Consent Management (for GDPR)

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Consent is the explicated permission of the Data Subject to have / use their personal data.
Data Subjects are natural persons, e.g. consumers, employee-consent, vendors, consultants.

Data retention shall be based on legal and privacy concerns versus economics and the need-to-know.

The requirement on consent are increased under GDPR. It is needed, when other grounds cannot be applied (main other grounds: legal obligation, contractual obligation) and business still have an interest to have / use it.

When reviewing and updating the Consent Management e.g. the following actions shall be considered:

  • Identify current cases / channels of consent, via the Data Collection
  • Assess if cases of consent can be reduced
  • Review consent statements (today and new proposed)
  • Operationalize a new EU (later potentially Global) consent management IT tool
  • Update consent policies and procedures
  • Consider to stop / change processing, where applicable
  • Gain new consents, where required
  • Consider actions in area of retention

Requirements on IT-systems to perform Consent Management could contain the following:

  • Tracking of consent given per Data Subject
  • Support that for different websites/shops/app’s, different selected consent can be handled
  • Support (other system performing) mass mailings
  • Multi language support
  • Version handling
  • Expand button, in case consent language is long
  • Preference center to manage all consents by data subject, incl withdrawal
  • Reporting on consent
  • Combine multiple channels, and work with 1 consent (one consumer can have an oven and a vacuum cleaner)
  • Multi branding

Wikipedia has (April 2020) a healthcare focused definition on Consent Management.

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