Global Local Inventory Relationship: Feature Guide
Feature Overview/Use-Cases
What is it?
The Global/Local feature is designed to help organizations manage inventory records that are similar across organizations, but are managed and reported on separately.
Who does it benefit?
Large, multi-national organizations with multiple legal entities or multiple DPOs operating in different jurisdictions, taking a centralized-hybrid approach to managing parts of their privacy program.
These organizations may already have or want to establish standard processing activities that are carried out by the local entities who are often acting as the controllers and ultimately responsible for maintaining and reporting on their local version of the standard process.
Organizations that use assets/applications that may have multiple instances or be hosted in multiple locations.
Challenges/Problems
Creating one shared process record in OneTrust today does not allow for accurate reporting and record keeping for local entities. Each local entity is typically acting as a controller for the process and will thus have specific details to capture and include in a report that are only relevant to their local version or record of process (e.g. DPO, controller contact info, operating location).
Often local versions are almost identical to the standard/master process but there tends to be slight variation among the local versions due to local laws and regulations.
E.g. The Payroll process carried out by the German entity uses a different local payroll system rather than the standard global application used by the other entities due to local hosting laws in Germany. Or, perhaps the Payroll process carried out by the French entity has a different data retention period than the global standard Payroll process due to local French regulations.
As a workaround, some organizations have created standalone copies of their inventory records for each organization who carries out the process which results in free-floating copies that are not organized, grouped or linked together in anyway.
Benefits: How does the feature help?
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Streamline and standardize your privacy program by creating master records to set standards and guidelines on how central processing activities or assets should be carried out/managed by your local organizations and DPOs.
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Create local versions of a master record to track which organizations use the standard process and gather local, entity-specific details. Local versions are linked to the master record and organized on a specific page.
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Identify different global hosting locations for similar assets within an organization by creating local versions of each asset.
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Simplify and streamline maintenance efforts with tools to keep local versions organized and up-to-date.
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Gather local, entity-specific details on local versions and easily compare differences between local versions and master records to understand where the local entities may be deviating from the standard and identify gaps/risks specific to local versions.
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Allow for each local entity to generate and maintain accurate records and Article 30 reports that contain the information relevant and specific to the local entity.
Capabilities
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Set Up Master Records
Set up inventory records as master records. This will be your standard record that is used as the baseline for how the other organizations should aim to implement the process.
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Create Local Versions
Once all of the details have been captured on the master record, create Local versions of the master for each organization that is carrying out the standard process. Local versions are linked copies of the master record. After local versions are created, they will be listed on the Local versions tab of a master record.
There are multiple ways to create local versions.
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Add local versions from the local version tab. See To Create Local Versions. All of the values from the master record will be inherited onto the local version.
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Use the Copy function in the Context Menu of a master record. Toggle on the Copy as local version option.
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If you have existing records/copies that should be identified as local versions, use the Link to master option located in the Context Menu of an inventory record.
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Set up local versions in bulk. See Create Local Versions from Bulk Import.
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Configure Inheritance Settings
Inheritance settings offers a way to promote standardization and streamline the maintenance efforts associated with keeping a group of similar, local versions up-to-date while still allowing for accurate and specific local reporting.
Configure inheritance settings from the Global Settings menu or the Local versions tab of a master record.
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Local Versions Tab: Compare, Organize and Maintain Local Versions
The Local versions tab is nested within the details of the master record. This is where you can view and manage all of the local versions with the master record.
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Bulk Launch Assessments on Local Versions to Gather Information
The assessment will be pre-populated with all the information from the master record so the local owner will only need to change any details specific to how the process is carried out in their organization.
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Bulk Edit Local Versions
Utilize bulk edit to quickly edit multiple local versions to streamline the maintenance and standardization process.
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Compare Master to Local Versions
Use the column selector on the Local versions tab to compare the master to multiple local versions to easily spot local variation.
Use the Compare option from the Context Menu on a local version to quickly compare a single local version to the master. This screen will show you all the attributes that are different between the master and the selected local version. You can also check the boxes on the side if you want to update the local version with values from the master record.
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Identifying Master and Local Records
Use the column selector on the Inventory list screen and include the Is master attribute to easily visualize which records are masters. Include the Master record name attribute to identify the master record to which a local version is linked.
Filter the inventory list by the Is Master attribute to identify all records that have been setup as master.
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View and Compare from a Local Version
In the Details page of a local record, you can easily see which master record the local version is associated to, view the details (read-only) of the master record for context and easily compare the master to the local version.
Reporting
Select Reports in the Data Mapping Automation menu to generate column reports and PDF reports on your inventories. Add the Is Master column and the Master Record name column in your reports to capture detailed information on your records' attribute inheritance configuration.
Frequently Asked Questions (FAQ)
Can I create master records for records that belong to sub-organizations?
Yes, any record can be setup as a master as long as the user has permission to create masters and has access to that record (the record’s managing org must belong to the users organization or sub-organization.
Can I create local versions linked to a master that belongs to a sibling organization?
Yes, there are two ways to approach this:
Consider the following Org Hierarchy.
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Set up a master at the “US” org.
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Option 1: User at the “Global Corp” organization can click ‘copy’ on the master, toggle ‘create as local version’ and select “EMEA” as the organization for the local version.
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Option 2: User in “Global Corp” organization could select an existing inventory record that belongs to “EMEA” and link it to the master “US” record.
Will configuring inheritance settings automatically affect all master records?
No. Inheritance settings must be configured separately for each master record.
Will local records inherit related inventories?
No. Automatic inheritance does not currently include inheriting related inventories.