How to address the GDPR after Brexit? Use AI! | Risk Advisory | Deloitte Netherlands


How to address the GDPR after Brexit? Use AI!

DocQMiner Use Cases Series

When the United Kingdom leaves the EU, the UK will be seen as a ‘third country’ from a GDPR perspective. From that moment on, any personal data pertaining to EU citizens that is transferred to the UK will need to be adequately protected, and contractual and operational safeguards will need to be in place to comply with the GDPR. Deloitte’s document review platform DocQMiner can help.

Your challenge

From the moment Brexit is a fait accompli and until an adequacy decision is reached (which may take years), the UK will be regarded as a ‘third country’ from a GDPR perspective. Under the GDPR, organizations that transfer the personal data of data subjects who are in the EU to a ‘third country’ need to be able to prove that it is protected to a comparable level as that in the EU.

If the implemented safeguards are not in place, or aren’t compliant with the GDPR , it will not be allowed to transfer the data to the UK, disrupting vital business processes. This applies even though the UK may have legislation in place that is equivalent to the GDPR. Even storing personal data in the UK of data subjects who are in the EU might be a risk after Brexit.

To stay ahead, you need to know what personal data your organization or your data processors (and sub processors) are transferring to the UK and which safeguards are contractually in place. That may require an organization to check hundreds or more contracts. To ensure you can take control of your personal data processing from a contracting perspective, Deloitte created DocQMiner.

What is DocQMiner?

DocQMiner is a document review platform that uses artificial intelligence. It makes data collection (including data tables and data flows) and the potential amending of contracts more efficient, while improving the quality of extracted data. It also provides a complete audit trail. The review workflow in DocQMiner enables users to identify personal data transfer-related clauses in contracts affected by Brexit, enabling any required amendments.

Because the artificial intelligence in DocQMiner understands the meaning of natural language, a contract does not have to be in a predefined format, structure or template. DocQMiner also enables users to amend the text of a legal document as input for the amending exercise, making the remediation of contracts as easy as possible. DocQMiner is essential for a controlled and structured repapering process, involving all stakeholders, and empowering you to continuously track the status of a contract.

How does DocQMiner work?

DocQMiner acts as a central repository or hub from which amendment efforts can be coordinated with suppliers and customers. When an organization starts using DocQMiner, our privacy experts first highlight personal data transfer-related clauses in unstructured documents (e.g. contracts) impacted by Brexit. The highlighted clauses are then used to train a machine learning model to suggest which clauses may be affected and may require amending.

When a new document enters the workflow, the machine learning model suggests which clauses may be affected , and the user reviews provided suggestions. The result is an iterative learning cycle, in which the quality of suggestions improves over time and the efficiency of both data collection and repapering increases. Users also have the option to enter a revised text for the repapering phase.

Why use DocQMiner?

Deloitte’s artificial intelligence specialists and privacy experts have teamed up to make DocQMiner; an accelerator and enabler for the contractual challenges related to the GDPR and Brexit. In the remaining period leading up to Brexit, users of DocQMiner can quickly investigate the location of the (sub)processors and identify the contracts and clauses that need to be amended to facilitate compliance with the GDPR. This conserves organizational resources while simultaneously speeding up the process. Moreover, using DocQMiner improves the quality of the amending process, and helps you stay in control during a complex and costly operation.

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The benefits of DocQMiner apply to many use-cases. Our dedicated sales team is ready to start the conversation with you.

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More information

If you want to know more about DocQMiner, please contact Marc Verdonk or Annika Sponselee.

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