risks associated with their data processing activities.
- Automate risk identification and mitigation, reducing human error and saving time during assessments.
- Maintain up-to-date and version-controlled assessment templates aligned with privacy policies.
- Ensure privacy teams have clear, actionable insights and structured workflows to manage assessments from screening through impact evaluation.
- Comply with privacy requirements by capturing necessary details such as data flow, lawful basis, and criticality factors directly within assessments.
To activate these features, customers must enable the snprivacy.enablesmartassessment system property. Detailed configuration guidance is available for tailoring templates and automations to organizational needs.
The new and improved assessment experience in Privacy Management uses the Smart Assessment Engine (SAE) application. The assessment engine enables you to perform privacy screening and privacy impact assessments to collect the necessary information for the privacy teams.
- Privacy screening assessment: A privacy screening assessment is a preliminary evaluation used to determine whether a processing activity involves personal data and whether it may pose privacy risks. It’s a high-level review conducted to identify whether a more detailed privacy review, such as a privacy impact assessment (PIA), is necessary. For example, when a new business application or process is created, the privacy teams must understand if the application or the business process processes personal data or not. To determine this, the screening assessments are sent to the business application or business process owners. After the assessment is approved by the privacy manager, a processing activity is created.
- Privacy impact assessment: After a screening assessment is performed, based on the responses, a privacy impact assessment may be generated. A Privacy impact assessment is a comprehensive evaluation of how a business application, system, or process affects personal data privacy. It assesses the privacy risks associated with processing activities and identifies measures to mitigate these risks. Each time a privacy impact assessment is performed, the risks are revisited to determine if the risk score changed. This helps the privacy teams remain vigilant and address the risks as required.
Benefits of using the new assessment experience
- Capture all the required information during the assessment eliminating the need for manually adding details to the processing activity.
- Capture the hierarchy or flow of data and specify where the data is coming from and where is the data going.
- Collect the lawful basis of collecting and processing data.
- Create multiple sections for logical grouping of questions
- Migrate assessments from older systems.
- Provide inline guidance for questions.
- Reassign the assessment to the correct responder.
- Create highly configurable templates.
Types of assessment templates
To perform the screening and the impact assessments, you require assessment templates. While the assessment templates are based on the Smart Assessment Engine, there are some additional configurations provided for the users of Privacy Management.
- Privacy screening assessment
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Starting with the Zurich release, a new template for Privacy screening assessment (Privacy Screening Assessment [V4]) is available.
For a screening assessment template, there are three sections:- General: In this section, you specify the assessment template category as Privacy category and also specify the assessment targets. For a screening assessment, the assessment targets are entities and privacy tasks.
- Questions: This section contains questions for the assessment responders. This section also contains data elements which are single units of information that represent a specific attribute or characteristic about a data subject or entity. Examples of data elements are name, email address, date of birth, and so on. In this section, you’ll also find a section titled Criticality factors and these questions are used to calculate the criticality score.
- Automations: In this section, you can define the rules that allow the automatic creation of processing activities based on the responses to questions. This section uses Workflow Studio. These automations are mapped to their relevant questions. Automation streamlines various processes, including the application of risk statements and control objectives based on user responses. When users select specific responses during an assessment, the system automatically applies the appropriate risks and controls to the relevant records. For example, consider an organizational policy stating that personal data can only be transferred outside the EU with explicit consent. During an assessment, if a user indicates that data is being transferred outside the EU, the system will automatically apply the Data Transfer risk to the processing activity: Assign Explicit Consent as a control to mitigate the identified risk. This automation ensures consistency, saves time, and reduces the likelihood of human error in managing risks and controls.
Figure 1. Privacy screening assessment - Privacy impact assessment
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Starting with the Australia release, a new template for Privacy impact assessment (Privacy Impact Assessment [V4]) is available.
For a privacy impact assessment template, like the screening assessment template, you have the Overview and Details sections, and while by default, the Automations section is present, it does not contain any predefined automations. You can add automations if you require them. For an impact assessment template, apart from the questionnaire, you can add the personal data elements. For detailed information on how to configure an impact assessment template, see Configure smart assessment templates for impact assessments.Figure 2. Privacy impact assessment screen
Review of an assessment
- Information objects: The information objects tab displays the information objects identified as part of the screening assessment.
- Hierarchy: The hierarchy of where data comes from and where it goes.
- Outcomes: The outcomes tab displays the risk statement and the control objectives associated with the assessment.