A Governance, Risk, and Compliance (GRC) Solution to the Global Data Privacy Quagmire
Consumer data privacy is one of the most compelling and far-reaching issues of our time. As of early 2024, 162 countries have enacted data privacy laws, including 17 that passed legislation from 2021 to 2023. The European Union has enacted the comprehensive General Data Protection Regulation (GDPR), 15 U.S. states have passed privacy legislation, and many other jurisdictions either have done or likely will do the same.
The Challenge of Achieving Data Privacy Compliance
All this legislation creates enormous governance, risk, and compliance (GRC) challenges for global businesses. Achieving compliance with any privacy regulation can mean making significant changes to a company’s GRC systems, processes, and documentation.
On top of all that, legislation is constantly evolving. The widespread business adoption of generative AI (GenAI) creates new privacy risks. Not surprisingly, businesses often struggle to comply with privacy laws. The cost of running afoul of these regulations can be costly.
One example is the $1.19 billion fine levied against Didi Global for privacy breaches in 2023. To avoid falling into similar circumstances, businesses need to monitor the emergence of privacy laws around the world and modify existing ones—but that's easier said than done. Fortunately, commercial technology solutions alongside GenAI can help.
A Social Media Company’s Struggle for Data Privacy Compliance
To better understand how difficult it is for businesses to manage GRC effectively, let’s consider the example of a hypothetical social media platform. Our platform—let’s call it Zenne—has hundreds of millions of users across more than 100 countries. Over the past few years, Zenne’s GRC team would have needed to understand and respond to several new privacy laws including Canada’s Consumer Privacy Protection Act (CPPA), India’s Digital Personal Data Protection (DPDP) Act, updates to GDPR, and more.
Now, put yourself in the shoes of Zenne’s GRC team, which manages the potential impacts of CPPA compliance. The CPPA aims to modernize Canada’s data privacy landscape beyond the country’s existing PIPEDA (Personal Information Protection and Electronic Documents Act). Although the CPPA hasn't been officially enacted yet, you need to prepare for its eventual passage—just in case.
As a company handling sensitive personal information belonging to millions of users, including Canadians, you’ll need to prepare for the passage of CPPA by coming up with a plan to adjust your practices.
Myriad Changes Required
For example, Zenne’s consent processes would likely need an overhaul. The CPPA requires “meaningful consent,” which goes beyond simple opt-in boxes. The app would have to provide granular control to users, clearly explaining how Zennue uses data for each individual purpose (advertising, analytics, etc.).
Zenne, like any social media platform, collects a wealth of first-party user data. The CPPA’s data minimization principle means you now need to scrutinize what data is truly necessary for specific, legitimate purposes and delete what’s not. Because the CPPA encourages efforts to mitigate bias in algorithmic decision-making, you would also need to audit your algorithms to identify and address potential unfairness or discrimination.
How could you stay on top of these myriad requirements and manage the GRC requirements related to the CPPA? And how could you know what laws might be emerging around the world while addressing those that have already been enacted? The answer: apply GenAI with a risk and compliance solution like Microsoft Purview.
Deploying GenAI to Monitor for New Data Privacy Regulations
Businesses can use GenAI to monitor the global data privacy landscape for evolving regulations, as long as they keep a close eye on it to mitigate privacy risks.
In context of regulations like the CPPA, a company could use GenAI models trained on Canadian legal resources to monitor relevant channels (government websites, legal publications, news outlets, etc.) for any announcements or proposals related to amendments to this legislation.
The GenAI tool could then quickly identify and summarize the specific changes being discussed. Depending on the chosen tool, it might also provide recommendations for where your company’s policies should be updated to align with evolving laws. This would save time and effort for legal and compliance teams.
GenAI could also possibly go beyond simple monitoring and help your business respond to external user queries. GenAI, especially models trained on code, could help end users visualize your business’s data flows, tracing how user data is collected, stored, and processed across different systems. This can reveal potential risks, bottlenecks, and identify areas requiring stronger data privacy controls.
A Risk and Compliance Solution
But to really manage the impacts of changing data privacy laws on your business’s GRC, you’d need to integrate GenAI with a heavy-duty risk and compliance solution. Take Microsoft Purview for example.
Purview is a comprehensive solution for GRC. It offers pre-built assessment templates for major regulations like GDPR, CCPA, and others. These templates allow your business to track its compliance posture against specific standards.
Purview also supports custom assessments for niche regulations or internal policies. This helps your business enforce policies covering how sensitive data is used and accessed, such as encryption, retention rules, and labeling.
The Benefits of GenAI-Enabled Data Privacy
In the case of Zenne, our hypothetical social media company from earlier, Purview could manage multiple functions:
- Purview Compliance Manager would help Zenne identify and catalog sensitive data across its systems (including cloud storage in Azure and Microsoft 365). This is crucial for any data privacy law, as it’s impossible to protect data you don’t know you have. GenAI could improve Purview Compliance Manager by making its assessments more specific to the CCPA’s requirements and by helping it identify potential compliance risks within Zenne’s data landscape.
- Purview Information Protection would help classify and label sensitive data. This would make it easier to enforce privacy policies and monitor what data is subject to specific regulations. GenAI could work with Purview Information Protection to automate the classification of sensitive data based on CCPA guidelines and suggest specific, highly accurate labels. This would make Zenne’s data protection efforts more efficient and reduce errors stemming from manual classification.
- Purview Data Lifecycle Management would help Zenne automate the retention and deletion of data based on its sensitivity and specific regulatory obligations. This helps ensure compliance with data minimization principles present in many privacy laws. GenAI could integrate with Purview Data Lifecycle Management to act as a knowledge base for CCPA-specific retention and deletion requirements. This could enable Purview to dynamically adjust data lifecycle policies. Zenne would ensure compliance without its GRC team needing to manually interpret complex legal regulations.
A Major Value-Add
In the context of the CPPA, a GenAI-enabled tool like Microsoft Purview would be a major value-add. Purview could scan Zenne’s data assets across cloud services, on-premises systems, and SaaS applications to pinpoint where the personal data of Canadian users resides.
This is the foundation of any data privacy compliance program. Purview’s automated tools and machine learning models can identify sensitive data types as defined by the CPPA, like personal identifiers, health information, or new categories introduced in any potential updates to the law.
Purview Record Management could help Zenne meet CPPA’s requirements around data retention periods and deletion. This would let them set time limits for keeping data and flag records relevant to specific compliance obligations.
And, frankly, this is barely scratching the surface. The point is that businesses need to invest in solutions like Purview alongside GenAI to protect themselves, their customers, and their business partners. There’s no other way to do this right—and the costs of not doing it right are just too high.
Next Steps
We at Centific, an industry leader in AI data services, recommend you:
- Plan for how to monitor evolving privacy laws with GenAI. This plan should mandate human-in-the-loop training and revising to ensure proper use.
- Work with privacy experts (either inside or outside the enterprise) to choose a compliance solution that suits your needs.