Transfers and Contextual Relationships: Feature Guide

Example (1): OneTrust (Legal Entity) sends data to Zentoso (Vendor) for the purpose of Payroll.

Source

: The originating point of a relationship. Used to help identify the directionality of the relationship (where relevant). In the above example OneTrust is the Source. Note how the source has a type (Legal Entity) to help you understand what type of object is being related.

Target

: The ending point of a relationship. Used to help identify the directionality of the relationship (where relevant). In the above example Zentoso is the Target. The Target is a vendor-type inventory record.

Relationship Type

: The relationship type provides context on the nature of the relationship between the Source and Target. In the example above, the relationship type would be Data Transfer. Each relationship type has its own set of attributes that can be independently configured.

Label

: Each relationship type has two labels—a source-to-target (or “forward”) label and a target-to-source (or “backward”) label.

Using the above example, the relationship type of Transfer has the following labels:

Relationship	Relationship Type	Label	Description
Source-To-Target (forward)	Transfer	“sends data to”	OneTrust sends data to Zentoso
Target-To-Source (backward)	Transfer	“receives data from”	Zentoso receives data from OneTrust

Note:

These are the same relationship, but expressed in two different ways. Most of the time, you will see the forward label, but there are a few instances where the backwards label may be used instead.

Business Context (Context Processing Activity)

: This field is optional, but important when you want to outline the purpose of a relationship. In the above example, we designate Payroll (a processing activity) as the reason for the transfer between OneTrust and Zentoso. Note that the Business Context can only be a processing activity.

Note:

Source, Link Type, and Target are not editable fields, however the Context Processing Activity may be updated.

If the context process is updated so that it matches another record, the update will register as a duplicate and fail.

Attributes

: Each relationship can have additional attributes to capture more context about the record. The attribute schema is independently defined for each relationship type.

For more information on attributes, see Adding, Editing, and Deactivating Relationship Attributes.

You can see the available contextual relationships, defined labels, and valid source/target pairs in About Inventory Linking and Relationships.

Uniqueness of a relationship is defined by the combination of Source, Target, Relationship Type, and Business Process.

If record OneTrust sends data to Zentoso already exists:

Example 1

"Zentoso sends data to OneTrust" would create a new record.

Example 2

“OneTrust sends data to ABC Vendor” would create a new record.

Example 3

“OneTrust is a controller of Zentoso” would create a new record.

Example 4

“OneTrust sends data to Zentoso for the purpose of Onboarding” would create a new record.

Manual configuration

: Capture relationships manually on the newRelatedtab. For more information, seeCreating and Managing Contextual Relationships.

Important:

This functionality and interface is new and is specifically designed for the new Related tab and Enhanced Contextual Inventory Relationships feature.

Import

: Leverage bulk import templates to create and update relationships. For more information, seeBulk Importing Inventory RelationshipsandBulk Updating Inventory Relationships.

Important:

This functionality is new and is specific to the new Related tab and Enhanced Contextual Inventory Relationships feature.

Assessments

: New relationship question type to capture relationship details through assessments. All information will be inherited and displayed on the inventory related tab when the assessment is approved. For more information, seeAdding, Editing, Reordering, and Deleting Questions .

Important:

The existing functionality to link inventory questions together still works and is available today; however, if you need to capture attributes or personal data against a relationship through an assessment, you will need to use the new relationship question type.

Convert existing data

: Leverage the Potential Transfers functionality on the cross-border map to convert assumed transfers between assets to actual transfers object. For more information, seeVisualizing Cross-Border Data Transfers.

Additional Functionality

• Add risks to the relationship or select risks from the Risk Library using the Risk tab on the Relationship Details screen.

• Add any applicable controls to the relationship.

• Add attachments to your relationships.

• Visualize all relationships on the improved cross-border map which now shows all relationship types and includes relationships between assets, legal entities and vendors. For more information, see Visualizing Cross-Border Data Transfers.

• Visualize relationships using the new data graph visual on the Related tab.

• Leverage improved related inventory reporting.

• Include relationships and relationship details in column and PDF reports.

• Enhanced reports when export your inventory data to Excel.

  Important:

  This functionality is new and is specific to the new Related tab and Enhanced Contextual Inventory Relationships feature.

Background

Attention:

This article is not legal advice. Please consult with your privacy legal experts for more detail.

As part of the Schrems II ruling, the European Data Protection Board (EDPB) published additional guidance on how to manage transfers. The full guidance can be found on EDPB’s website.

Contextual relationships can help your organization complete each of the recommended steps of the EDPB 6 steps for data transfer management.

Vendor-to-Vendor Subprocessor

Due to the nature of the upgrade, there are some ambiguous scenarios for the upgrade that require admin review.

Current relationship structure: Vendor 1 ← subprocessor → Vendor 2

New relationship structure:

• Option 1: Vendor 1 → subprocessor → Vendor 2 (“Vendor 1 is a subprocessor of Vendor 2”)

• Option 2: Vendor 1 ← subprocessor ← Vendor 2 (“Vendor 2 is a subprocesor of Vendor 1”)

If your tenant has such relationships, these records will be displayed with an option to reverse direction.

Exception Handling

In case any exceptions are identified during the upgrade process, the tenant will be rolled back to the beginning of the maintenance window.