Task 2 — Data Categories, Data Subjects & Data Flows

Which data, about whom, from where, to whom — and in which system?

For each processing activity, describe the data and how it flows. This is where data minimisation happens: every data category has to be needed for the purpose.

What to document

  • Data categories: e.g. contact data, bank details, health data — and whether sensitive data is involved
  • Data subjects: employees, applicants, customers, suppliers' contacts, website visitors
  • Sources: collected from the person, or obtained from third parties
  • Recipients: internal departments and external parties, e.g. tax office, payroll provider
  • Systems: the applications and storage locations where the data lives
  • Minimise: question every category — is it really needed? Remove what is not.

Example: processing activity "Payroll"

Data categoriesName, address, tax and social security number, bank details, salary, sick days
Sensitive dataSick days (health) — only the number of days, no diagnosis
Data subjectsEmployees, former employees
SourcesEmployee, time recording, HR
RecipientsPayroll provider, bank, tax and social security authorities
SystemsPayroll software, HR file share

Minimisation found: the payroll export also contained private phone numbers and emergency contacts — not needed for payroll, so they are removed from the export.