- Data flow tables describe the collection, use and disclosure of personal information in the business process.
- The tables follow each data element or cluster from collection, use, disclosure and to disposition.
- A good example of a data cluster could be client identification for authentication (name, date of birth, country of birth, case number).
- The following tips are important:
- Consider data flow, data sharing, data retention and data disposal in your analysis.
- Make sure the information in the Questionnaire relates to the data flow tables.
- Discuss how information is acquired (indirectly or directly).
- Keep 'scope' in mind at all times. One of the key challenges with data flow tables is scope and the tables can become too detailed or conversely, not detailed enough.
- Consider writing down a point by point description of what happens. Information to flesh out the proposal description can be added later.
- Use data dictionaries to list out all the required information.
- Use the table provided in the Word template.
It's easy to over-complicate your Data Analysis. Keep it as simple as possible. Stay focused and organized.
As you work through the Privacy Analysis phase of the PIA and specifically, the Questionnaire, expect to revise this section of your Report.
The OPC has noted that many PIAs have incomplete inventories of data elements collected and used (information may be described but it
is not illustrated in a data flow table).
Data Flow Analysis - Business Flow Diagram & Description
Privacy Analysis
Introduction