A GDPR International Transfer Compliance Framework Based on an Extended Data Privacy Vocabulary (DPV)

Abstract

This paper describes a tool using an extended Data Privacy Vocabulary (the DPV) to audit and monitor GDPR compliance of international transfers of personal data. New terms were identified which have been proposed as extensions to the DPV W3C Working Group. A prototype software tool was built based on the model plus a set of validation rules, and synthetic use-cases created to test the capabilities of the model and tool (together a compliance framework). This framework was created because the rules around international transfer compliance are complex and changing, there is an absence of a common approach to ensuring compliance, few tools exist to assist, and those that do lack interoperability. Evaluation results demonstrate that the proposed model improves compliance identification and standardisation. The tool received positive feedback from the data protection practitioners who participated in the evaluation, and an initial version of is now in use in one financial services organisation. While currently the tool only addresses international transfers, in theory the framework can be extended through further work to the broader area of compliance of other aspects of the GPDR.