- PIA & DPIA Automation
- Cookie Compliance
- Data Mapping Automation
- Universal Consent and Preference Management
- OneTrust DataGuidance
VFS Global’s Journey to Implementing a Custom Privacy Program with the Full OneTrust Platform
VFS Global is the world’s largest travel visa outsourcing and technology services specialist for governments and diplomatic missions worldwide. It provides visa facilitation application services to 64 client governments in 144 countries worldwide. Processing millions of visa applications a year, privacy is a core competent of VFS Global’s business allowing the company to build trust between their client governments as well as the customers applying for a visa.
Centralized Management for a Global Operation
Barry Cook, Privacy and Group Data Protection Officer at VFS Global, leads a team covering the global privacy and data protection function of the business. As the company operations involve the processing of personal data and are geographically very diverse Barry found a need for a centralized tool that allowed him to manage the local requirements of the 144 countries in which they operate. Barry and his team also needed a solution that could cut back on the manual work of assessments, reports and research, whilst increasing their ability to demonstrate accountability.
OneTrust accounts for between two to three additional staff, and it’s a very good ROI.Barry CookPrivacy and Group Data Protection Officer
Passport to Privacy with the Full OneTrust Platform
When looking at the tools available on the market, one thing that made OneTrust stand out was that it was heavily focused on operationalizing a privacy program, rather than solely offering legal assistance and templates. This value has rippled throughout VFS Global’s’ privacy program and has provided Barry with the centralized management point that he needed.
VFS Global approached using the Assessment Automation module by starting from an activity-based aspect, with the record of processing activities driving their whole process. With the record of processing activities at the heart of their process, VFS Global uses Assessment Automation to make judgment calls and better understand what is needed, whether that be a DPIA, vendor assessment, or Privacy by Design checklist.
Barry and his team have been able to customize this module by adding logic decisions and rules to launch other assessments, and this ability to adapt the tool to their needs has been a considerable benefit. “Out of the box OneTrust is very good, but a huge part of its appeal is the ability to customize,” said Barry.
The fact that all the modules are closely interlinked and that attributes can so easily be shared has helped VFS Global better understand and utilize the data that they’re working with. Through the entity inventory element of the Data Mapping module, VFS Global is able to streamline even more of their processes, as they can handle other aspects that are associated with the mapped entities. The way that the Data Mapping modules feeds into the Assessment Automation modules helps add clarity to the overall understanding of their privacy program.
“The interconnecting modules are very good, it’s very easy to share attributes between different tools and use the data that is in seemingly unconnected modules, bringing them together and give more holistic picture of the privacy landscape,” said Barry.
The Data Subject Access Requests module has reduced the time that it takes to respond to requests whilst also providing a clearer workflow. This increased efficiency means that the internal process is much more transparent and from a consumer perspective the requests are actioned much more quickly.
VFS Global operates a huge number of websites, each with individual functions, so without the Cookie Consent tool VFS Global would find the management almost impossible to manage the cookie banners. The Cookie Consent tool offers the capability to create bundles and interact with the privacy notice management module, and the templates that Barry and his team have created allow the web development team to implement the scripts and banners themselves, knowing that the content is compliant.
Developing test scripts for the UAT and test sites has been very useful for VFS Global, and the ability to create a script for a UAT/Test site enables website teams to fully test functionality before going live.
Competitive Privacy as a Fast-Pass to Success
Accountability is an important part of any privacy program and when presenting to a government client the first question VFS Global is asked is, “Have you done a DPIA?” Thanks to OneTrust, they can promptly present a neat report, made particularly accessible by the user-friendly dashboard. This allows VFS Global to demonstrate their proactiveness and action privacy as a competitive differentiator. Privacy used to be a compliance, tick box style task, but now it has become a very active and significant part of VFS Global’s strategy.
This transparency also plays a vital role in improving the clarity of the privacy program with the business, the senior leadership team are able to utilize the OneTrust dashboard to gain a better understanding of how the processes look in practice, and have that information available almost instantly rather than having to search through spreadsheets.
OneTrust enables globalization to be managed by a central component, and also allows for the fine detail of local management.Barry CookPrivacy and Group Data Protection Officer
A Stamp of Approval for the OneTrust Privacy Platform
Prior to implementing OneTrust, all of VFS Global’s operations were very manual, heavily relying on spreadsheets and email, this was a key area in which efficiency was being lost. OneTrust has enabled Barry to reduce the overhead and time that it actually takes to perform particular tasks. In reflecting on a return on investment, the benefit to VFS Global is clear, with the ease of integration with other platforms greatly enhancing the platform’s value, Barry can justify the cost involved and operate with smaller team.
“OneTrust accounts for between two to three additional staff, and it’s a very good ROI,” said Barry.
The Sky is the Limit for Privacy Program Development
An exciting part about using OneTrust is seeing how they adapt to keep up with and often pre-empt the industry needs. With OneTrust Athena AI and robotic process automation, the ability to customize and enhance the VFS privacy program is even more tangible.
OneTrust has helped bring unity to VFS Global’s privacy program and has made privacy feel more accessible. A continuing focus for VFS Global will be building on their culture of privacy with Awareness Training. “The Awareness Training courses have a very modern, upbeat feel about them, people like to do them. You don’t often hear that being said within a company that they actually enjoyed doing the mandatory training. They are really first-class courses,” said Barry
With operations across 144 countries, a key focus for VFS Global is always keeping on top of localization requirements as they come up and knowing that they can rely on DataGuidance as a source of news and guidance puts Barry and his team in a confident position when it comes to updating their processes. This knowledge can easily be actioned by amending their automated workflows and assessments, and as all of this fine detail is centralized in one dashboard, large-scale updates across multiple jurisdictions aren’t the daunting task that they once were. “OneTrust enables globalization to be managed by a central component, and also allows for the fine detail of local management,” said Barry.
Read this case study for more insight into how VFS Global leverage OneTrust DataGuidance.