Building Situational Awareness of GDPR

Abstract

Because previous academic research does not comment sufficiently on how the relevant content of the European Union (EU) General Data Protection Regulation (GDPR has been properly communicated to the organisations, or how the situational awareness (SA) of GDPR has been built in the organisations, this qualitative empirical research was regarded as a valuable approach for gathering authentic research material on the practical bases of this phenomena. The aim of this empirical case study (CS) is to develop a picture of what processes organisations use to build SA of the GDPR requirements. To guide the CS, we asked how the SA for decision-making was constructed and how it was perceived in organisations. The experiences of eight Finnish organisations showed that the organisations’ practices of building SA and their experiences with the quality and adequacy of SA differed. However, building SA proved to be a critical step for organisations in the overall process of meeting GDPR requirements. Especially the data coming from inside the organisation became very relevant in the SA process, because it supported decision makers to determine how the GDPR requirements should be implemented in the organisation. As a main contribution of this article, based on best practices shared by organisations a model of building SA was built. The proposed model is threefold and was constructed by combining the findings of an empirical CS analysis, the steps of the intelligence process, and the essential elements of the model of creating information security SA. The result is potentially beneficial for building situational understanding of any complex or ambiguous issue, especially in complex and digitalised technological areas, where combining information management with accurate and efficient decision-making is a common challenge. The results can be used by any party who is looking to build SA of an abstract issue in a complex environment.