Industry: Retail and Manufacturing
Region: International
Company size: Enterprise
Featured solutions: Data Mapping Automation, Targeted Data Discovery, Assessment Automation, Cookie Consent, Privacy Rights Automation, PIA & DPIA Automation
Alfred Kärcher
Alfred Kärcher builds a data protection strategy that scales beyond geographical borders
Alfred Kärcher achieves global impact and compliance with automated data management
Overview
When Michael Apperger became the Data Protection Officer (DPO) at Alfred Kärcher SE & Co. KG in 2019, the record of processing activities was kept in an Excel spreadsheet.
As a world market leader in cleaning equipment and solutions, Kärcher has more than 150 subsidiaries across 80 countries. It’s founded and headquartered in Germany, where Apperger serves as DPO for the parent company as well as five other subsidiaries in the country.
Being at Kärcher for 25 years made Apperger a perfect fit to be its DPO. Not only was he already familiar with operations, his previous experience in the IT department also equipped him to automate and streamline its data protection process.
Today, Kärcher maintains a reliable record of processing activities built around OneTrust and an automated system that makes it easier to stay compliant with data privacy laws.
Rethinking the role of data protection
From the moment Apperger opened the first Excel sheet full of data processing activities, he set a goal to overhaul the entire process.
“My colleague filled out the sheet himself. Yes, he had discussions with the process owner, but he was the one who wrote the descriptions,” he says. “In my opinion, if I don’t live the process, I can’t describe the process. I need the process owner to describe the process.”
Apperger searched for a solution that could facilitate the data processing activities at scale, from sending custom-built templates directly to designated process owners to maintaining an updated data inventory.
OneTrust was the obvious choice. “At that time, the other tools were only able to document the processing activities. OneTrust was the only one that could do that, and also help with GDPR compliance, privacy laws, data discovery, and automation,” he says. “After analyzing the options, I decided that OneTrust is the tool for Alfred Kärcher and its subsidiaries.”
"I have 25 years experience at Kärcher, but even I don’t know what every department does. From time to time, we still find processing activities that need to be described and added to OneTrust."
Michael Apperger, Data Protection Officer (DPO) at Alfred Kärcher SE & Co. KG
Accelerating adoption with faster forms
Apperger spent the first year rebuilding Kärcher’s record of data processing activities using two OneTrust modules: PIA and DPIA Automation and Data Mapping Automation. These modules work together to integrate assessment templates into existing systems and provide a real-time, comprehensive view into the organization’s data respectively.
The first batch of PIA and DPIA forms, however, revealed a missing piece in the plan. “We asked the correct questions, but the answers from the process owners were not really good because they didn’t have the depth of understanding about GDPR,” says Apperger.
With data processing activities carried out across the entire company, from sales and marketing to human resources, the forms had to address a broad audience.
“We made them shorter,” he says. “We only included the basics, about 20 questions. And every email we send with the form also includes a short overview of how OneTrust works and what can be done with the tool.”
Once the answers are submitted and reviewed, Apperger then meets with the process owner for further discussion before giving final approval. The form is sent to process owners periodically for review of processing activities.
Investing in internal documentation
In addition to simplifying forms, Apperger was looking for ways to communicate the importance of data protection and data security. He wanted to raise awareness of the GDPR and data protection laws. He also wanted to make the information more appealing to his colleagues. A better understanding leads to a smoother process.
"Every day we get a new question about the GDPR: Is this image personal data? Is this information personal data?" says Apperger. "It's all new language for the company. We have documented how we implement data protection at Kärcher in a data protection manual."
To further raise awareness of data protection in the company, Kärcher published a quarterly newsletter on general data protection topics, current information from the supervisory authorities, and data protection topics.
With this additional guidance, Apperger and his team were able to build a data protection strategy that scales beyond geographical borders. As new laws and regulations are enforced, and data transfer guidelines change, it’s critical for a company to stay in control of its data.
“This is a benefit of OneTrust — we can create custom fields and use them as a filter to see which processing activities we need to change when any given regulation changes,” says Apperger.
Expanding a global data protection process
Once his data protection strategy was in place, Apperger began personally introducing OneTrust to the other DPOs at Kärcher. He created another handbook to explain the different modules that help maintain data processing activities and ensure GDPR compliance.
From there, integrating the solution was easy. “Subsidiaries use many of the same processes we use, so most of the time, it’s just copy-paste,” he says. For example, Kärcher’s online recruitment process is the same for all countries. Since the process is already documented in OneTrust, it can be copied and immediately applied to any other location.
The challenge, however, was addressing the number of customer data inquiries received by subsidiaries. Kärcher’s subsidiaries operate as sales arms in their respective country, which makes them the primary channel for customers to request access, correction, or deletion of their data — a process easier said than done.
Every request requires verifying the legitimacy of the request, locating the data across disparate systems (including any third parties), determining any data exemptions, and documenting any changes.
“This required a mindset change and a solution,” he says. Apperger and his team utilized the OneTrust Privacy Rights Automation and Data Discovery modules to facilitate these customer data requests. By automatically scanning every data environment, down to the field and file level, he was able to streamline the end-to-end process — from intake to discovery to taking action — on a single platform.
Looking forward to greater data governance
Today, OneTrust is the backbone of Kärcher’s data protection strategy. “It gave us an overview of all the company’s processing activities and helped our colleagues understand the GDPR,” says Apperger.
“I think the process we have is really good at this time. In the future, we look to connect our processing activities to see how data is created and flows through the company. This is something we can do very easily in OneTrust.”
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