US20110270768A1 - International Cross Border Data Movement - Google Patents

Abstract

In some embodiments, a data movement system comprises a memory and a workflow manager. The memory is operable to store a request to move data from one or more jurisdictions, the request comprising (a) a data type, (b) a jurisdiction from which the data is to be moved, and (c) a purpose for moving the data. The workflow manager is configured to identify a set of data movement rules based at least in part upon the request. The set of data movement rules are associated with regulations of the jurisdiction identified in the request. The workflow manager is configured to apply at least one rule of the set of data movement rules to identify an action item to be completed in order to comply at least in part with the regulations.

Description

RELATED APPLICATIONS
• Pursuant to 35 U.S.C. §119(e), this application claims priority to U.S. Provisional Patent Application Ser. No. 61/329,724, entitled INTERNATIONAL CROSS BORDER DATA MOVEMENT, filed Apr. 30, 2010. U.S. Provisional Patent Application Ser. No. 61/329,724 is hereby incorporated by reference in its entirety.
TECHNICAL FIELD
• The present disclosure relates to data movement generally and more specifically to international cross border data movement.
BACKGROUND
• Some jurisdictions may restrict an organization's ability to export certain types of data. These jurisdictions may promulgate regulations that either prohibit exportation of certain types of data or allow exportation subject to specified requirements. The extent and complexity of these regulations may differ among jurisdictions.
SUMMARY
• In some embodiments, a data movement system comprises a memory and a workflow manager. The memory is operable to store a request to move data from one or more jurisdictions, the request comprising (a) a data type, (b) a jurisdiction from which the data is to be moved, and (c) a purpose for moving the data. The workflow manager is configured to identify a set of data movement rules based at least in part upon the request. The set of data movement rules are associated with regulations of the jurisdiction identified in the request. The workflow manager is configured to apply at least one rule of the set of data movement rules to identify an action item to be completed in order to comply at least in part with the regulations.
• Certain embodiments may provide one or more technical advantages. A technical advantage of one embodiment may include the capability to identify inherent risk associated with moving data out of one or more jurisdictions. A technical advantage of one embodiment may include the capability to identify action items required for regulatory compliance. A technical advantage of one embodiment may include the capability to reduce risk associated with moving data out of a jurisdiction by identifying and completing action items. A technical advantage of one embodiment may include the capability to provide a quantitative expression of inherent risk that may allow an organization to appropriately allocate resources towards minimizing the organization's risk in that jurisdiction. A technical advantage of one embodiment may include the capability to improve organization knowledge of project history and provide a trail for evaluators to assess the organization's compliance with jurisdictional regulations.
• Various embodiments of the invention may include none, some, or all of the above technical advantages. One or more other technical advantages may be readily apparent to one skilled in the art from the figures, descriptions, and claims included herein.
BRIEF DESCRIPTION OF THE DRAWINGS
• For a more complete understanding of the present disclosure and its advantages, reference is now made to the following description taken in conjunction with the accompanying drawings, in which:
• FIG. 1 shows a data movement system according to one embodiment;
• FIG. 1A shows an example project file ofFIG. 1 according to one embodiment;
• FIG. 1B shows an example project snapshot ofFIG. 1 according to one embodiment;
• FIG. 2 shows a risk workflow according to one embodiment;
• FIG. 3 shows an action item workflow according to one embodiment;
• FIG. 4 shows an update workflow according to one embodiment;
• FIGS. 5A-5D show example request forms according to one embodiment;
• FIG. 6 shows a jurisdictional matrix according to one embodiment;
• FIGS. 7A and 7B shows example decision grids for applying rules to a request according to several embodiments; and
• FIG. 8 shows an example project summary according to one embodiment.
DETAILED DESCRIPTION
• It should be understood at the outset that, although example implementations of embodiments of the invention are illustrated below, the present invention may be implemented using any number of techniques, whether currently known or not. The present invention should in no way be limited to the example implementations, drawings, and techniques illustrated below. Additionally, the drawings are not necessarily drawn to scale.
• An organization may conduct activities and store data in multiple jurisdictions throughout the world. An organization may include any social arrangement that pursues collective goals. One example of an organization is a business. A business is an organization designed to provide goods or services, or both, to consumers, governmental entities, and other businesses. Examples of a business may include, but are not limited to, agriculture and mining businesses, financial institutions, manufacturers, real estate companies, retailers and distributors, service businesses, transportation companies, and utility companies. A business may include both for-profit and not-for-profit businesses. An organization may also include multiple businesses. For example, an organization may control businesses in multiple jurisdictions throughout the world. Examples of organizations are not limited to businesses. For example, an organization can itself be a government entity.
• Some jurisdictions may restrict an organization's ability to export certain types of data. These jurisdictions may promulgate regulations that either prohibit exportation of certain types of data or allow exportation subject to specified requirements. The extent and complexity of these regulations may differ among jurisdictions. For example, an organization may store personally-identifiable information in ten different jurisdictions, and each of them may have different restrictions on the organization's ability to move the personally-identifiable information. In another example, the ten different jurisdictions may have different definitions as to what constitutes personally-identifiable information (e.g., jurisdictions may disagree as to whether an individual's job title is personally-identifiable information).
• Teachings of certain embodiments recognize the ability for an organization with a past, current, or future data-movement project to identify inherent risk associated with moving data out of one or more jurisdictions. Returning to the last example, teachings of certain embodiments recognize the ability to quantitatively assess risk associated with exporting data out of one or all of the ten jurisdictions. Teachings of certain embodiments also recognize the ability to identify action items in furtherance of regulatory compliance. Returning to the last example, teachings of certain embodiments recognize the ability to identify actions that the organization may take in a step toward compliance with governing regulations (e.g., actions required for compliance with a jurisdiction's data-movement regulations).
• As used throughout, a data-movement project may include any project that involves moving data out of at least one jurisdiction. A data-movement project may be associated with one or more requests to move data. A request to transfer data may include any information regarding a past, present, or proposed movement of data out of a jurisdiction. A request to transfer data may include both one-time and recurring data movements. A jurisdiction includes any territory or legal division that may have regulations restricting exportation of data out of the jurisdiction. Examples of jurisdictions may include, but are not limited to, countries, states, dependencies (e.g., the Isle of Man), territories (e.g., the Cayman Islands), unions (e.g., the European Union), and other national and international organizations. Data may refer to either plural data or singular datum.
• FIG. 1 shows adata movement system1000 according to one embodiment.FIG. 1 A shows an example project file210 ofFIG. 1 according to one embodiment.FIG. 1B shows anexample project snapshot710 ofFIG. 1 according to one embodiment.
• In general,system1000 receives requests to transfer data out of one or more jurisdictions and then aids in determining jurisdictional requirements for transferring the data. These requests to transfer data are associated with data-movement projects, which may include any effort by the organization to move data.
• In some embodiments,system1000 may identify inherent risk associated with moving data out of one or more jurisdictions. Two example types of risk are jurisdiction risk and project risk. Jurisdiction risk may approximately express the inherent risk associated with moving data out of a jurisdiction. For example, a jurisdiction with a highly complex regulatory structure may add to inherent risk because of the possibility that the organization fails to comply with the regulations of the jurisdiction. A jurisdiction in which the organization's exposure is high may add to inherent risk because of the ramifications to the organization for failure to comply with the regulations of the jurisdiction. Teachings of certain embodiments recognize that a quantitative expression of inherent risk may allow an organization to appropriately allocate resources towards minimizing the organization's risk in that jurisdiction. If the inherent risk associated with a jurisdiction is unmanageable, the organization may even decide to abandon efforts to move data out of the jurisdiction.
• Project risk may approximately express the inherent risk associated with moving data out of each of the jurisdictions identified in the data-movement project. For example, a project with a higher project risk may indicate that the project includes a large number of jurisdictions with a highly complex regulatory structure and/or a large number of jurisdictions where the organization's exposure is high. Teachings of certain embodiments recognize that a quantitative expression of inherent project risk may allow an organization to appropriately allocate resources towards minimizing the organization's risk associated with that project. If the inherent project risk associated with the project is unmanageable, the organization may even decide to abandon the project.
• In some embodiments,system1000 may also identify action items required for regulatory compliance. As one example, if a jurisdiction requires outsourcing agreements with third parties to include certain terms, thensystem1000 may analyze a project to determine whether the organization needs to include the certain terms in its outsourcing agreements. Teachings of certain embodiments recognize that identifying action items and completing those action items may reduce risk associated with moving data out of a jurisdiction. Thus, if a jurisdiction has a high inherent jurisdiction risk or a project has a high inherent project risk, identifying and completing action items may mitigate risk. In this manner, identifying and completing action items may be analogous to an internal control system for minimizing risk.
• An internal control may include any process effected by an organization that is designed to accomplish specific goals or objectives, such as reducing risk. Teachings of certain embodiments also recognize the ability to manage and track execution of action items as an additional mechanism for monitoring and mitigating risk. Action items may include specific actions that an organization may take to comply with a rule or regulation, or to otherwise mitigate risk associated with moving data out of a jurisdiction. Action items may be managed and tracked over time. For example, action items may include recurring actions to be completed, and action items may change over time due to changes in the project or changes in any governing regulations. Teachings of certain embodiments also recognize that tracking execution of action items may allow an evaluator to later confirm that the project is complying with any governing regulations.
• Theexample system1000 ofFIG. 1 features aninterface100, arequest repository200, aworkflow manager300, arules engine400, aregulation repository500,external systems600, and adocument management repository700, that may be implemented by one ormore computer systems10.
• Computer system10 may includeprocessors12, input/output devices14, communications links16, andmemory18. In other embodiments,computer system10 may include more, less, or other components.Computer system10 may be operable to perform one or more operations of various embodiments. Although the embodiment shown provides one example ofcomputer system10 that may be used with other embodiments, such other embodiments may utilize computers other thancomputer system10. Additionally, embodiments may also employmultiple computer systems10 or other computers networked together in one or more public and/or private computer networks, such as one ormore networks30.
• Processors12 represent devices operable to execute logic contained within a medium. Examples ofprocessor12 include one or more microprocessors, one or more applications, and/or other logic.Computer system10 may include one ormultiple processors12.
• Input/output devices14 may include any device or interface operable to enable communication betweencomputer system10 and external components, including communication with a user or another system. Example input/output devices14 may include, but are not limited to, a mouse, keyboard, display, and printer.
• Network interfaces16 are operable to facilitate communication betweencomputer system10 and another element of a network, such asother computer systems10. Network interfaces16 may connect to any number and combination of wireline and/or wireless networks suitable for data transmission, including transmission of communications. Network interfaces16 may, for example, communicate audio and/or video signals, messages, internet protocol packets, frame relay frames, asynchronous transfer mode cells, and/or other suitable data between network addresses. Network interfaces16 connect to a computer network or a variety of other communicative platforms including, but not limited to, a public switched telephone network (PSTN); a public or private data network; one or more intranets; a local area network (LAN); a metropolitan area network (MAN); a wide area network (WAN); a wireline or wireless network; a local, regional, or global communication network; an optical network; a satellite network; a cellular network; an enterprise intranet; all or a portion of the Internet; other suitable network interfaces; or any combination of the preceding.
• Memory18 represents any suitable storage mechanism and may store any data for use bycomputer system10.Memory18 may comprise one or more tangible, computer-readable, and/or computer-executable storage medium. Examples ofmemory18 include computer memory (for example, Random Access Memory (RAM) or Read Only Memory (ROM)), mass storage media (for example, a hard disk), removable storage media (for example, a Compact Disk (CD) or a Digital Video Disk (DVD)), database and/or network storage (for example, a server), and/or other computer-readable medium.
• In some embodiments,memory18stores logic20.Logic20 facilitates operation ofcomputer system10.Logic20 may include hardware, software, and/or other logic.Logic20 may be encoded in one or more tangible, non-transitory media and may perform operations when executed by a computer.Logic20 may include a computer program, software, computer executable instructions, and/or instructions capable of being executed bycomputer system10.Example logic20 may include any of the well-known OS2, UNIX, Mac-OS, Linux, and Windows Operating Systems or other operating systems. In particular embodiments, the operations of the embodiments may be performed by one or more computer readable media storing, embodied with, and/or encoded with a computer program and/or having a stored and/or an encoded computer program.Logic20 may also be embedded within any other suitable medium without departing from the scope of the invention.
• Various communications betweencomputers10 or components ofcomputers10 may occur across a network, such asnetwork30.Network30 may represent any number and combination of wireline and/or wireless networks suitable for data transmission.Network30 may, for example, communicate internet protocol packets, frame relay frames, asynchronous transfer mode cells, and/or other suitable data between network addresses.Network30 may include a public or private data network; one or more intranets; a local area network (LAN); a metropolitan area network (MAN); a wide area network (WAN); a wireline or wireless network; a local, regional, or global communication network; an optical network; a satellite network; a cellular network; an enterprise intranet; all or a portion of the Internet; other suitable communication links; or any combination of the preceding. Althoughsystem1000 shows onenetwork30, teachings of certain embodiments recognize that more or fewer networks may be used and that not all elements may communicate via a network. Teachings of certain embodiments also recognize that communications over a network is one example of a mechanism for communicating between parties, and any suitable mechanism may be used.
• Interface100 may include any interface accessible by a user, such as auser50.User50 may include any individual, group of individuals, entity, machine, and/or mechanism that interacts withinterface100. Examples ofusers5 include, but are not limited to, a manager, executive, review board, accountant, engineer, technician, contractor, agent, and/or employee or representative of an organization.
• Interface100 may include one or more forms for receiving information fromuser50 and/or providing information touser50 relating to a data-movement project. A data-movement project may include any project that involves moving data out of at least one jurisdiction. As one example, a data-movement project may involve moving data from a first jurisdiction to a second jurisdiction. As another example, a data-movement project may involve sharing data among multiple jurisdictions. Data-movement projects may include both one-time and recurring movements of data.
• Data-movement projects may move data for any suitable purpose. As one example, a data-movement project may allow multiple business units or lines of business of an organization to share data housed in different jurisdictions. In this example,interface100 may receive any information useful in determining whether and how the data-movement project implicates data privacy regulations promulgated by the different jurisdictions. Data privacy involves the relationship between collection and dissemination of data, technology, the public expectation of privacy, and the legal and political issues surrounding them. Example data privacy regulations may include, but are not limited to, regulations restricting the collection and movement of personally identifiable information, which may be received from sources such as healthcare records, criminal justice investigations and proceedings, financial institutions and transactions, biological traits and genetic material, residence and geographic records, and ethnicity.
• As another example, data may be moved out of a jurisdiction in order to comply with a request from outside the organization, such as a subpoena. In this example,interface100 may receive any information useful in determining whether and how the data-movement project implicates data secrecy regulations promulgated by the jurisdiction. Data secrecy involves ensuring that information is accessible only to those authorized to have access. One example of data secrecy is bank secrecy. Bank secrecy is a legal principle in some jurisdictions under which financial institutions are not allowed to provide to authorities personal and account information about their customers unless certain conditions apply. For example, bank secrecy regulations are prevalent in countries such as Switzerland, Singapore, and Luxembourg.
• As yet another example, a data-movement project may involve outsourcing data out of a jurisdiction to an external organization, such as a third-party data processor. In this example,interface100 may receive any information useful in determining whether and how the data-movement project implicates outsourcing regulations promulgated by the jurisdiction. Outsourcing involves the practice of hiring an external organization to perform some functions using an organization's data. Outsourcing regulations may include restrictions on what data may be outsourced and requirements stipulating how outsourced data must be handled.
• In one embodiment,interface100 includes one or more request forms110aand110band one ormore project summaries120. Example request forms110aand110bare shown inFIGS. 5A-5D, and anexample project summary120 is shown inFIG. 8.
• Request forms110aand110bprovide a form for receiving information regarding requests to transfer data out of one or more jurisdictions. In one embodiment, information received through request forms110aand110bis stored in aproject file210 inrequest repository200. In this example embodiment ofFIG. 1A, the information received through request forms110aand110bincludesproject information212,data movement information214, andjurisdiction information216.Project information212 may include any information regarding a data-movement project, such as a project name, a project identifier, a requestor name and contact information, and a project type.Data movement information214 may include any information regarding the proposed data movement, such as a type of data to be moved, a purpose for the data movement, and information identifying whether the data movement will be one-time or recurring. Examples of data type may include personal data (e.g., customer, client, or associate specific identifiable data), background data, transaction data (e.g., individual transaction level data), government data (e.g., data about or controlled by a sovereign entity), medical data (e.g., information containing personal medical records), sensitive data (e.g., religious or political affiliations), and anti-money laundering information (e.g., trending to identify anti-money laundering transactions). Teachings of certain embodiments recognize that categories of data types may differ among jurisdictions. As one example, some jurisdictions consider an individual's job title to be personally-identifiable information, whereas other jurisdictions do not. Examples of movement purposes include anti-money laundering, sales, servicing, marketing, financial reporting, fulfillment, data storage, testing, associate access, reporting, processing, and document storage.Jurisdiction information216 may include information identifying one or more jurisdictions hosting the data to be moved. Additional examples of request forms110aand110b,project information212,data movement214, andjurisdiction information216 are described with respect toFIGS. 5A-5D.
• Referring back toFIG. 1,project summary120 provides a form for reporting information regarding requests to transfer data out of one or more jurisdictions. In one example, such reported information includes theproject information212, thedata movement information214, thejurisdiction information216, and resultsinformation218.Results information218 may include any information regarding jurisdictional requirements for transferring the data, such as information regarding regulations promulgated by one or more jurisdictions, actions that facilitate with the regulations promulgated by one or more jurisdictions (e.g., action items), and actions completed towards compliance with the regulations promulgated by one or more jurisdictions. Examples of the regulations promulgated by one or more jurisdictions includecurrent regulations510 andpast regulations520, which is described in greater detail with regard toregulation repository500. Additional examples ofproject summary120,project information212,data movement214,jurisdiction information216, and resultsinformation218 are described with respect toFIG. 8.
• Request repository200 may include any repository for storing information regarding requests to transfer data out of one or more jurisdiction. In the illustrated embodiment,request repository200 stores one or more project files210. Eachproject file210 includes information regarding one request to transfer data out of one or more jurisdictions. Eachproject file210 may also be assigned a unique record locator for identifying theproject file210. In the illustrated embodiment,project file210 information includesproject information212,data movement information214,jurisdiction information216, and resultsinformation218.Request repository200 may receiveproject information212,data movement information214, andjurisdiction information216 frominterface100 and may receiveresults information218 fromworkflow manager300.
• In some embodiments, project files210 may be ordered in a queue for processing. Project files210 may be arranged in any suitable order. In one embodiment, project files210 are arranged according to a time stamp (e.g., in the order received). In some embodiments, auser50 associated with the organization may manually change the order of project files210 withinqueue215. In another embodiment, project files210 are automatically prioritized according to factors such as project type (e.g., proposed or active), data type, project deadlines, line of business, number of jurisdictions, regulation complexity, project purpose, project phase and/or project risk. One example of overall project risk is described with regards to FIG.2, which shows arisk workflow2000 for calculating jurisdictional risk and project risk.
• In one embodiment,request repository200 may provideT-P-J information220 toworkflow manager300. In this example,T-P-J information220 includes three types of information about a project: a data type, a project purpose, and a jurisdiction hosting the data.T-P-J information220 may be extracted from one or more project files210.Workflow manager300 may use at least some of theT-P-J information220 as inputs to one or more workflows.
• The illustrated embodiment features three example workflows:risk workflow2000, anaction item workflow3000 for identifying action items that facilitate regulatory compliance, and anupdate workflow4000 for updating jurisdictional requirements for a project. As one example,risk workflow2000 may assess risk for a project that involves moving first data from a first jurisdiction and second data from a second jurisdiction. The first and second jurisdictions may be identified byT-P-J information220, and the regulations of those jurisdictions may be collected fromcurrent regulations510 stored onregulatory repository500.Risk workflow2000 may also userules410 in lieu of or in addition tocurrent regulations510. In this example, the project may be determined based on the jurisdictional complexity of the project and the jurisdictional exposure of the project. The jurisdictional complexity of the project may be determined based on the regulations of the first jurisdiction and the second jurisdiction. The jurisdictional exposure of the project may also be determined based on the organization's volume of business activity in the first jurisdiction and the second jurisdiction.
• As another example,action item workflow3000 may determine information for moving data from one or more jurisdictions.T-P-J information220 may identify request information including a data type, a jurisdiction from which the data is to be moved, and a purpose for moving the data. A set of data movement rules may be identified and applied against the request to identify an action item to be completed in order to comply at least in part with the regulations.
• As yet another example,update workflow4000 may update jurisdictional information for a project that involves moving data from a first jurisdiction.T-P-J information220 may identify request information including a data type, a jurisdiction from which the data is to be moved, and a purpose for moving the data. An update to the request may be received changing some part of theT-P-J information220. A set of data movement rules may be identified and applied against the updated request to identify an updated action item to be completed in order to comply at least in part with the regulations.
• As yet another example,update workflow4000 may update jurisdictional information for moving data across jurisdictional borders.T-P-J information220 may identify request information including a data type, a jurisdiction from which the data is to be moved, and a purpose for moving the data. An update to the rules associated with the jurisdiction may be received. The update may represent a change to at least one regulation of the jurisdiction. The updated data movement-rules may be applied against the request to identify an updated action item to be completed in order to comply at least in part with the regulations.
• Risk workflow2000,action item workflow3000, andupdate workflow4000 are described in greater detail with regards toFIGS. 2,3, and4.
• Rules engine400 stores and appliesrules410.Rules410 are associated with regulations of a jurisdiction. In the illustrated embodiment, rules410 are developed fromcurrent regulations510 stored in aregulation repository500.Rules410 may be developed dynamically fromregulations510 or may be compiled ahead of time based onregulations510. In one embodiment, rules410 may include if/then/else scenarios developed fromregulations510 to identify whether and/or how the regulations restrict movement of data out of a jurisdiction. Teachings of certain embodiments recognize thatrules410 may provide a structured mechanism for applying regulations of a jurisdiction to a project and may reduce the need to refer to the regulations directly. In one example, a regulation may be relevant if the project involves moving “data type A” data. In this example, a regulation may apply to data type A, and a corresponding rule may be applied against those projects that have data type=data type A. Thus, in this example, the relevant rule may be identified without searching the regulations for regulations that may implicate “data type A” data. Example rules410 are described in greater detail with regard toFIGS. 7A and 7B.
• Rules engine400 may also store ajurisdiction matrix420.Jurisdiction matrix420 provides a snapshot view of multiple jurisdictions, the jurisdiction risk scores associated with the multiple jurisdictions, and a list of those factors and corresponding weights that are used to determine the jurisdiction risk scores. Thus, ajurisdiction matrix420 may aggregate information assessing inherent risk associated with an organization that operates in a jurisdiction and may move data out of that jurisdiction.Jurisdiction matrix420 includes at least two categories of information:jurisdiction information422 andorganization information424.Jurisdiction information422 includes information regarding regulatory complexity of the jurisdiction and/or the jurisdiction's penalties for failing to comply with the jurisdiction's regulations.Organization information424 includes information regarding an organization's exposure in the jurisdiction.Organization information424 may include, for example, the organization's volume of business activity in the jurisdiction and/or the organization's volume of data in the jurisdiction. In some embodiments,jurisdiction matrix420 may be populated dynamically by reference torules410 or compiled ahead of time based onrules410 orregulations510. For example, in one embodiment, rules410 are applied to jurisdiction information in a manner similar to that described with regard toaction item workflow3000 to determine whether rules exist restricting data movement in a variety of regulatory arenas but without actually analyzing individual project information to identify action items. Anexample jurisdiction matrix420 is described in greater detail with regard toFIG. 6.
• Regulatory repository500 may include any repository for storing regulations promulgated by one or more jurisdictions. In the illustrated embodiment,regulatory repository500 storescurrent regulations510 andpast regulations520.Current regulations510 are regulations promulgated by a jurisdiction and that are either in effect or expected to be in effect in the future.Past regulations520 are regulations once promulgated by a jurisdiction but that are no longer effective.
• In some embodiments,external systems600 may facilitate transmitting or receiving information from an organization's information systems. As one example, request forms110aand110bmay useexternal systems600 to auto-populate information fields. As another example,project snapshots710 may include references to an organization's document management system, andexternal systems600 may be used to access documents stored on the document management system. As yet another example,external systems600 may transmit information regarding a project to other organizational software tools. As one example,external systems600 may include an email server configured to send information regarding a project to organizational employees associated with the project.
• Document management repository700 may include any repository for storingproject snapshots710 and completion documents720.Project snapshots710 are data records that archive information relating to a project, as described below. Eachproject snapshot710 may be associated with a project identifier, a timestamp, and/or a snapshot identifier. Completion documents720 are documents created during execute of an action item. Eachcompletion document720 may be associated with aproject snapshot710. For example, aproject snapshot710 that lists completed action items may identify the completion documents720 that provide evidence that the action items were indeed completed.Project snapshots710 andcompletion documents720 together represent a searchable collection of organizational knowledge regarding past and current projects.
• Teachings of certain embodiments recognize that archiving information relating to a project may improve organizational knowledge of project history and provide a trail for evaluators to assess the organization's compliance with jurisdictional regulations. For example, one project may be associated withmultiple project snapshots710 that allow evaluators to review the project at different points at time, such as after set periods of time or after the project or regulations change. An evaluator may reviewproject snapshots710 for any purpose, such as ascertaining the validity and reliability of the information contained in theproject snapshots710 or evaluating the organization's internal controls.
• Returning toFIG. 1B, information archived inproject snapshots710 may include, but is not limited to, regulations applied to the project (e.g.,current regulations510 or past regulations520), rules applied to the project (e.g., rules410), action items identified for the project (e.g., action items identified through action item workflow3000), actions performed in response to the identified action items (e.g., references to completion documents720), and other project details (e.g.,project information212, data-movement information214, and jurisdiction216).Project snapshots710 may also include references identifying archived information stored elsewhere. As used throughout, references may include any identification of documents or information. As one example,project snapshots710 may include a reference tocurrent regulations710 orpast regulations720 without necessarily including copies of those regulations; such references may identify the regulations and/or provide information on how to locate copies of the regulations. As another example,project snapshots710 may include references tocompletion documents720 instead of actual copies of those documents.
• Returning back toFIG. 1, completion documents720 represent documents created during execution of an action item. As one example, if an action item requires the organization to obtain customer consents, then completion documents720 may include copies of the customer consents. As another example, if an action item requires the organization to enter into outsourcing agreements with third parties subject to certain terms, then completion documents720 may include a copy of the outsourcing agreements. Teachings of certain embodiments recognize that storingcompletion documents720 may allow an evaluator to efficiently assess the organization's compliance withregulations510. Teachings of certain embodiments also recognize that completion documents720 may be reused in future projects. For example, if an action item requires the organization to obtain customer consents, a future project may reuse some or all of the stored customer consent documents if facing a similar action item. For example, if the customer consents include language requested by a jurisdiction, then future customer consents used in that jurisdiction may reuse the that language.
• A project may be associated withmultiple project snapshots710. For example, aproject snapshot710 may be stored every time a project is updated. Update events may include, but are not limited to, times when action items are identified, when action items are completed, when action items are changed, when regulations or rules have changed, and when any other project information has changed. As one example, if a project is directed to moving data out of a first jurisdiction, afirst project snapshot710 may include a reference tocurrent regulation510. If the referencedcurrent regulation510 is replaced with a new regulation, thecurrent regulation510 may be stored as apast regulation520, and the new regulation may be stored as acurrent regulation510. Thefirst project snapshot710 would then have a reference to the storedpast regulation520, and asecond project snapshot710 would have a reference to the newcurrent regulation510.
• In operation, according to one embodiment, request forms110aand110bare prepared. Auser50 may complete request forms110aand110bby providingproject information212, data-movement information214, andjurisdiction information216, which may then be stored in aproject file210 onrequest repository200. Project files may be organized in aqueue215, and auser50 may review and prioritize the project files210 before projects proceed toworkflow manager300.Workflow manager300 selects a project fromproject file210 and receivesT-P-J information220. Using thisT-P-J information220,workflow manager300 may initiate different workflows.Risk workflow2000 may populatejurisdiction matrix420 to calculate jurisdictional risk and project risk based on the organization and the jurisdictions identified byjurisdiction information216.Action item workflow3000 may applyrules410 to theT-P-J information220 to identify action items required for the project to comply with each jurisdiction's regulations.Update workflow4000 may updaterules410 and/or action items for the project in response to changes to the jurisdiction's regulations or changes to theT-P-J information220. Identified action items may be reviewed and validated by auser50 to ensure they accurately represent the governing regulations.Document management repository700 may storeproject snapshots710, which archive changes and developments to the projects.
• FIG. 2 showsrisk workflow2000 according to one embodiment.FIG. 3 showsaction item workflow3000 according to one embodiment.FIG. 4 showsupdate workflow4000 according to one embodiment.Workflows2000,3000, and4000 are described with reference to an example data-movement project. The example data-movement project includes an organization's request to move data out of an example Jurisdiction A and an exampleJurisdiction B. Workflows2000,3000, and4000 are also described with reference toFIGS. 6-8.
• According to one embodiment,workflow2000 may assess jurisdictional risk and project risk associated with a project that involves moving first data from a first jurisdiction and second data from a second jurisdiction. Jurisdictional risk may approximately express the inherent risk associated with moving data out of a jurisdiction. Project risk may approximately express the inherent risk associated with moving data out of each of the jurisdictions identified in the project.
• Risk workflow2000 starts atstep2100. Atstep2200,jurisdiction information216 is received. In this example,jurisdiction information216 identifies Jurisdiction A and Jurisdiction B. Atstep2300, the complexity of the regulations of Jurisdiction A and Jurisdiction B is determined. In this example,jurisdiction matrix6000 ofFIGS. 6A-6B may be used to determine regulatory complexity.FIGS. 6A-6B will be described in the following paragraphs.
• FIGS. 6A-6B showsjurisdictional matrix6000 according to one embodiment.Jurisdictional matrix6000 represents one example of thejurisdictional matrix420 ofFIG. 1. In this example embodiment,jurisdictional matrix6000 includes rows ofjurisdictions6100 and columns of matrix factors6200.Example jurisdictions6100 include Jurisdiction A and Jurisdiction B.
• Example matrix factors6200 includeregulatory information6210,regulatory oversight factors6220,data volume factors6230, and business criticality factors6240.Regulatory information6210 identify whether eachjurisdiction6100 restricts movement of data in the areas of data privacy, secrecy, and outsourcing. Exampleregulatory information6210 include requirements related to the regulatory areas of data privacy, data secrecy, and outsourcing.
• Regulatory oversight factors6220 identify the regulatory activity of eachjurisdiction6100 and the penalties that may be incurred for failing to obey regulations of eachjurisdiction6100. Exampleregulatory oversight factors6220 include the civil and criminal penalties for failure to comply with data movement regulations and the activity level of the jurisdiction's regulatory body. For example, a jurisdiction that requires many regulatory filings and has an enforcement division may increase the chances that an organization would be prosecuted for failure to comply as compared to a jurisdiction that has a passive regulatory structure.
• Data volume factors6230 assess the volume of an organization's data within each jurisdiction. Exampledata volume factors6230 may include the number of data centers located in a jurisdiction, whether there are any large-volume data operations in the jurisdiction, and whether the organization considers the jurisdiction to be a “critical outsourcing location.”Business criticality factors6240 assess the criticality of the jurisdiction to the organization's overall business. Examplebusiness criticality factors6240 may include the number of lines of business the organization has in the jurisdiction, the organization's revenue attributable to activities in the jurisdiction, and whether the organization is considering new market entry or expansion into the jurisdiction.
• Jurisdictional matrix6000 also includesweights6300.Weights6300 define a relative value for eachmatrix factor6200. As one example, acquiring customer consent may be more complex than providing customer notification; accordingly, the weight assigned to the customer consentregulatory information6210 is higher than the weight assigned to the customer notificationregulatory information6210. Applyingweights6300 toregulatory information6210,regulatory oversight factors6220,data volume factors6230, andbusiness criticality factors6240 yield correspondingregulatory information scores6410,regulatory oversight scores6420,data volume scores6430, andbusiness criticality scores6440, as shown inFIG. 6. Additionally, in this example,regulatory information scores6410 may be added to yield an overallregulatory information score6510;regulatory oversight scores6420 may be added to yield overallregulatory oversight score6520;data volume scores6430 may be added to yield overalldata volume score6530; andbusiness criticality scores6440 may be added to yield overallbusiness criticality score6540.
• In addition, for each jurisdiction, theregulatory information scores6410,regulatory oversight scores6420,data volume scores6430, andbusiness criticality scores6440 may be added to yield ajurisdiction risk score6600. Teachings of certain embodiments recognize that ajurisdiction risk score6600 may approximately express the inherent risk associated with moving data out of a jurisdiction. In this example, a higherjurisdiction risk score6600 indicates that a jurisdiction has a highly complex regulatory structure and/or the organization's exposure in the jurisdiction is high. Teachings of certain embodiments recognize that a quantitative expression of inherent risk may allow an organization to appropriately allocate resources towards minimizing the organization's risk in that jurisdiction.
• In one embodiment, thejurisdiction risk scores6600 identified injurisdictional matrix6000 may be compared to a break value, set at 255 in the exemplaryjurisdictional matrix6000. The break value represents a threshold that may be used to classify thejurisdictional risk scores6600 as either high or low. Although the break value in this example is set at 255, teachings of certain embodiments recognize that the break value may be set to any suitable value. As one example, the break value may be set at the median or mean of all jurisdiction risk scores6600. In some example embodiments, multiple threshold values may be used to categorizejurisdictional risk scores6600 into different tiers.
• Returning torisk workflow2000 ofFIG. 2,step2300 may includesteps2310 and2320. Atstep2310,weights6300 may be applied toregulatory information6210 to yieldregulatory information scores6310 and overallregulatory requirement score6410. In one example, theregulatory information6210 include “yes” or “no” answers, with a “yes” answer having a value of 1 and a “no” answer having a value of 0. In this example, applyingweights6300 to theregulatory information6210 converts the yes/no answers into numerical values that express both the existence of a factor in a jurisdiction and the importance of that factor as compared to the other factors.
• Atstep2320,weights6300 may be applied toregulatory oversight factors6220 to yieldregulatory oversight scores6320 and overallregulatory oversight score6420. In one example, theregulatory oversight factors6220 include “yes” or “no” answers, with a “yes” answer having a value of 1 and a “no” answer having a value of 0. In this example, applyingweights6300 to theregulatory oversight factors6220 converts the yes/no answers into numerical values that express both the existence of a factor in a jurisdiction and the importance of that factor as compared to the other factors.
• Atstep2400, the organization's exposure in Jurisdiction A and Jurisdiction B may be determined. In this example,step2400 may includesteps2410 and2420. Atstep2410,weights6300 may be applied todata volume factors6230 to yield data volume scores6330 and overalldata volume score6430. In one example, the todata volume factors6230 include “yes” or “no” answers, with a “yes” answer having a value of 1 and a “no” answer having a value of 0. In this example, applyingweights6300 to the todata volume factors6230 converts the yes/no answers into numerical values that express both the existence of a factor in a jurisdiction and the importance of that factor as compared to the other factors.
• Atstep2420,weights6300 may be applied tobusiness criticality factors6240 to yield business criticality scores6340 and overallbusiness criticality score6440. In one example, thebusiness criticality factors6240 include “yes” or “no” answers, with a “yes” answer having a value of 1 and a “no” answer having a value of 0. In this example, applyingweights6300 to thebusiness criticality factors6240 converts the yes/no answers into numerical values that express both the existence of a factor in a jurisdiction and the importance of that factor as compared to the other factors.
• Atstep2500,jurisdiction risk scores6600 for Jurisdiction A and Jurisdiction B may be determined. As explained above, ajurisdiction risk score6600 may approximately express the inherent risk associated with moving data out of a jurisdiction. In this example,jurisdiction risk score6600 may be determined by addingregulatory information scores6410,regulatory oversight scores6420,data volume scores6430, andbusiness criticality scores6440, as shown inFIG. 6.
• Atstep2600, aproject risk score6700 may be determined. Teachings of certain embodiments recognize that aproject risk score6700 may approximately express the inherent risk associated with moving data out of each of the jurisdictions identified in the project. In this example, a higherproject risk score6700 indicates that the project includes a large number of jurisdictions with a highly complex regulatory structure and/or a large number of jurisdictions where the organization's exposure is high. Teachings of certain embodiments recognize that a quantitative expression of inherent risk may allow an organization to appropriately allocate resources towards minimizing the organization's risk associated with that project.
• An exampleproject risk score6700 is shown by reference toexample project summary120, as shown inFIG. 8.Project summary120 identifies different jurisdictional andorganizational risk factors6710 and counts the number of jurisdictions that have a high, medium, or low value for each risk factor. In the embodiment shown inFIG. 8, the example jurisdictional andorganizational risk factors6710 include overallregulatory information score6410, overalldata volume score6430, overallbusiness criticality score6440, and weighed revenue factor score (selected from among the business criticality scores6440). In this example, theproject risk score6700 is calculated as a function of the number of jurisdictions that have a high, medium, or low value for each of the identified jurisdictional and organizational risk factors6710. In one example embodiment, theproject risk score6700 is calculated by applying weights to the totals of high, medium, and low values and then added to yield a composite score. Theexample project summary120 ofFIG. 8 will be described in greater detail below.
• FIG. 3 showsaction item workflow3000 according to one embodiment.
• Action item workflow3000 may determine requirements for moving data from one or more jurisdictions. In some embodiments,workflow3000 may identify action items in an effort to reduce risk associated with moving data out of a jurisdiction. For example, if a jurisdiction has a high inherent risk or a project has a high inherent risk, identifying and completing action items may mitigate inherent risk. In addition,workflow3000 may provide a structured mechanism for applying regulations of a jurisdiction to a project and may reduce the need to refer to the regulations directly through the application ofrules410.
• Action item workflow3000 starts atstep3100. Atstep3200,T-P-J information220 is received. In this example,T-P-J information220 identifies a request to move personally identifiable information (PII) out of Jurisdiction A. Atstep3300, a set ofdata rules410 are identified based on theT-P-J information220. In this example,data rules410 corresponding to Jurisdiction A regulations concerning data privacy are identified because theT-P-J information220 identified Jurisdiction A and an intent to move PII data. The identifieddata rules410 may include if/then/else scenarios developed from regulations of Jurisdiction A related to data privacy that identify whether and/or how the Jurisdiction A restricts movement of PII data out of a jurisdiction. In different embodiments, the identifieddata rules410 may include all regulations of Jurisdiction A related to data privacy or a subset. As one example, the identifieddata rules410 may include initial rules that, when applied, will lead to other rules and action items. Atstep3400, the identifieddata rules410 are applied against the request.FIG. 7A shows anexample decision grid415afor applyingrules410 to the request atstep3400 according to one embodiment.FIG. 7A will be described in the following paragraph.
• FIG. 7A shows anexample decision grid415a.Decision grid415aillustrates one example method for applyingrules410. Applying rule1.0 to theT-P-J information220 reveals that data privacy “regulatory restrictions [are] present” and that “specific restrictions” should be determined at rule2.0. Applying rule2.0 to theT-P-J information220 reveals that “sensitive data elements” are involved, as that term is defined under the regulations of Jurisdiction A, and that the “sensitive data elements” should be determined at rule2.1. Applying the rule2.1 to theT-P-J information220 reveals that “sensitive data elements are present in the project request” and that “regulatory compliance requirements” should be determined at rule2.2. Applying the rule2.2 reveals that “compliance requirements exist” and should be defined at rule2.2a. Applying the rule2.2areveals that “customer notice [is] required” and that the organization should complete an action item: “deliver customer notice.”
• Returning toaction item workflow3000 ofFIG. 3,step3400 answered whether the request is allowed under the regulations of Jurisdiction A and what action items may facilitate compliance. In the example ofFIG. 7A,decision grid415arevealed that the requested data movement is allowed if customer notice is delivered.
• Atstep3500, the answer produced atstep3400 is analyzed to determine whether therules410 allow the requested data movement under any circumstances. In this example, the requested data movement is allowed if customer notice is delivered, so theaction item workflow3000 proceeds to step3600. However, if the requested data movement had been prohibited in all circumstances, a response denying the request may be generated atstep3510. The response may be provided in any suitable form. In one example, aproject summary120 may indicate that the requested data movement is denied under any circumstances. In another example,external systems600 may generate an email alerting the organization that the requested data movement is denied under any circumstances.
• Atstep3600, the answer produced atstep3400 is analyzed to determine whether therules410 require action items to be completed for compliance. In this example, therules410 require the organization to deliver customer notice to those customers required by the jurisdiction, so theaction item workflow3000 proceeds to step3700. However, if the requested data movement had been allowed in all circumstances, a response allowing the request may be generated atstep3610.
• Atstep3700, the request and the action item are stored. In one example, the action item is stored as part ofresults218. In another example, aproject snapshot710 is generated and records the request and the action item. In some embodiments, theresults218 and/orproject snapshot710 may be updated to record that the action item is completed. In this example, when the organization delivers the required customer notification, results218 may be updated,project snapshot710 may be updated, and copies of the customer notices may be stored at the document management repository as completion documents720. A response reporting that the requested data movement is allowed subject to an action item may also be generated.
• Teachings of certain embodiments recognize the capability to include verification steps to ensure that the identified action items accurately reflect the requirements of the governing regulations. As one example, a review board may determine whether a project will comply with each jurisdiction's regulations once the action items are completed. As an organization validates action items for projects over time, the organization may develop confidence that the action items and associated rules accurately reflect the governing regulations. Accordingly, teachings of certain embodiments recognize the capability to validate action items without submitting the action items for human review. For example, when an action item is generated, therequest repository200 may be searched for project records210 that include similar action items. In one example, two action items may be considered similar if they require the organization to perform the same steps but to different data sets. If the search ofrequest repository200 reveals a similar action item that has been verified, in some embodiments the new generated action item may be deemed verified without human review. In an alternative embodiment, a new generated action item may be deemed verified without human review if searching therequest repository200 revealed a sufficient number of similar action items that have been verified (e.g., ten or more).
• FIG. 4 showsupdate workflow4000 according to one embodiment.Update workflow4000 may update jurisdictional information for a project that involves moving data from a first jurisdiction. For example, action items may change over time due to changes in project information and/or changes in jurisdictional regulations. Teachings of certain embodiments recognize thatupdate workflow4000 may provide a structured mechanism for updating, adding, and removing action items through the application ofrules410 against existing projects and action items. Thus,workflow4000 may update those actions that the organization should complete to maintain compliance with governing regulations.
• Update workflow4000 starts atstep4100. Atstep4200,T-P-J information220 and an associated action item are stored. In this example,T-P-J information220 identifies a request to move personally identifiable information (PII) out of Jurisdiction A, and the associated action item requires the organization to provide customer notice, as identified by thedecision grid415aofFIG. 7A.
• Atstep4300, an update to theT-P-J information220 or therules410 corresponding to Jurisdiction A is received. In this example, the update is to rules410: as part of the update, Jurisdiction A now requires “customer consent” instead of “customer notice.” Accordingly, in this example,step4450 requires thatupdate workflow4000 proceed to step4550. Atstep4550, projects that involve moving data out of Jurisdiction A are identified. In this example,request repository200 and/ordocument management repository700 are searched to identify theT-P-J information220 and action item stored atstep4200. Atstep4650, the update torules410 are applied against the request.FIG. 7B shows an example method for applying updatedrules410 to the request atstep4650 according to one embodiment.FIG. 7B will be described in the following paragraph.
• FIG. 7B shows anexample decision grid415b.Decision grid415bproceeds to rule2.2asimilar to thedecision grid415aofFIG. 7A. However, rule2.2aofdecision grid415bis different from rule2.2aofdecision grid415a. Applying rule2.2areveals that “customer consent” is required and that the organization should “validate [that] customer consent is on file.” If the “customer consent” is not on file,decision grid415bproceeds to rule2.2b, which identifies a new action item: “obtain customer consent.” If “customer consent” is on file,decision grid415bproceeds to rule2.3. Applying rule2.3 once “customer consent” is obtained reveals another action item: “obtain regulatory notification.” Once “regulatory notification” is obtained,decision grid415bproceeds to rule2.4, which identifies another action item: “file regulatory notification with XYZ regulator.” Once the “regulatory notification” is filed,decision grid415bends.
• Returning to updateworkflow4000 ofFIG. 4,step4650 answered whether the request is allowed under the updated regulations of Jurisdiction A and what action items may be required for compliance. Atstep4750, the request and the updated action items are stored. In one example, the updated action items are stored as part ofresults218. In another example, aproject snapshot710 is generated and records the request and the action items; thissecond snapshot710 may be in addition to anyproject snapshot710 generated atstep3700 of the action item workflow ofFIG. 3.
• Returning to step4300 ofupdate workflow4000, if the received update is an update toT-P-J information220, then step4400 would indicate that theupdate workflow4000 proceed to step4500. Atstep4500, a set ofdata rules410 are identified in a manner similar to that described above with regard to step3300 ofaction item workflow3000. Atstep4600, the identifieddata rules410 are applied against the updated request in a manner similar to that described above with regard to step3400 ofaction item workflow3000. Atstep4700, the request and the action item are stored in a manner similar to that described above with regard to step3700 ofaction item workflow3000 and/orstep4750 ofupdate workflow4000.
• FIGS. 5A-5D show example request forms110aand110baccording to one embodiment. In the illustrated example, request forms110aand110bincludeintake form110aandassessment form110b. Together, request forms110aand110binclude several fields for receiving project information, includingproject information212,data movement information214, andjurisdiction information216. As one example,data movement information214 may be derived in part from the identified “purpose of using the above mentioned data” inQuestion 6 ofintake form110a. In this example, the purpose information may be included inT-P-J information220.
• FIG. 8 shows anexample project summary120 according to one embodiment. As explained above,project summary120 may displayproject risk score6700 and organizational risk factors6710.Project summary120 may also show action item summary information. For example,FIG. 8 shows action item summary information derived fromdecision grid415b. In this example, Jurisdiction A included a data privacy regulation requirement that “regulatory notification be filed with XYZ regulation.” According to thisexample project summary120, the task of filing the regulatory notification has been assigned within the organization to “Mr. Person,” and Mr. Person has one month to complete the task. Theexample project summary120 also includes high, medium, and low values derived from the overallregulatory information score6510, the overallregulatory oversight score6520, the overalldata volume score6530, and the overallbusiness criticality score6540 ofFIG. 6. As explained above, these high, medium, and low values may be derived by comparing each score to one or more threshold values.
• In some embodiments, updates to a project may yield new and/or updatedproject summaries120. Update events may include, but are not limited to, times when action items are identified, when action items are completed, when action items are changed, when regulations or rules have changed, and when any other project information has changed. As one example, if updated action items are identified throughupdate workflow4000, the updated action items may be shown on updatedproject summaries120. As another example, if Jurisdiction A changes their regulatory requirements, the changes may result in different values for: theproject risk score6700; theorganizational risk factors6710; the identified action items; and/or the high, medium, and low values derived from the overallregulatory information score6510, the overallregulatory oversight score6520, the overalldata volume score6530, and the overallbusiness criticality score6540 ofFIG. 6.
• Modifications, additions, or omissions may be made to the systems and apparatuses described herein without departing from the scope of the invention. The components of the systems and apparatuses may be integrated or separated. Moreover, the operations of the systems and apparatuses may be performed by more, fewer, or other components. The methods may include more, fewer, or other steps. Additionally, steps may be performed in any suitable order. Additionally, operations of the systems and apparatuses may be performed using any suitable logic. As used in this document, “each” refers to each member of a set or each member of a subset of a set.
• Although several embodiments have been illustrated and described in detail, it will be recognized that substitutions and alterations are possible without departing from the spirit and scope of the present invention, as defined by the appended claims.
• To aid the Patent Office, and any readers of any patent issued on this application in interpreting the claims appended hereto, applicants wish to note that they do not intend any of the appended claims to invokeparagraph 6 of 35 U.S.C. §112 as it exists on the date of filing hereof unless the words “means for” or “step for” are explicitly used in the particular claim.

Claims (18)

1. A data movement system comprising:

a memory operable to store a request to move data from one or more jurisdictions, the request comprising (a) a data type, (b) a jurisdiction from which the data is to be moved, and (c) a purpose for moving the data; and

a workflow manager configured to:

identify a set of data movement rules based at least in part upon the request, wherein the set of data movement rules are associated with regulations of the jurisdiction identified in the request; and

apply at least one rule of the set of data movement rules to identify an action item to be completed in order to comply at least in part with the regulations.

2. The system ofclaim 1, wherein applying the at least one rule identifies a second data movement rule, the method further comprising applying the second data movement rule to identify a second action item.

3. The system ofclaim 1, the workflow manager further configured to generate a response to the request, wherein the response to the request is one of an approval to move the data, a disapproval to move the data, and an approval conditional on completion of the action item.

4. The system ofclaim 1, wherein the memory is further configured to store information regarding the request and the action item and the workflow manager is further configured to store information in response to execution of the action item.

5. The system ofclaim 1, wherein the memory is further configured to:

store the identified set of data movement rules;

store an identification of the regulations associated with the identified set of data movement rules; and

store copies of documents created during execution of the action item.

6. The system ofclaim 1, wherein:

the request comprises a first request, the action item comprises a first action item, and the data comprises a first set of data, wherein the organization performed a first action to execute the first action item;

the memory is further configured to store the first request and the first action item; and

the workflow manager is further configured to:

receive a second request to move a second set of data out of the first jurisdiction;

apply the at least one data movement rule to the second request to identify a second action item, the second action item requiring the organization to perform a second action to execute the second action item; and

determine that the first action with respect to the first set of data is the same as the second action with respect to the second set of data.

7. A requirements computer comprising:

a memory operable to store a request to move data from one or more jurisdictions, the request comprising (a) a data type, (b) a jurisdiction from which the data is to be moved, and (c) a purpose for moving the data; and

a processor configured to:

identify a set of data movement rules based at least in part upon the request, wherein the set of data movement rules are associated with regulations of the jurisdiction identified in the request; and

apply at least one rule of the set of data movement rules to identify an action item to be completed in order to comply at least in part with the regulations.

8. The computer ofclaim 7, wherein applying the at least one rule identifies a second data movement rule, the method further comprising applying the second data movement rule to identify a second action item.

9. The computer ofclaim 7, the processor further configured to generate a response to the request, wherein the response to the request is one of an approval to move the data, a disapproval to move the data, and an approval conditional on completion of the action item.

10. The computer ofclaim 7, wherein:

the memory is further configured to store information regarding the request and the action item; and

the processor is further configured to store information in response to execution of the action item.

11. The computer ofclaim 7, wherein the memory is further configured to:

store the identified set of data movement rules;

store an identification of the regulations associated with the identified set of data movement rules; and

store copies of documents created during execution of the action item.

12. The computer ofclaim 7, wherein:

the request comprises a first request, the action item comprises a first action item, and the data comprises a first set of data, wherein the organization performed a first action to execute the first action item;

the memory is further configured to store the first request and the first action item; and

the processor is further configured to:

receiving a second request to move a second set of data out of the first jurisdiction;

applying the at least one data movement rule to the second request to identify a second action item, the second action item requiring the organization to perform a second action to execute the second action item; and

determining that the first action with respect to the first set of data is the same as the second action with respect to the second set of data.

13. A method for determining requirements for moving data from one or more jurisdictions, the method comprising:

receiving a request to move data, the request comprising (a) a data type, (b) a jurisdiction from which the data is to be moved, and (c) a purpose for moving the data;

identifying a set of data movement rules based at least in part upon the request, wherein the set of data movement rules are associated with regulations of the jurisdiction identified in the request; and

applying at least one rule of the set of data movement rules to identify an action item to be completed in order to comply at least in part with the regulations.

14. The method ofclaim 13, wherein applying the at least one rule identifies a second data movement rule, the method further comprising applying the second data movement rule to identify a second action item.

15. The method ofclaim 13, further comprising generating a response to the request, wherein the response to the request is one of an approval to move the data, a disapproval to move the data, and an approval conditional on completion of the action item.

16. The method ofclaim 13, further comprising:

storing information regarding the request and the action item; and

updating the stored information in response to execution of the action item.

17. The method ofclaim 13, further comprising:

storing the identified set of data movement rules;

storing an identification of the regulations associated with the identified set of data movement rules; and

storing copies of documents created during execution of the action item.

18. The method ofclaim 13, wherein the request comprises a first request, the action item comprises a first action item, and the data comprises a first set of data, wherein the organization performed a first action to execute the first action item, the method further comprising:

recording the first request and the first action item;

receiving a second request to move a second set of data out of the first jurisdiction;

applying the at least one data movement rule to the second request to identify a second action item, the second action item requiring the organization to perform a second action to execute the second action item; and

determining that the first action with respect to the first set of data is the same as the second action with respect to the second set of data.

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