Authorization for Processing

Authorization for processing personal data represents the start of personal data processing for a purpose that relies on legal basis other than consent, such as legitimate interest or contractual obligations. Unlike consent, which requires the explicit expression of the data subject’s free will for specific purposes, authorization for processing applies when data processing is based on other legal basis like legitimate interest or contractual obligations.

These purposes are often not adequately mapped and managed precisely because they do not rely on consent. However, according to privacy notices, these purposes typically have their own retention period and constraints regarding the right to object or exercise other rights by data subjects. Failure to manage these aspects creates significant risks of non-compliance and privacy violations within the organization.

Authorization for processing marks the start of the data retention period for each specific purpose, beginning from when the privacy notice detailing the relevant purpose is acknowledged (e.g., handling commercial requests, soft spam, etc.), ensuring that processing is lawful and GDPR-compliant. This moment must be accurately documented to ensure the company can demonstrate the lawfulness of personal data processing and reduce the risk of sanctions in the event of inspections or disputes. This way, it is guaranteed that all personal data processing activities are compliant, and that data processing is properly documented, not limited to just explicit consents.
Trust Guardian’s approach to authorization for processing
Trust Guardian automates the management of authorization for processing for purposes based on legitimate interest, contractual obligations, or other legal basis different from consent. The platform tracks each authorization and records the start of the retention period, calculated from the acknowledgment of the privacy notice detailing the purpose of processing. It integrates with various business systems to ensure that data is managed in compliance with regulations. This approach reduces the risk of unauthorized processing, enhances operational efficiency, and ensures that each processing activity is always updated and aligned with company policies and the preferences of data subjects.