The General Data Protection Regulation (GDPR) gives individuals the right to request access to their personal data held by organizations. This includes the right to:
- Access personal data.
- Rectify inaccuracies in their data.
- Erase their data in certain circumstances (the right to be forgotten).
When implementing a GDPR data access request (DAR) process on Power Pages, you need to enable users to submit requests for accessing, updating, or deleting their personal information. Here’s a detailed step-by-step guide on how to implement such a process in your Power Pages portal.
1. Create a Data Access Request Form
The first step is to allow users to submit a request for their data. This form will collect the necessary details to identify the user and process the request.
Example of Data Access Request Form:
<form id="dataAccessRequestForm">
<h2>Data Access Request</h2>
<p>Please provide your details to submit a request for accessing or managing your personal data:</p>
<label for="userEmail">Email Address:</label>
<input type="email" id="userEmail" name="userEmail" required>
<label for="requestType">Request Type:</label>
<select id="requestType" name="requestType" required>
<option value="access">Request Access to Data</option>
<option value="rectify">Request Rectification of Data</option>
<option value="delete">Request Deletion of Data</option>
</select>
<label for="additionalDetails">Additional Details:</label>
<textarea id="additionalDetails" name="additionalDetails"></textarea>
<button type="submit">Submit Request</button>
</form>
- User Email: This field allows identifying the user who is making the request.
- Request Type: This allows users to specify the type of request they are making—access, rectification, or deletion.
- Additional Details: This section allows users to add any extra information or context to their request.
2. Implement Backend Logic for Processing Requests
The next step involves implementing the backend logic that processes these requests. You need to connect the form submission to Power Automate, Power Apps, or custom API calls to interact with your data source (Dataverse, SQL, SharePoint, etc.) and fulfill the request.
Steps to Implement Backend Logic:
- Connect the form submission to Power Automate: When a user submits the form, a Power Automate flow can trigger and process the request.
- Fetch User Data: Using the email address provided by the user, you can fetch their data from Dataverse or any other database.
- Process Request Type:
- Access Request: Return the data to the user or send an email with a link to access their data.
- Rectification Request: If the user requests a correction to their data, provide a mechanism for updating their details.
- Deletion Request: If the user requests deletion, ensure that their data is deleted from your database and log the action.
Power Automate Flow Example:
- Trigger on form submission (via Power Pages).
- Search Dataverse (or other data source) using the email address.
- Based on the request type, take the appropriate action:
- Access: Return the data via email or portal.
- Rectify: Update the records in Dataverse.
- Delete: Permanently delete the records from the system and confirm via email.
3. Notify Users About Their Request
It’s essential to notify users about the status of their request. This could be done through email or portal messages.
Example Email Template for Data Access Request:
Subject: Your Data Access Request
Dear [User Name],
Thank you for your data access request. Below are the details of your request:
Request Type: [Request Type]
Request ID: [Request ID]
We are currently processing your request, and we will get back to you shortly with the requested information.
If you have any questions, please contact us at [Support Email].
Best regards,
[Company Name] Support Team
In case of a deletion request, send a confirmation email after deleting the data to let the user know their request has been fulfilled.
4. Log and Monitor Data Access Requests
GDPR requires organizations to keep track of data access requests for accountability. This can be done by logging each request, including:
- The request ID.
- The user’s email.
- The type of request.
- The date and time of the request.
- The action taken (accessed, rectified, deleted).
You can store these logs in Dataverse, SharePoint, or any other system that your organization uses.
Example of Logging a Request in Dataverse:
You can create a custom entity in Dataverse called Data Access Requests and store the following fields:
- Request ID (Auto-generated)
- User Email
- Request Type
- Status (Pending, Completed)
- Timestamp
- Action Taken
This log ensures that all requests are tracked for audit purposes and ensures compliance with GDPR.
5. Confirm User’s Identity (Optional)
For security and verification, it might be necessary to confirm the user’s identity before processing their data access request. This can involve:
- Email verification: Send a confirmation email with a unique code that the user must enter on the portal to confirm their identity.
- Two-factor authentication (2FA): For more sensitive data, 2FA can be implemented before submitting the request.
6. Implement Time Constraints for Fulfilling Requests
GDPR mandates that organizations respond to data access requests within one month. If a request is particularly complex, an extension of up to two additional months is allowed, but the user must be informed within the first month.
To manage this, ensure that your process includes:
- Tracking timestamps for when a request was submitted and when it was processed.
- Automated reminders to ensure that you fulfill the request within the time limit.
7. Enable Data Deletion (Right to be Forgotten)
If a user requests to have their data deleted, GDPR requires that the data be erased from your systems. Ensure that:
- All personal data related to the user is removed from both primary and backup storage.
- You can provide the user with a confirmation that their data has been deleted.
Be mindful that some data might need to be retained for legal reasons (e.g., financial records or contracts), in which case, inform the user of the retention reason.