Executive Summary
You cannot protect what you do not know you have. A data inventory catalogues what personal data the organisation holds, where it is stored, how it flows, and who can access it. This foundational asset supports compliance with nearly every DPDPA obligation. This guide addresses practical approaches to creating and maintaining a data inventory.
Key Takeaways
- 1Start with business processes that involve personal data, not technical systems
- 2Document data flows, not just data stores
- 3Include sufficient detail to support compliance activities
- 4Establish procedures to maintain inventory currency
- 5Use the inventory as a living tool, not a one-time exercise
1Why Data Inventories Matter
A data inventory enables compliance with multiple DPDPA obligations. Responding to access requests requires knowing where to find data. Implementing retention policies requires knowing what data exists. Assessing cross-border transfers requires knowing where data flows. Conducting audits requires knowing what to audit. The inventory is foundational infrastructure for data protection compliance.
2Defining Inventory Scope
Before beginning the inventory effort, define what will be catalogued.
Data Categories
Focus on personal data as defined under DPDPA. Include directly identifying data, indirectly identifying data, and pseudonymised data that can be re-identified.
Organisational Scope
Determine which parts of the organisation are in scope. Start with areas that process significant volumes of personal data.
System Scope
Include formal enterprise systems, departmental applications, cloud services, and shadow IT where identified.
Detail Level
Define the granularity of cataloguing. Data element level detail provides more value but requires more effort than system or category level cataloguing.
3Information to Capture
A useful inventory includes multiple dimensions of information about each data holding.
Data Elements
What specific personal data is collected or processed? Name, email, purchase history, location, etc.
Data Subjects
Whose data is it? Customers, employees, business contacts, website visitors, etc.
Collection Source
How and where is the data collected? Direct from individuals, from third parties, generated through processing, etc.
Processing Purposes
Why is the data processed? Service delivery, marketing, analytics, legal compliance, etc.
Legal Basis
What authorises the processing? Consent, legitimate uses, legal obligation, etc.
Storage Location
Where is the data stored? Specific systems, databases, file shares, cloud services.
Access Permissions
Who can access the data? Roles, teams, individuals, third parties.
Data Flows
Where does data move? Internal flows between systems, external flows to third parties, cross-border transfers.
Retention Period
How long is the data retained? Applicable retention period and deletion procedures.
4Inventory Methodology
Several approaches can be used to gather inventory information.
Process Mapping
Start with business processes and map what data flows through them. This approach grounds the inventory in business reality.
System Discovery
Inventory systems and applications, then catalogue what personal data each contains. Useful for technical completeness.
Stakeholder Interviews
Interview business unit leaders, system owners, and data stewards about their data holdings. Captures institutional knowledge.
Automated Discovery
Use data discovery tools to scan systems and identify personal data. Provides technical completeness but requires interpretation.
Hybrid Approach
Combine methods for comprehensive coverage. Process mapping for context, automated discovery for completeness, interviews for validation.
5Inventory Tools
Choose appropriate tools based on organisational size and complexity.
Spreadsheets
Simple and accessible for smaller organisations. Limitations emerge with scale and complexity.
Purpose-Built Software
Data mapping and privacy management platforms provide structured templates, workflow support, and reporting. Worth investment for larger organisations.
GRC Integration
If the organisation uses governance, risk, and compliance platforms, data inventory may integrate with existing risk management.
Data Catalogues
Technical data catalogue tools focused on metadata management can be extended for privacy inventory purposes.
6Maintaining Inventory Currency
An outdated inventory is a false comfort. Establish procedures to keep it current.
Change Triggers
Define events that should trigger inventory updates: new systems, new processing activities, organisational changes, system decommissioning.
Periodic Review
Schedule regular comprehensive reviews to catch changes that did not trigger updates. Annual review at minimum.
Ownership Assignment
Assign responsibility for maintaining accuracy. Data stewards or system owners should own inventory entries for their domains.
Process Integration
Integrate inventory updates into related processes. New system procurement should include inventory documentation. Privacy impact assessments should update the inventory.
7Using the Inventory
The inventory's value lies in its use for compliance and operational purposes.
Access Requests
Use the inventory to identify where to search when responding to Data Principal access requests.
Deletion Requests
Reference the inventory to ensure erasure requests are executed across all relevant systems.
Compliance Audits
The inventory provides the scope and baseline for compliance assessments.
Risk Assessment
Use the inventory to identify high-risk processing activities requiring closer attention.
Breach Response
When incidents occur, the inventory helps assess what data may be affected and who needs notification.