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Data Mapping

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Vinesh Nair August 21, 2020

X-Way Tech is a large communications and technology company. It has offices in 3 cities around south east Asia, Kuala Lumpur (HQ), Singapore and Manila. It has grown over the past 7 years into one of the strongest companies in its field.

As a primary service it offers mobile network and data services used primarily in phones but also in other devices such as tablets, cars etc. Its second biggest offering is the service of GPS tracking for corporations who require the tracking of staff, vehicles or packages. This is common for logistics companies, food delivery services, transport services etc.

Having recognized the important role of privacy in the company, the C-level management has formed a privacy team that consists representatives from the following 5 departments of the company:

Human Resources

This is the department responsible for handling all affairs relating to employees which include onboarding new employees, monitoring employee performance, payment of salaries and bonuses, managing complaints and employee misconducts etc.

Customer Service and Engagement

Customer Service deals with existing customers and helps them deal with their concerns and complaints when using the company’s products/services. In addition, this department also follows up on customer satisfaction by keeping in regular contact with each customer through emails, newsletters, phone calls etc.


The marketing department is responsible for getting new customers in. This often aggressive department is required to collect information from various sources on potential customers and develop marketing plans and strategies. They may engage indirectly with customers through advertisements etc, or through direct engagement i.e. cold calls, targeted marketing campaigns etc.

Verification Department

This department’s role is to verify individual customers (individuals and companies) by conducting background checks on them to avoid dealing with ‘blacklisted’ customers. These searches include bankruptcy searches, bad credit ratings, criminal records, legal cases pending etc.   

Vendor & Contractor management

This department deals with all third-party services. They go through a background check of each vendor or contractor, manage the information provided to them to do their job and ensure the job is completed. Vendors and contractors can be companies or individuals. A lot of the contractor work for X-way Tech is for analytics work.

This privacy team’s main aim is to map the data of the company. To do this, complete the following tasks in sequence:-

  1. Identify what kind of data each department may have and may be using.
  2. Build an Excel sheet of the types of data and classify that data.
  3. Begin the mapping process.
    • Entry point
    • Movement
    • Access
    • Exit
  4. Create a risk assessment of the data after it is mapped.