Client Profile
A multinational healthcare technology provider with over 15,000 employees and operations in 35 countries. The client handles sensitive patient data through SaaS platforms used by hospitals, clinics, and insurers. The organization initiated a GDPR compliance transformation in response to increased scrutiny from EU regulators and client concerns about data privacy practices.
Challenges Faced
Key security concerns included:
- Unstructured handling of Personally Identifiable Information (PII) across departments
- Lack of documented lawful basis for data processing activities
- Inadequate data subject access request (DSAR) fulfillment workflows
- No formal Data Protection Impact Assessment (DPIA) framework in place
Solution
COE Security implemented a tailored GDPR Readiness & Enablement Program, combining:
- Data Discovery & Mapping: Automated scans and workshops to classify personal data flows
- Risk-Based DPIA Framework: Established thresholds and workflows for consistent privacy impact assessments
- Policy & Control Implementation: Deployed GDPR-aligned data protection, retention, and breach notification policies
- Employee Privacy Awareness Training: Built organizational knowledge through gamified e-learning modules
Operational Enablement and Compliance Milestones
- Mapped over 150 unique data processing activities across business units
- Implemented centralized DSAR workflow with automated tracking and escalation
- Reduced unencrypted PII storage by 92% through policy enforcement and cloud remediation
- Enabled pseudonymization for analytics datasets used in R&D
- Built consent and preference management capabilities into the client’s SaaS platform
Governance, Strategy & Readiness Enhancements
- Established a cross-functional Data Protection Office (DPO-led) with quarterly governance reviews
- Integrated GDPR controls into vendor due diligence and onboarding process
- Created and enforced 12 updated policies including data retention, access control, and incident response
- Developed GDPR audit playbooks for both internal and third-party assessments
COE GDPR Compliance Service Portfolio
- GDPR Gap Assessment & Maturity Roadmap
- Personal Data Inventory & Mapping
- Data Subject Rights Management Automation
- Data Protection Impact Assessment Frameworks
- Vendor Risk & Third-Party Compliance Reviews
- GDPR Awareness & Training Programs
- Privacy Policy & Control Design
- Consent Lifecycle & Cookie Management
- Legal Basis Review & Documentation
- Data Breach Response Planning & Simulation
Implementation Details
- Deployed data discovery tools integrated with Azure and AWS cloud environments
- Established integrations with ServiceNow for DSAR, DPIA, and incident workflows
- Delivered live and on-demand training to 3,000+ employees
- Created role-specific privacy guidelines and documentation
- Provided monthly compliance dashboards to CISO and General Counsel
Results Achieved
- 100% GDPR audit-readiness within 90 days
- 92% reduction in exposed personal data in unstructured repositories
- Improved average DSAR fulfillment time from 30 to 6 days
- Increased privacy maturity score from Level 2.1 to 4.0 (out of 5)
Client Testimonial
“COE Security’s expert-led approach to GDPR made what initially felt overwhelming entirely achievable. Their combination of governance and technical delivery gave us peace of mind and the confidence to face regulatory reviews head-on.”