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GDPR request log template

A template log for requests from people about their personal data in an Exponential store - one line per request, with dates, the kind of request, the data found, what was done and the proof - plus how to keep the log…

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Address: https://doc.exponential.earth/exphelp/viewer/help/customers/commerce/gdpr-request-log-template.md

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GDPR request log template

This page is a template for the person who answers privacy requests. Keeping a log of every request, and what was done about it, lets you show later that requests were handled. The routine that fills the log is on GDPR requests.

Warning

Template, not legal advice. What you must record, and for how long, is for your lawyer or data protection officer to decide. Adapt the columns to their advice.

How to keep the log

  • Keep it where only the people who handle requests can read it, not in a shared folder for the whole team.
  • Record what you did, not more personal data than you need: a reference to the person is often enough. Ask your adviser what reference to use.
  • Do not paste exported data into the log. Exports are deleted when the request is closed (Data retention and deletion).
  • Review the log when you review your privacy notice, at least once a year.

The log

GDPR REQUEST LOG - [organization]                 Owner of this log: [role]

No. | Received   | Channel  | Kind of request            | Identity confirmed (how, when) | Due (per adviser)
----|------------|----------|----------------------------|--------------------------------|------------------
1   |            |          | access / correction /      |                                |
    |            |          | export / erasure / object  |                                |

No. | Data found (tick)                                              | Decision (by whom)
----|----------------------------------------------------------------|-------------------
1   | [ ] user account   [ ] orders        [ ] form submissions      |
    | [ ] mail prefs     [ ] newsletter    [ ] other: ______         |

No. | Action taken                         | Tool used                       | Done on | By
----|--------------------------------------|---------------------------------|---------|----
1   |                                      |                                 |         |

No. | Answer sent on | Export files deleted on | Kept, and why (e.g. bookkeeping rule) | Closed on
----|----------------|-------------------------|----------------------------------------|----------
1   |                |                         |                                        |

The tools column

Name the tool in the log, so the next person can repeat the step. The tools the software offers, from GDPR requests and Compliance and GDPR:

DataTool to name in the log
Mail preferences and consentexp:mail:preferences export or erase; the person's own download
Marketing objectionexp:mail:suppression add, or the person's own unsubscribe link
Audit records about a userexp:audit export --subject-user=<id>
User accountRemoval in Users (final)
Form submissionsSetup > Collected information
OrdersStore > Customers, customer order view; shop/archiveorder or shop/removeorder
Newsletter subscribersThe cjw_newsletter administration
BackupsYour host, under your agreement

The shape of one entry

One entry in plain text, with the field names in square brackets. Keep entries free of more personal data than the request itself needs.

No. [number] | Received [date] | [channel] | [kind of request] | identity confirmed [how, date] | due [date per adviser]
Data found: [which of the places above hold data about the person]
Decision: [what is erased, exported or kept, and why] ([who decided], [date])
Action: [commands and admin pages used] | [date] | [who did it]
Answer sent [date] | [export files, if any] | [what is kept, and the rule for keeping it] | closed [date]

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Documentation license

This documentation is free documentation, licensed under the GNU Free Documentation License 1.3 or later.

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