GDPR, Anonymization of Customer Data

In accordance with the directives for GDPRClosed The General Data Protection Regulation is a regulation in EU law on data protection and privacy in European Union and European Economic Area., individual customers' data privacy has to be protected. Data Governance is the process that classifies sensitive data and anonymizes it on request for data protection regulations.

NOTE  
Based on our experience, FintechOS selected which information to be anonymize. The financial institution can validate or add/remove attributes from the anonymization process within Innovation Studio.

There are two scenarios when the data can be anonymized:

  1. Automatically

    After 5 years (not counting the year of closure) from the contractual relationship between a customer and a bank has ended. Certain data is automatically anonymized by the system.

  2. Manually

    Upon user request, the bank can manually select a customer for which the data to be anonymized.

The types of information that are anonymized are username and password and:

Session information and activity within the Online and Mobile Banking solution:

session information
IP
login time
logout time
used functionalities during the session
 

Personal data about their identity and contact information:

Entity containing the data of the users' enrollment process

Primary key
name
system user ID
user name
name
middle name
last name
personal ID number
customer ID CoreBanking
document number
email address
mobile phone number

Entity containing the users' data

name
full name
name
middle name
last name
personal ID number
Customer ID CoreBanking
document number
system user ID
unique identifier
email address
mobile phone number

Entity containing the users and customers' data

name
system user ID
client ID
accounts
 

Products, services and transactions including communication between the customer and bank.

 

Entity containing the mailbox received messages

customer
user ID

 

Entity containing the mailbox sent messages

 

attachments
customer

 

 

 

 

 

 

 

 

Entity containing the payments' data

 

 

 

 

 

 

payer first name
payer middle name
payer last name
payer account
payer address
payer postcode
beneficiary name
beneficiary IBAN account
payment reason
name
transaction Id
ultimate payer
ultimate payer ID
ultimate beneficiary
purpose of payment

 

 

Entity containing the payment extension

 

first authorizer user ID 
second authorizer user ID 
third authorizer user ID 
fourth authorizer user ID 

Entity containing the foreign currency payment extension

Primary key
account number
beneficiary address
beneficiary post code
payment attachments

Entity containing the budget payment extension

obligated party payer 
companyId obligated party 
personId obligated party 
personId obligated party foreigner 
document number
document date 

Entity containing the utility payment contracts

Primary key
name
user
customer Id

Entity containing the utility services

name
utility payment service parent Id

Entity containing the utility transactions

name
utility payment contractid
user X TransactionType id
transaction ID
payment details

Entity containing the payments templates

Primary key
template friendly name
schema type
currency
visible all users
payer account
beneficiary name
beneficiary IBAN account
payment amount
payment currency
payment reason
payment type
name
payment category
beneficiary address
details of charges
settlement date
obligated party payer 
company Id obligated party 
person Id obligated party 
person Id obligated party foreigner 
budget type payer 
budget type code 
budget type description 
document type
document number
document date 

 

Entity containing the data about bulk files

Primary key
bulk file name

Entity containing the users and bank account data

alias

Entity containing the bank account data

IBAN
available balance
reason for the blocked amount
blocked amount

currency

balance
loan number
 

The anonymization is done based on a rule. Both requests manually and automatically, anonymize the data that have the status Inactive. Manually, the bank representative searches for the user or customer or automatically, the system anonymizes all the records which meet the rule.

IMPORTANT!  
All the records, which will be anonymized, must be in the Inactive state first before anonymization.

Prerequisites

You need an administrator role to perform this action. Additionally, before creating the request, you need to disassociate the users from the customer. Then, you must inactivate the users.

To inactivate a user, two flows are in place. The maker must:

  1. Open the FintechOS Portal.
  2. Click the button Search Users.
  3. Type a value in one of the columns: User name, first name, last name, mobile phone number, email address, personal ID number, Core Banking Unique Id, System User Id.
  4. Select the user needed for the modification from the grid.
  5. On the page Edit IB User, in the grid Associated Customers, select the customer. The User Client List page is displayed.
  6. In the grid Current Modifications List, select the active user by clicking once on the entry in the grid.
  7. Click Inactive.

    IMPORTANT!  
    You cannot inactivate a user from the grid Active settings (before current modifications). A toast message is displayed. Firstly, click Rest the modifications or Activate & Approve, then turn the user inactive.

    The record is saved automatically. The user is displayed in the grid Current Modifications List with the business status To Be Inactivated.

From here, it is the checker who finishes the inactivation.

The checker must:

  1. Log in the FintechOS Portal with the given credentials.
  2. From the grid Requests sent for Approval, double-click the record with the business status To Be Inactivated. The User Client List opens.
  3. Click the Pick Up button. The page reloads.
  4. Click Approve & Activate. The business status is Inactive.

Creating a Sensitive Request and Approving the Records Manually

The following process is done by a back-office employee from the bank:

  1. Log into FintechOS Portal with the credentials given.
  2. Open the main menu, and select Data Anonymization Requests. The Sensitive Requests List is displayed.
  3. Click Insert.
  4. Fill in the following fields:
    FieldDescription
    Request NoInsert a suggestive number.
    Request DateThe system automatically displays the current date.
    Sensitive Context

    Select one from the list:

    • GDPR Account (affects data from more entities)

      The attributes are CNP, Name, Phone, First Name, Last Name, entityStatusID.

    • GDPR User.
    NOTE  
    Two requests must be made, one with each of the contexts above for the anonymization to be complete.
  5. Click Save and reload. The Request Search Attributes grid is displayed. It is time to choose a customer who has those attributes active.

  6. In the grid, in the column named Search Value, insert the corresponding CNP of the customer you are trying to anonymize.

  7. Click Save and reload. The request was created.
  8. On the top right-hand corner, in the Business Workflow widget, the status is Register. Change the status to Requested by clicking on Choose status, and then on Requested from the drop-down.
  9. The system asks you: Are you sure you want to change the business status?

    Click Yes to continue. The data to be anonymized is populated.

    or

    Click No to stop the process.

  10. Click in the section tab Data Found. The Request Entities grid is displayed, it showcases the customer.
  11. On the top right-hand corner, in the Business Workflow widget, the status is Requested. Change the status to Validated by clicking on Validated.

    If the Rule is Approved, then:

  12. The system asks you: Are you sure you want to change the business status?
    • Click Yes to continue. The rule is triggered and the status is Solved.

      or

    • Click No to stop the process.
  13. Click the section tab Data found.
  14. Click on the customer found.
  15. In the page Edit Request Entity, the fields become read-only, and the Request Data Rules grid displays the outcome of the rule in the Message field:
    • success

      It has the status pending approval.

      or

    • fail.
  16. On the top right-hand corner, in the Business Workflow widget, the status is Pending Approval. Change the status to Approved or Rejected by clicking Choose status, and then on Approved from the drop-down if the configuration is as needed.
  17. Click Save and reload. In the Data Found section tab, the Business Status is Anonymized.

  18. If the Rule is Rejected, then:

    The system displays the message: Are you sure you want to change the business status?
    • Click Yes to continue. The rule is triggered and the status is Solved.

      or

    • Click No to stop the process.

    In the page Edit Request Entity, the fields become read-only, and the Request Data Rules grid displays the outcome of the rule:

    • success

      or

    • fail.

      The status is Rule Rejected.

  19. On the top right-hand corner, in the Business Workflow widget, the status is Rule Rejected. Change the status to Approved or Rejected by clicking on Pending Approval, and then on Approved from the drop-down if the configuration is as needed.

For more information, see Data Governance.