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Learn how to manage Data Privacy in legacy systems with these 7 simple steps. Ensure your legacy data remains secure and compliant with the DPDPA.

A sales team has kept a lot of customer data in a spreadsheet for 10 years. After a security concern, they now want to move this data into their sales systems.

The spreadsheet is a mess – it’s not accurate, consistent, up-to-date, or well-organised. But it’s still important data that they need to move, update processes, access, and use.

This is what we refer to as Legacy Data, which can be tricky to handle and process, especially with the Digital Personal Data Protection Act (DPDPA), 2023 now in effect. This blog walks you through 7 steps to ensure data privacy in Legacy systems.

What is Legacy Data?

Legacy data is information stored in old or outdated systems, formats, or technologies (called Legacy Systems) that can be hard to get to. This data was made years ago and might not be used by a company anymore. But it’s often important for legal, regulatory/compliance, or historical reasons.

Examples of legacy data include:

• customer records
• financial data
• Emails
• Documents
• Databases
• Dpreadsheets
• Presentations
• Data stored on old storage devices that are not used much anymore

Importance of Managing Legacy Data

Managing legacy data is crucial for several reasons:

• Compliance: Legacy data might be required to follow specific regulations on how it’s stored, managed, protected, and deleted. Not following these rules can lead to legal trouble, financial penalties and business loss and can also harm your reputation.
• Better Data Management: Legacy data can give valuable insights for business decisions, trends, and planning. Managing it well ensures it stays useful even as technology changes.
• Improved Decision-making: Analysing legacy data helps understand past business operations and improve future decisions. It can also reveal patterns useful for product development, marketing, and more.
• Better Customer Service: Having access to past data helps provide better service. For example, knowing a customer’s buying history can help tailor products and services to their needs.
• Cost Savings: Properly managing legacy data helps avoid the costs of maintaining outdated systems and tech. This includes hardware and software maintenance, data migration, and legal compliance.

Even though it’s important, managing old data can be tough. Your organisation might have lots of sensitive data in outdated legacy systems, which could lead to data loss, breaches, or compliance issues. But there are steps you can take to keep that data safe and protect your organisation.

1. Ensure Regulatory Compliance

Lots of companies have to follow legal regulations about how they handle and keep different types of data, including legacy data. In India, the DPDPA sets out many obligations for companies that collect, use, store or share personal data. In case of non-compliance, they could face big fines, up to INR 250 crore.

You can use the DPDPA Readiness Review to see how the privacy law affects all parts of your business.

2. Assess Data Privacy Risks

The next step is to look at how your data privacy practices are functioning currently and find any weak points. You can leverage DPDP Consultant’s DPDPA Compliance Assistance, to set up internal audit frameworks for regulatory alignment.

3. Implement Data Privacy Principles.

Put data privacy principles into action by following guidelines for collecting, processing, storing, and sharing data. The DPDPA outlines principles like data minimisation, purpose limitation, consent, accuracy, security, accountability, and transparency.Serve Privacy notice to consented data Principals whose data is stored by your legacy systems. Take consent if not already available. Honor Data principals rights.

Use these principles to create and enforce policies and procedures that respect the rights and preferences of data principals. Make sure to document and share these policies with your data subjects, stakeholders, and regulators.

4. Apply Data Privacy Techniques

Use data privacy techniques to keep your data safe from unauthorised access, use, or disclosure. Techniques like encryption, pseudonymisation, anonymisation, masking, and tokenisation can help. These techniques change or hide your data so it’s still useful but harder to identify or misuse. Make sure to check and review these techniques regularly to make sure they work well. A Data Protection Impact Assessment (DPIA) tool helps with this process, making it easier for Data Protection Officers (DPOs) to conduct DPIAs using a user-friendly platform.

5. Adopt Data Privacy Tools

You can also use data privacy tools to make your data privacy tasks easier by automating them. Tools like data discovery, data classification, data governance, data lineage, and data quality can help you find, organise, manage, track, and enhance your data in your legacy system.

Data Principal Consent Management (DPCM) is one of the DPDPA tools that helps in creating notices that align with the act’s provisions, ensuring your processes remain clear and transparent.

An automated Data Principal Grievance Redressal (DPGR) tool enables data principals to easily exercise their rights through a user-friendly platform and enables requests to be accessed by Data Protection Officers or concerned persons manually or automatically.

6. Update your Data Privacy Skills

Keeping your data privacy skills up-to-date is important. The field is always changing, so it’s crucial to stay on top of the latest trends, standards, and best practices. You can do this by taking online courses, reading blogs and books, attending webinars and conferences, and joining data privacy communities and networks.

An easier way to do this is through the Data Protection Awareness Program (DPAP). It’s a subscription-based tool that helps companies run regular and mandatory awareness sessions, followed by assessments. This ensures that every employee understands the DPDPA and knows what could happen if they don’t comply. The assessments make sure everyone takes the program seriously, and the results are shared with all stakeholders.

7. Plan a Data Privacy Strategy

The last step is to plan out your data privacy strategy and roadmap. Data privacy isn’t just a one-time thing; it’s an ongoing process that needs regular checking, reviewing, and enhancing.

To plan your strategy, start by setting your data privacy goals, objectives, and metrics. Make sure these align with your business and data engineering goals. Then, prioritise your data privacy projects, assign your resources, and keep track of your progress and results.

Overcoming the Challenge of Legacy Data

Dealing with legacy data can be tough for many organisations. The challenges can vary depending on the organisation and where they are located. To tackle these challenges, companies might need to invest in special tools and know-how to handle legacy data well.

One way to get this expertise is by partnering with DPDP Consultants.

Our team of experts know all about data protection and privacy rules and can help you build compliance and get valid consent for all your customers’ and stakeholders’ personal data.

Our tailored solutions equip your organisation with the necessary skills, tools, and know-how to efficiently adhere to these regulations and manage legacy data effectively. We ensure the ongoing accessibility, accuracy, and security of your data. Moreover, we uncover valuable insights within this data to fuel your business growth. Additionally, our team can help you with strategies to migrate legacy data to more user-friendly systems.

Legacy Data Is a Big Problem. Let us Help You!

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