Hey, DPO—Are You in the Loop on That System Migration?

System migrations aren't just about cost or tech anymore—they’re about privacy too.

Yesterday, we switched to a new CRM system. Sounds routine, right? But migrating personal data without involving the privacy officer is asking for trouble. Here are 5 key considerations to ensure privacy doesn’t get lost in the shuffle:

• International Data Transfers
  Many CRMs host data outside your country. Have you conducted a Transfer Impact Assessment (TIA) or Data Transfer Impact Assessment (DTIA)? These assessments evaluate the privacy implications of transferring data across borders. Even if your regulations don’t explicitly require them, they’re a great way to minimize risks and adopt best practices.

• Updating the DPA
  Your Data Processing Agreement (DPA) likely outlines the systems in use, security measures, and risk profiles. Switching to a new system could impact existing agreements. While naming specific tools in a contract might be rigid, including their categories, purposes, and data handled ensures your agreements stay relevant.

• Legacy Data Integrity
  What happens to the data in your old system? Does canceling the service ensure that all personal data is deleted? Is there a contractual retention period? Handling, deleting, or transferring legacy data is just as much “data processing” as using it.

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• Security Standards
  Have you assessed the security criteria of the new system? Downgrading security measures for cost savings can backfire. For instance, if your old system used multi-factor authentication (MFA) but the new one relies solely on username and password, is that risk worth exposing your entire database to potential attacks?

• Migration Process Risks
  Not all systems support seamless data migrations (API-to-API). Many involve manual spreadsheets—cue the spreadsheet chaos. Sending spreadsheets by email, involving third parties, or accidental misaddressing (hello, gmai.com) opens up massive risks.

Bonus Insight:
Did you know that "gmai.com" is a real domain? A quick search reveals countless horror stories of people accidentally emailing sensitive info to the wrong address. Are you confident everyone in your organization will type it correctly?

Final Thought:
Data migrations touch on fundamental privacy rights. Make sure your DPO is part of these decisions—not as an afterthought but as a trusted advisor who ensures privacy risks are managed effectively.

Midweek musings over. Let’s get to work. 🛡️