Eliminate the liability risks associated with document migration, in this case, related to GDPR compliance. Avoid non-compliance fines that can exceed €200 million by being able to prove data integrity in every step you take. Document migration's regulatory and operational aspects must be addressed before disruptions occur within your enterprise.
Keeping up with regulations has become a must for businesses. The evolution of law is creating compliance gaps that go unnoticed even by tech giants. Negligence of the rules or corresponding gaps has already led to severe consequences. According to the GDPR Enforcement Tracker Report, non-compliance fines increased from over 500 in January 2021 to over 2.000 by January 2024, with some of those penalties surpassing the 200 million euros mark. This discussion concerns one of those compliance gaps and how to close them; in other words, Document Migration has liabilities, and Truth Enforcer is the solution to mitigate them.
The structure and consequences of GDPR and Article 5
The information overflow that has now become available as a valuable resource has seen its application across industries and countries grow. This raised concerns for the privacy and security of personal data across the globe. Because of this growing concern, the European Union created the General Data Protection Regulation (GDPR).
The main goal of the GDPR is to protect personal data, but it also addresses business processes that can be often overlooked, such as document and system migrations. Reading Article 5 and how it can apply to migrations raises key compliance questions: How does one prove such integrity? How can someone confirm that the content of the documents being altered was not manipulated during the migration?
That is what Truth Enforcer responds to.
Just because we are focusing on a specific circumstance and its connection to one article does not mean the consequences are less significant. The penalty still fits the fine framework defined by the GDPR:
"(...) the fine framework can be up to 20 million euros, or in the case of an undertaking, up to 4% of their total global turnover of the preceding fiscal year, whichever is higher. (...) less severe violations (...) sets forth fines of up to 10 million euros, or, in the case of an undertaking, up to 2% of its entire global turnover of the preceding fiscal year, whichever is higher."
Document Migration: document integrity and risk mitigation
During document migration, the risks taken by the change of systems or formats do not only affect compliance with regulations but can also damage operations, business processes, or even reputation. The complexity of the process itself varies, but the danger of data being altered or corrupted remains – and that violates GDPR compliance.
Risk mitigation begins with looking at the two sides of migration, human and machine, with a clear mindset on why: human error in data entry or adjustments and technical failures from bugs or system crashes that can jeopardize the transfer. Now, security protocols, retention policies, and access control are key planning considerations for any enterprise that might need to adapt or grow depending on the level of migration. Still, they should not be the sole guard of document integrity.
To guarantee document integrity means considering its fallibility and implementing a procedure that supports that logic. When establishing the migration plan, make sure there are data validations before and after the transfer. How? Secure the document's content with a unique hash stored on an immutable ledger and verify if the hash still matches after the migration is done. These two steps of hash attribution and hash verification secure proof of authenticity with reliability and safeguard you as an individual and your business in the knowledge that proving the integrity of the transferred documents is possible.
Remember that documents can be in different formats and categorized as you wish – the key goal here is to certify authenticity and mitigate liabilities. Even if legal liability is not a concern, reputation damage and operational disruption should be considered, too. As previously mentioned, compliance is not the sole responsibility of an enterprise. Data inaccuracies can lead to mismatched customer information, which is one step away from communication errors and churn rate increases; if any disruptions in business operations impact the time you take to deliver or your decision-making process, then not only the customers but also employees' satisfaction and product quality might be affected as well.
This cascading effect needs to be taken into consideration when planning the migration. Secure a procedure that responds to the key aspects of your enterprise and assure accuracy, integrity, and accountability throughout the process.
Close the Compliance Gap in Document Migration
It is understandable that the database schema, system integration, access management structure, and other components that are part of the migration will affect the planning and implementation, but that does not impede the integrity verification after the transfer is complete.
Outline a comprehensive plan that includes Truth Enforcer as your hashing mechanism. This will allow you to create unique identifiers for each document content before the migration process and allow the immutable audit trail of hashes to enable the post-migration verification that validates if the documents have not been altered or corrupted during the process - evidence of compliance and data integrity.
We recommend that you keep this structure even after the migration because data integrity will remain a vital part of your process. Regular audits and monitoring should be part of the standard procedure for any business that produces or handles data. What enterprise doesn’t these days?
Important warning: do not limit this solution to migrations; the need to have a document verification process is constant and essential. Additionally, even outside of the European Union, there are other regulations (CCPA&CPRA, HIPAA, GLBA, and FISMA) regarding this dynamic. Talk to our experts and find the solution that fits your needs. Feel free to reach out through any of our channels with questions about this or our other solutions.
We are looking forward to connecting software with you!
By Francisco Rodrigues, Business Analyst
"I'm writing about how software integrations can adapt to business environments and respond to industry-specific demands. I want to show enterprises the road to streamline processes, eliminate bottlenecks, and ensure compliance by empowering teams and C-suite executives with the right tools."