With global data privacy regulations like the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA) emphasizing individual rights over personal data, one of the most important obligations for organizations is to handle Data Subject Erasure Requests—commonly known as the “Right to be Forgotten.” For companies running SAP systems, efficiently processing these requests while maintaining system integrity and compliance poses unique challenges.
This article explores the best practices, challenges, and SAP-centric approaches for managing data subject erasure requests to ensure compliance and uphold data privacy.
A Data Subject Erasure Request is a formal request by an individual to have their personal data deleted or anonymized from an organization’s records. Under regulations like GDPR, individuals have the right to demand erasure when:
Organizations must respond promptly and comprehensively to such requests.
SAP systems are complex, often containing interconnected modules like SAP ERP, SAP S/4HANA, SAP Customer Data Cloud, and SuccessFactors. This complexity creates several challenges:
Identify all data repositories holding personal information, including master data, transactional records, logs, and archives.
SAP Information Lifecycle Management (ILM) can automate data retention, archiving, and deletion based on legal requirements, enabling controlled and auditable erasure.
For data that must be retained for compliance but is subject to erasure requests, anonymization or pseudonymization can protect identity while preserving data utility.
Establish workflows to log, track, and process erasure requests systematically, ensuring timely and consistent handling.
For customer data, SAP Customer Data Cloud provides tools to manage consent and erasure requests across channels effectively.
Before deleting data, analyze dependencies and ensure no critical processes are adversely affected.
Document all erasure activities for compliance and demonstrate accountability to regulatory bodies.
An organization receives an erasure request from a former employee. Using SAP ILM combined with SuccessFactors data management:
Processing data subject erasure requests within SAP systems is a complex but essential task in the era of data privacy regulations. By combining robust data governance, leveraging SAP tools like ILM and Customer Data Cloud, and implementing clear workflows, organizations can meet legal obligations efficiently while maintaining operational integrity.
A proactive approach to handling erasure requests not only ensures compliance but also builds customer trust and demonstrates a commitment to responsible data management.