IP Library Granted Patent US 10,949,567
Granted Patent B2
US 10,949,567 · App. 17/019,771 · Granted Mar 16, 2021

Data processing systems for fulfilling data subject access requests and related methods

Inventors: Kabir A. Barday (Atlanta, GA); Jason L. Sabourin (Brookhaven, GA); Jonathan Blake Brannon (Smyrna, GA); Mihir S. Karanjkar (Marietta, GA); Kevin Jones (Atlanta, GA)
Assignee: OneTrust, LLC
G06F21/6245G06F15/76G06F21/31G06F21/552H04L41/5029H04L41/5064H04L63/102H04L63/107H04L63/108H04L63/12H04L63/20G06F2221/2103G06F2221/2111G06F2221/2137H04L67/20
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Quick Facts
Patent No.
US 10,949,567
App. No.
17/019,771
Granted
Mar 16, 2021
Kind
B2
Abstract

Responding to a data subject access request includes receiving the request and identifying the requestor and source. In response to identifying the requestor and source, a computer processor determines whether the data subject access request is subject to fulfillment constraints, including whether the requestor or source is malicious. If so, then the computer processor denies the request or requests a processing fee prior to fulfillment. If not, then the computer processor fulfills the request.

Claims (76)

1. A computer-implemented data processing method for responding to a data subject access request, the method comprising:

receiving, by one or more computer processors, the data subject access request from a requestor comprising one or more request parameters, wherein the one or more request parameters comprise one or more pieces of personal data associated with the requestor;

validating, by the one or more computer processors, the requestor based at least in part on the one or more request parameters;

at least partially in response to validating the requestor, determining, by the one or more computer processors, based at least in part on fulfillment constraint data, whether the data subject access request is subject to one or more response fulfillment constraints associated with the requestor, wherein determining whether the data subject access request is subject to the one or more response fulfillment constraints comprises determining whether the data subject access request comprises one of a threshold quantity of data subject access requests from the requestor within a threshold time period;

at least partially in response to determining that the data subject access request is subject to the one or more response fulfillment constraints, determining, by the one or more computer processors, based at least in part on historical data associated with the requestor, whether to fulfill the data subject access request;

at least partially in response to determining, based at least in part on the historical data associated with the requestor, not to fulfill the data subject access request, taking, by the one or more computer processors, one or more actions selected from a group of actions comprising:

(a) denying the data subject access request; and

(b) requesting, from the requestor, one or more processing fees prior to fulfilling the request;

at least partially in response to determining, based at least in part on the historical data associated with the requestor, to fulfill the data subject access request, fulfilling, by the one or more computer processors, the data subject access request; and

at least partially in response to determining that the data subject access request is not subject to the one or more response fulfillment constraints, fulfilling, by the one or more computer processors, the data subject access request.

2. The computer-implemented data processing method of claim 1 , wherein the historical data associated with the requestor comprises a rating associated with the requestor.

3. The computer-implemented data processing method of claim 1 , wherein the historical data associated with the requestor comprises one or more pieces of data selected from a group of pieces of data consisting of:

(a) one or more spending characteristics of the requestor;

(b) one or more complaint characteristics of the requestor; and

(c) a status of the requestor.

4. The computer-implemented data processing method of claim 3 , wherein:

the historical data associated with the requestor comprises the one or more spending characteristics of the requestor; and

the one or more spending characteristics of the requestor comprises an amount of money spent by the requestor over a particular time period.

5. The computer-implemented data processing method of claim 4 , wherein determining, based at least in part on the historical data associated with the requestor, whether to fulfill the data subject access request comprises determining, by the one or more computer processors, whether the amount of money spent by the requestor over the particular time period exceeds a threshold.

6. The computer-implemented data processing method of claim 1 , wherein the threshold time period comprises a single day.

7. The computer-implemented data processing method of claim 1 , wherein the historical data associated with the requestor comprises a current or former employment status of the requestor.

8. A non-transitory computer-readable medium storing computer-executable instructions for responding to a data subject access request by:

receiving, by one or more computer processors, the data subject access request from a source of the data subject access request comprising one or more request parameters, wherein the one or more request parameters comprise one or more pieces of personal data associated with a requestor;

identifying, by the one or more computer processors, the requestor based at least in part on the one or more request parameters;

at least partially in response to identifying the requestor, determining, by the one or more computer processors, based at least in part on fulfillment constraint data, whether the data subject access request is subject to one or more response fulfillment constraints associated with the requestor, wherein determining whether the data subject access request is subject to the one or more response fulfillment constraints comprises determining whether the data subject access request comprises one of a threshold quantity of data subject access requests from the requestor within a threshold time period;

at least partially in response to determining that the data subject access request is subject to the one or more response fulfillment constraints, determining, by the one or more computer processors, based at least in part on historical data associated with the requestor, whether to fulfill the data subject access request;

at least partially in response to determining, based at least in part on the historical data associated with the requestor, not to fulfill the data subject access request:

notifying, by the one or more computer processors, the requestor that the data subject access request is subject to one or more limitations; and

taking, by the one or more computer processors, one or more actions selected from a group of actions consisting of:

(a) denying the data subject access request; and

(b) requesting, from the requestor, one or more processing fees prior to fulfilling the request;

at least partially in response to determining, based at least in part on the historical data associated with the requestor, to fulfill the data subject access request, fulfilling, by the one or more computer processors, the data subject access request; and

updating the fulfillment constraint data, by the one or more computer processors in a computer memory, to reflect that the data subject access request was received.

9. The non-transitory computer-readable medium of claim 8 , wherein:

the one or more request parameters comprise one or more pieces of source data; and

the computer-executable instructions further comprise instructions for identifying, by the one or more computer processors, the source of the data subject access request based at least in part on the one or more pieces of source data.

10. The non-transitory computer-readable medium of claim 9 , wherein the one or more response fulfillment constraints are associated with the source of the data subject access request.

11. The non-transitory computer-readable medium of claim 10 , wherein the source of the data subject access request is selected from a group consisting of:

(a) a particular IP address;

(b) a particular domain; and

(c) a particular geographical region.

12. The non-transitory computer-readable medium of claim 8 , wherein the historical data associated with the requestor comprises one or more pieces of data selected from a group of pieces of data consisting of:

(a) one or more spending characteristics of the requestor;

(b) one or more complaint characteristics of the requestor; and

(c) a status of the requestor.

13. The non-transitory computer-readable medium of claim 12 , wherein:

the historical data associated with the requestor comprises the one or more complaint characteristics of the requestor; and

the one or more complaint characteristics of the requestor comprises a number of complaints received from the requestor over a particular time period.

14. The non-transitory computer-readable medium of claim 13 ,

wherein determining, based at least in part on the historical data associated with the requestor, whether to fulfill the data subject access request comprises determining, by the one or more computer processors, that the number of complaints received from the requestor over the particular time period is zero.

15. A system for processing data subject access requests, the system comprising:

one or more computer processors; and

a computer memory comprising a non-transitory computer-readable medium that stores computer-executable instructions for processing data subject access requests that, when executed by the one or more computer processors, cause the one or more computer processors to perform operations comprising:

receiving, by the one or more computer processors, a data subject access request from a requestor comprising one or more request parameters, wherein the one or more request parameters comprise one or more pieces of personal data associated with the requestor;

validating, by the one or more computer processors, the requestor based at least in part on the one or more request parameters;

at least partially in response to validating the requestor, determining, by the one or more computer processors, based at least in part on fulfillment constraint data, whether the data subject access request is subject to one or more response fulfillment constraints associated with the requestor, wherein the one or more response fulfillment constraints comprise a threshold quantity of data subject access requests from the requestor within a threshold time period;

at least partially in response to determining that the data subject access request is subject to the one or more response fulfillment constraints, determining, by the one or more computer processors, that a quantity of data subject access requests received from the requestor within the threshold period of time exceeds the threshold quantity of data subject access requests;

at least partially in response to determining that the quantity of data subject access requests received from the requestor within the threshold period of time exceeds the threshold quantity of data subject access requests, determining, by the one or more computer processors, based at least in part on historical data associated with the requestor, whether to fulfill the data subject access request;

at least partially in response to determining, based at least in part on the historical data associated with the requestor, not to fulfill the data subject access request, taking, by the one or more computer processors, one or more actions comprising:

(a) denying the data subject access request;

(b) notifying the requestor that the data subject access request is subject to one or more limitations; and

(c) requesting, from the requestor, one or more processing fees prior to fulfilling the request;

at least partially in response to determining, based at least in part on the historical data associated with the requestor, to fulfill the data subject access request, fulfilling, by the one or more computer processors, the data subject access request; and

at least partially in response to determining that the data subject access request is not subject to the one or more response fulfillment constraints, fulfilling, by the one or more computer processors, the data subject access request.

16. The system of claim 15 , wherein the historical data associated with the requestor comprises one or more pieces of data selected from a group of pieces of data consisting of:

(a) one or more spending characteristics of the requestor;

(b) one or more complaint characteristics of the requestor; and

(c) a status of the requestor.

17. The system of claim 16 , wherein:

the historical data associated with the requestor comprises the one or more complaint characteristics of the requestor; and

the one or more complaint characteristics of the requestor comprises a number of complaints received from the requestor over a particular time period.

18. The system of claim 17 , wherein determining, based at least in part on the historical data associated with the requestor, whether to fulfill the data subject access request comprises determining, by the one or more computer processors, that the number of complaints received from the requestor over the particular time period is associated with an extensive complaint history for the requestor.

19. The system of claim 16 , wherein:

the historical data associated with the requestor comprises the status of the requestor; and

the status of the requestor comprises an indication that the requestor is associated with a competitor of an entity receiving the data subject access request.

20. The system of claim 15 , wherein the operations further comprise updating, by the one or more computer processors in the computer memory, the historical data associated with the requestor to reflect that the data subject access request was received.

Assignments (2)
SECURITY INTEREST Recorded Jul 5, 2022
From: ONETRUST LLC
To: KEYBANK NATIONAL ASSOCIATION, AS ADMINISTRATIVE AGENT
Reel/Frame 060573/0001 →
ASSIGNMENT OF ASSIGNOR'S INTEREST Recorded Sep 14, 2020
From: BARDAY, KABIR A.; KARANJKAR, MIHIR S.; SABOURIN, JASON L.; JONES, KEVIN; BRANNON, JONATHAN BLAKE
To: ONETRUST, LLC
Reel/Frame 053760/0455 →