Subject: SAP-Data-Privacy
Article Code: 084
Author: ChatGPT
Date: May 25, 2025
Under data privacy regulations such as the GDPR, data subjects have the right to restrict the processing of their personal data. This means individuals can request that an organization limits how their data is used under specific circumstances. For organizations running SAP systems like SAP S/4HANA, efficiently managing and responding to these restriction requests is critical for compliance and maintaining customer trust. This article explores how to handle data subject restriction of processing requests in SAP environments.
A restriction of processing request is a formal demand from a data subject to temporarily or permanently limit the processing activities involving their personal data. Restrictions may apply in cases such as:
- Disputes over the accuracy of data (while accuracy is verified).
- Processing is unlawful but the individual opposes erasure.
- The organization no longer needs the data but the individual requires it for legal claims.
- The individual has objected to processing pending verification of legitimate grounds.
During the restriction period, the organization can only store the data but cannot use it for other processing purposes.
SAP systems often serve as the digital core for managing personal data. Responding promptly and accurately to restriction requests ensures:
- Compliance with GDPR Article 18 and similar data protection laws.
- Avoidance of penalties and reputational harm.
- Respect for individual privacy rights.
- Transparency and trust in business operations.
¶ 3. Steps to Handle Restriction Requests in SAP
¶ a. Identification and Validation
- Use SAP data subject request management tools or SAP Information Lifecycle Management (ILM) to log and track requests.
- Validate the identity of the requester to prevent unauthorized requests.
¶ b. Data Discovery and Impact Analysis
- Identify all instances of the subject’s personal data across SAP modules (e.g., HR, Sales, CRM).
- Assess processing activities impacted by the restriction (reporting, marketing, billing).
- Using SAP ILM, restrict further processing activities while preserving data for storage.
- Suspend automated workflows or data transfers involving the subject’s data where required.
- Update access permissions if necessary to prevent processing by users.
- Inform the data subject about the status of their request and any limitations.
- Document all actions taken for audit purposes.
¶ e. Review and Lift Restrictions
- Periodically review the status of the restriction, especially if based on disputes or objections.
- Lift restrictions when the conditions prompting the request no longer apply.
- SAP Data Privacy Management by ERP for Data Protection: Provides workflows to manage data subject rights including restriction requests.
- SAP ILM: Controls data retention and processing restrictions.
- SAP Access Control and Authorization Management: Restricts user access to the data in line with processing limitations.
- SAP Information Lifecycle Governance: Automates data lifecycle and compliance tasks.
- Maintain a Centralized Request Management System: Track all data subject requests in one place to avoid delays or missed actions.
- Regularly Train Employees: Ensure that staff handling personal data understand restriction obligations.
- Automate Where Possible: Use SAP workflows and tools to reduce manual errors and speed up response times.
- Document Everything: Maintain logs and audit trails of requests and actions for compliance audits.
- Coordinate Across Departments: Engage legal, compliance, IT, and business units for effective response.
Responding to data subject restriction of processing requests is a critical component of SAP data privacy compliance. Leveraging SAP’s native tools, alongside clear processes and employee training, enables organizations to honor individual rights effectively while safeguarding business operations. Timely and transparent handling of these requests reinforces trust and positions organizations as responsible custodians of personal data.
Keywords: Restriction of Processing, Data Subject Rights, SAP Data Privacy, SAP ILM, GDPR Compliance, Data Subject Request Management, Data Protection
Category: SAP-Data-Privacy
Word Count: ~640