Patent Issued for Data processing systems for assessing readiness for responding to privacy-related incidents (USPTO 11328240): OneTrust LLC

2022 MAY 26 (NewsRx) -- By a News Reporter-Staff News Editor at Insurance Daily News -- According to news reporting originating from Alexandria, Virginia, by NewsRx journalists, a patent by the inventors Brannon, Jonathan Blake (Smyrna, GA, US), Clearwater, Andrew (Brunswick, ME, US), Hecht, Trey (Atlanta, GA, US), Thielova, Linda (London, GB), filed on August 20, 2021, was published online on May 10, 2022.

The assignee for this patent, patent number 11328240, is OneTrust LLC (Atlanta, Georgia, United States).

Reporters obtained the following quote from the background information supplied by the inventors: “Over the past years, privacy and security policies, and related operations have become increasingly important. Breaches in security, leading to the unauthorized access of personal data (which may include sensitive personal data) have become more frequent among companies and other organizations of all sizes. Such personal data may include, but is not limited to, personally identifiable information (PII), which may be information that directly (or indirectly) identifies an individual or entity. Examples of PII include names, addresses, dates of birth, social security numbers, and biometric identifiers such as a person’s fingerprints or picture. Other personal data may include, for example, customers’ Internet browsing habits, purchase history, or even their preferences (e.g., likes and dislikes, as provided or obtained through social media).

“Many organizations that obtain, use, and transfer personal data, including sensitive personal data, have begun to address these privacy and security issues. To manage personal data, many companies have attempted to implement operational policies and processes that comply with legal requirements, such as Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) or the U.S.’s Health Insurance Portability and Accountability Act (HIPPA) protecting a patient’s medical information. Many regulators recommend conducting privacy impact assessments, or data protection risk assessments along with data inventory mapping. For example, the GDPR requires data protection impact assessments. Additionally, the United Kingdom ICO’s office provides guidance around privacy impact assessments. The OPC in Canada recommends certain personal information inventory practices, and the Singapore PDPA specifically mentions personal data inventory mapping.

“In implementing these privacy impact assessments, an individual may provide incomplete or incorrect information regarding personal data to be collected, for example, by new software, a new device, or a new business effort, for example, to avoid being prevented from collecting that personal data, or to avoid being subject to more frequent or more detailed privacy audits. In light of the above, there is currently a need for improved systems and methods for monitoring compliance with corporate privacy policies and applicable privacy laws in order to reduce a likelihood that an individual will successfully “game the system” by providing incomplete or incorrect information regarding current or future uses of personal data.

“Organizations that obtain, use, and transfer personal data often work with other organizations (“vendors”) that provide services and/or products to the organizations. Organizations working with vendors may be responsible for ensuring that any personal data to which their vendors may have access is handled properly. However, organizations may have limited control over vendors and limited insight into their internal policies and procedures. Therefore, there is currently a need for improved systems and methods that help organizations ensure that their vendors handle personal data properly.”

In addition to obtaining background information on this patent, NewsRx editors also obtained the inventors’ summary information for this patent: “A computer-implemented data processing method for monitoring one or more system inputs as input of information related to a privacy campaign, according to various embodiments, comprises: (A) actively monitoring, by one or more processors, one or more system inputs from a user as the user provides information related to a privacy campaign, the one or more system inputs comprising one or more submitted inputs and one or more unsubmitted inputs, wherein actively monitoring the one or more system inputs comprises: (1) recording a first keyboard entry provided within a graphical user interface that occurs prior to submission of the one or more system inputs by the user, and (2) recording a second keyboard entry provided within the graphical user interface that occurs after the user inputs the first keyboard entry and before the user submits the one or more system inputs; (B) storing, in computer memory, by one or more processors, an electronic record of the one or more system inputs; (C) analyzing, by one or more processors, the one or more submitted inputs and one or more unsubmitted inputs to determine one or more changes to the one or more system inputs prior to submission, by the user, of the one or more system inputs, wherein analyzing the one or more submitted inputs and the one or more unsubmitted inputs to determine the one or more changes to the one or more system inputs comprises comparing the first keyboard entry with the second keyboard entry to determine one or more differences between the one or more submitted inputs and the one or more unsubmitted inputs, wherein the first keyboard entry is an unsubmitted input and the second keyboard entry is a submitted input; (D) determining, by one or more processors, based at least in part on the one or more system inputs and the one or more changes to the one or more system inputs, whether the user has provided one or more system inputs comprising one or more abnormal inputs; and (E) at least partially in response to determining that the user has provided one or more abnormal inputs, automatically flagging the one or more system inputs that comprise the one or more abnormal inputs in memory.

“A computer-implemented data processing method for monitoring a user as the user provides one or more system inputs as input of information related to a privacy campaign, in various embodiments, comprises: (A) actively monitoring, by one or more processors, (i) a user context of the user as the user provides the one or more system inputs as information related to the privacy campaign and (ii) one or more system inputs from the user, the one or more system inputs comprising one or more submitted inputs and one or more unsubmitted inputs, wherein actively monitoring the user context and the one or more system inputs comprises recording a first user input provided within a graphical user interface that occurs prior to submission of the one or more system inputs by the user, and recording a second user input provided within the graphical user interface that occurs after the user inputs the first user input and before the user submits the one or more system input; (B) storing, in computer memory, by one or more processors, an electronic record of user context of the user and the one or more system inputs from the user; (C) analyzing, by one or more processors, at least one item of information selected from a group consisting of (i) the user context and (ii) the one or more system inputs from the user to determine whether abnormal user behavior occurred in providing the one or more system inputs, wherein determining whether the abnormal user behavior occurred in providing the one or more system inputs comprises comparing the first user input with the second user input to determine one or more differences between the one or more submitted inputs and the one or more unsubmitted inputs, wherein the first user input is an unsubmitted input and the second user input is a submitted input; and (D) at least partially in response to determining that abnormal user behavior occurred in providing the one or more system inputs, automatically flagging, in memory, at least a portion of the provided one or more system inputs in which the abnormal user behavior occurred.

“A computer-implemented data processing method for monitoring a user as the user provides one or more system inputs as input of information related to a privacy campaign, in various embodiments, comprises: (A) actively monitoring, by one or more processors, a user context of the user as the user provides the one or more system inputs, the one or more system inputs comprising one or more submitted inputs and one or more unsubmitted inputs, wherein actively monitoring the user context of the user as the user provides the one more system inputs comprises recording a first user input provided within a graphical user interface that occurs prior to submission of the one or more system inputs by the user, and recording a second user input provided within the graphical user interface that occurs after the user provides the first user input and before the user submits the one or more system inputs, wherein the user context comprises at least one user factor selected from a group consisting of: (i) an amount of time the user takes to provide the one or more system inputs, (ii) a deadline associated with providing the one or more system inputs, (iii) a location of the user as the user provides the one or more system inputs; and (iv) one or more electronic activities associated with an electronic device on which the user is providing the one or more system inputs; (B) storing, in computer memory, by one or more processors, an electronic record of the user context of the user; (C) analyzing, by one or more processors, the user context, based at least in part on the at least one user factor, to determine whether abnormal user behavior occurred in providing the one or more system inputs, wherein determining whether the abnormal user behavior occurred in providing the one or more system inputs comprises comparing the first user input with the second user input to determine one or more differences between the first user input and the second user input, wherein the first user input is an unsubmitted input and the second user input is a submitted input; and (D) at least partially in response to determining that abnormal user behavior occurred in providing the one or more system inputs, automatically flagging, in memory, at least a portion of the provided one or more system inputs in which the abnormal user behavior occurred.

“A computer-implemented data processing method for scanning one or more webpages to determine vendor risk, in various embodiments, comprises: (A) scanning, by one or more processors, one or more webpages associated with a vendor; (B) identifying, by one or more processors, one or more vendor attributes based on the scan; (C) calculating a vendor risk score based at least in part on the one or more vendor attributes; and (D) taking one or more automated actions based on the vendor risk rating.

“A computer-implemented data processing method for generating an incident notification for a vendor, according to particular embodiments, comprises: receiving, by one or more processors, an indication of a particular incident; determining, by one or more processors based on the indication of the particular incident, one or more attributes of the particular incident; determining, by one or more processors based on the one or more attributes of the particular incident, a vendor associated with the particular incident; determining, by one or more processors based on the vendor associated with the particular incident, a notification obligation for the vendor associated with the particular incident; generating, by one or more processors in response to determining the notification obligation, a task associated with satisfying the notification obligation; presenting, by one or more processors on a graphical user interface, an indication of the task associated with satisfying the notification obligation; detecting, by one or more processors on a graphical user interface, a selection of the indication of the task associated with satisfying the notification obligation; and presenting, by one or more processors on a graphical user interface, detailed information associated with the task associated with satisfying the notification obligation.”

The claims supplied by the inventors are:

“1. A method comprising: receiving, by computing hardware, information for a data breach incident, wherein the information identifies an affected jurisdiction; generating, by the computing hardware, a questionnaire comprising a plurality of questions, wherein the plurality of questions included in the questionnaire is based on an ontology comprising a mapping of the plurality of questions to a plurality of activities to address the data breach incident; causing, by the computing hardware, a request for an answer to each of the plurality of questions in the questionnaire from a user; receiving, by the computing hardware, information indicating respective answers to each of the plurality of questions in the questionnaire originating from the user; determining, by the computing hardware and based on the respective answers to the plurality of questions, a plurality of required activities to address the data breach incident for the affected jurisdiction, wherein the plurality of required activities is a subset of the plurality of activities from the ontology to address the data breach incident; generating, by the computing hardware, a graphical user interface by configuring a mechanism for each of the plurality of required activities, wherein the mechanism is configured so that an indication can be provided for a corresponding required activity of the plurality of required activities; providing, by the computing hardware, the graphical user interface for display on a computing device to a user; receiving, by the computing hardware, the indication via the mechanism for at least one of the plurality of required activities, wherein the indication corresponds to a progress of completion of the at least one of the plurality of required activities; and responsive to receiving the indication: generating, by the computing hardware, data breach response data identifying the progress of completion of the at least one of the plurality of required activities; and customizing, by the computing hardware, the graphical user interface based on the data breach response data by: configuring the graphical user interface to display at least one of (i) a readiness indicator representing a readiness of an entity to address the data breach incident for the affected jurisdiction or (ii) a plurality of comparison readiness indicators in which each comparison readiness indicator of the plurality of comparison readiness indicators represents a readiness of a different entity to address the data breach incident for the affected jurisdiction and a relative ranking of each comparison readiness indicator of the plurality of comparison readiness indicators and the readiness indicator of the entity.

“2. The method of claim 1, wherein customizing the graphical user interface comprises reconfiguring the mechanism for at least one of the plurality of required activities based on the data breach response data.

“3. The method of claim 1, wherein the data breach response data indicates an urgency of addressing the data breach incident for the affected jurisdiction.

“4. The method of claim 3, wherein: the information further identifies a second affected jurisdiction, generating the graphical user interface is performed by configuring a second mechanism for each of a plurality of second required activities identified based on the information as a requirement for addressing the data breach incident in the second affected jurisdiction, the second mechanism being configured so that a second indication can be provided for a corresponding second required activity of the plurality of second required activities, and the method further comprises: receiving the second indication via the second mechanism for at least one of the plurality of second required activities, wherein the second indication corresponds to a progress of completion of the at least one of the plurality of second required activities; and responsive to receiving the second indication: generating, by the computing hardware, second data breach response data based on the progress of completion of the at least one of the plurality of second required activities, wherein the second data breach response data indicates an urgency of addressing the data breach incident for the second affected jurisdiction; and customizing, by the computing hardware, the graphical user interface based on the second data breach response data, wherein the graphical user interface is customized to display the urgency of addressing the data breach incident for the second affected jurisdiction is higher than the urgency of addressing the data breach incident for the first affected jurisdiction.

“5. The method of claim 1, wherein the data breach response data comprises at least one of an order in which the plurality of required activities were completed, whether a relevant deadline for completion of at least one required activity of the plurality of required activities was met, a number of the plurality of required activities that were completed, or whether at least one required activity of the plurality of required activities was performed properly.

“6. A system comprising: a non-transitory computer-readable medium storing instructions; and a processing device communicatively coupled to the non-transitory computer-readable medium, wherein, the processing device is configured to execute the instructions and thereby perform operations comprising: generating a questionnaire comprising a plurality of questions, wherein the plurality of questions is included in the questionnaire based on an ontology mapping the plurality of questions to a plurality of activities to address a data breach incident; causing a request for an answer to each of the plurality of questions in the questionnaire from a user; receiving information indicating respective answers originating from the user to each of the plurality of questions in the questionnaire; determining, based on the respective answers, a plurality of required activities to address the data breach incident for an affected jurisdiction, wherein the plurality of required activities is a subset of the plurality of activities from the ontology to address the data breach incident; generating a graphical user interface by configuring a mechanism for each of the plurality of required activities, wherein the mechanism is configured so that an indication can be provided for a corresponding required activity of the plurality of required activities, and the graphical user interface is provided for display on a computing device; receiving the indication via the mechanism for at least one of the plurality of required activities, wherein the indication corresponds to a progress of completion of the at least one of the plurality of required activities; and responsive to receiving the indication: generating data breach response data based on the indication identifying the progress of completion of the at least one of the plurality of required activities; and customizing the graphical user interface based on the data breach response data by: configuring the graphical user interface to display at least one of (i) a readiness indicator representing a readiness of an entity to address the data breach incident for the affected jurisdiction or (ii) a plurality of comparison readiness indicators in which each comparison readiness indicator of the plurality of comparison readiness indicators represents a readiness of a different entity to address the data breach incident for the affected jurisdiction and a relative ranking of each comparison readiness indicator of the plurality of comparison readiness indicator and the readiness indicator of the entity.

“7. The system of claim 6, wherein customizing the graphical user interface comprises reconfiguring the mechanism for at least one of the plurality of required activities based on the data breach response data.

“8. The system of claim 6, wherein the data breach response data indicates an urgency of addressing the data breach incident for the affected jurisdiction.

“9. The system of claim 8, wherein: the information further identifies a second affected jurisdiction, the operation for generating the graphical user interface comprises configuring a second mechanism for each of a plurality of second required activities identified based on the information as a requirement for addressing the data breach incident in the second affected jurisdiction, the second mechanism being configured so that a second indication can be provided for a corresponding second required activity of the plurality of second required activities, and the operations further comprises: receiving the second indication via the second mechanism for at least one of the plurality of second required activities, wherein the second indication corresponds to a progress of completion of the at least one of the plurality of second required activities; and responsive to receiving the second indication: generating second data breach response data based on the progress of completion of the at least one of the plurality of second required activities, wherein the second data breach response data indicates an urgency of addressing the data breach incident for the second affected jurisdiction; and customizing the graphical user interface based on the second data breach response data, wherein the graphical user interface is customized to display the urgency of addressing the data breach incident for the second affected jurisdiction is higher than the urgency of addressing the data breach incident for the first affected jurisdiction.”

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For more information, see this patent: Brannon, Jonathan Blake. Data processing systems for assessing readiness for responding to privacy-related incidents. U.S. Patent Number 11328240, filed August 20, 2021, and published online on May 10, 2022. Patent URL: http://patft.uspto.gov/netacgi/nph-Parser?Sect1=PTO1&Sect2=HITOFF&d=PALL&p=1&u=%2Fnetahtml%2FPTO%2Fsrchnum.htm&r=1&f=G&l=50&s1=11328240.PN.&OS=PN/11328240RS=PN/11328240

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