# US 2021/0344720 A1 · Data processing systems and methods for performing privacy assessments and monitoring of new versions of computer code for privacy compliance

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- Number: US 2021/0344720 A1
- Document ID: US20210344720A1
- Status: Published application
- Kind: A1
- Application number: 17/334,948
- Filed: 2021-05-31
- Published: 2021-11-04
- Earliest claimed: 2016-06-10
- Assignees: OneTrust, LLC
- Applicants: OneTrust, LLC
- Inventors: Kabir A. Barday; Mihir S. Karanjkar; Steven W. Finch; Ken A. Browne; Nathan W. Heard; Aakash H. Patel; Jason L. Sabourin; Richard L. Daniel; Dylan D. Patton-Kuhl; Jonathan Blake Brannon
- Web page: https://patentgrep.com/patent/US20210344720A1

## CPC

- G06Q 10/0635: Risk analysis of enterprise or organisation activities
- H04L 63/20: {for managing network security; network security policies in general (filtering policies H04L63/0227)}
- G06Q 10/06: Resources, workflows, human or project management; Enterprise or organisation planning; Enterprise or organisation modelling
- G06Q 10/10: Office automation; Time management
- H04L 63/04: {for providing a confidential data exchange among entities communicating through data packet networks}
- H04L 63/0414: {during transmission, i.e. party's identity is protected against eavesdropping, e.g. by using temporary identifiers, but is known to the other party or parties involved in the communication}
- H04L 63/1433: {Vulnerability analysis}
- G06Q: INFORMATION AND COMMUNICATION TECHNOLOGY [ICT] SPECIALLY ADAPTED FOR ADMINISTRATIVE, COMMERCIAL, FINANCIAL, MANAGERIAL OR SUPERVISORY PURPOSES; SYSTEMS OR METHODS SPECIALLY ADAPTED FOR ADMINISTRATIVE, COMMERCIAL, FINANCIAL, MANAGERIAL OR SUPERVISORY PURPOSES, NOT OTHERWISE PROVIDED FOR
- H04L: TRANSMISSION OF DIGITAL INFORMATION, e.g. TELEGRAPHIC COMMUNICATION (arrangements common to telegraphic and telephonic communication H04M)

## Abstract

In various embodiments, a data map generation system is configured to receive a request to generate a privacy-related data map for particular computer code, and, at least partially in response to the request, determine a location of the particular computer code, automatically obtain the particular computer code based on the determined location, and analyze the particular computer code to determine privacy-related attributes of the particular computer code, where the privacy-related attributes indicate types of personal information that the particular computer code collects or accesses. The system may be further configured to generate and display a data map of the privacy-related attributes to a user.

## Claims

### Claim 1

A method comprising:
monitoring, by computing hardware, a location where computer code is located;
identifying, by the computing hardware, a new instance of the computer code at the location;
comparing, by the computing hardware, the new instance of the computer code with a previous instance of the computer code to identify a change has been made to the computer code;
responsive to identifying the change, analyzing, by the computing hardware, the new instance of the computer code to determine a privacy-related attribute of the new instance of the computer code, the privacy-related attribute indicating a type of personal information that the new instance of the computer code at least one of collects or accesses;
modifying, by the computing hardware, a data map representing processing of the personal information to reflect the privacy-related attribute identified for the new instance of the computer code; and
providing, by the computing hardware, the data map for display to a user.

### Claim 2 (depends on 1)

The method of claim 1, wherein analyzing the new instance of the computer code to determine the privacy-related attribute comprises detecting use by the computer code of at least one of a location-based capability to detect a location of a user computing device, an encryption capability, a call to third party computer code, a communication log, or a cookie to track user behavior.

### Claim 3 (depends on 1)

The method of claim 1, wherein the computer code is associated with a website and identifying the new instance of the computer code involves identifying a change in information displayed on the website.

### Claim 4 (depends on 3)

The method of claim 3, wherein the change in information comprises at least one of a change made to a privacy policy displayed on the website or a change in a location of a link to the privacy policy.

### Claim 5 (depends on 1)

The method of claim 1, wherein the computer code is an application and identifying the new instance of the computer code involves identifying a new version of the application is available at the location.

### Claim 6 (depends on 1)

The method of claim 1, wherein modifying the data map to reflect the privacy-related attribute comprises modifying the data map to identify a storage location for the type of personal information that the new instance of the computer code at least one of collects or accesses.

### Claim 7 (depends on 1)

The method of claim 1, wherein the data map is associated with a privacy campaign and providing the data map for display to the user comprises providing a visual representation of the privacy campaign that includes the type of personal information that the new instance of the computer code at least one of collects or accesses.

### Claim 8

A system comprising:
a non-transitory computer-readable medium storing instructions; and
a processing device communicatively coupled to the non-transitory computer-readable medium,
wherein, the processing device is configured to execute the instructions and thereby perform operations, upon a new instance of a computer code being identified at a location being monitored where the computer code is located, comprising:
comparing the new instance of the computer code with a previous instance of the computer code to identify a change has been made to the computer code;
responsive to identifying the change, analyzing the new instance of the computer code to determine a privacy-related attribute of the new instance of the computer code, the privacy-related attribute indicating a type of personal information that the new instance of the computer code at least one of collects or accesses;
modifying a data map representing processing of the personal information to reflect the privacy-related attribute identified for the new instance of the computer code; and
providing the data map for display to a user.

### Claim 9 (depends on 8)

The system of claim 8, wherein analyzing the new instance of the computer code to determine the privacy-related attribute comprises detecting use by the computer code of at least one of a location-based capability to detect a location of a user computing device, an encryption capability, a call to third party computer code, a communication log, or a cookie to track user behavior.

### Claim 10 (depends on 8)

The system of claim 8, wherein the privacy-related attribute represents at least one of a storage location of the type of personal information or an access permission of the type of personal information.

### Claim 11 (depends on 8)

The system of claim 8, wherein the computer code is associated with a website and identifying the new instance of the computer code involves identifying at least one of a change made to a privacy policy displayed on the website or a change in a location of a link to the privacy policy.

### Claim 12 (depends on 8)

The system of claim 8, wherein modifying the data map to reflect the privacy-related attribute comprises modifying the data map to identify a storage location for the type of personal information that the new instance of the computer code at least one of collects or accesses.

### Claim 13 (depends on 8)

The system of claim 8, wherein the data map is associated with a privacy campaign and providing the data map for display to the user comprises providing a visual representation of the privacy campaign that includes the type of personal information that the new instance of the computer code at least one of collects or accesses.

### Claim 14

A non-transitory computer-readable medium storing computer-executable instructions that, when executed by processing hardware, configure the processing hardware to perform operations, upon a new instance of a computer code being identified at a location being monitored where the computer code is located, comprising:
comparing the new instance of the computer code with a previous instance of the computer code to identify a change has been made to the computer code;
responsive to identifying the change, analyzing the new instance of the computer code to determine a privacy-related attribute of the new instance of the computer code, the privacy-related attribute indicating a type of personal information that the new instance of the computer code at least one of collects or accesses; and
modifying a data map representing processing of the personal information to reflect the privacy-related attribute identified for the new instance of the computer code, wherein the data map is provided for display to a user.

### Claim 15 (depends on 14)

The non-transitory computer-readable medium of claim 14, wherein analyzing the new instance of the computer code to determine the privacy-related attribute comprises detecting use by the computer code of at least one of a location-based capability to detect a location of a user computing device, an encryption capability, a call to third party computer code, a communication log, or a cookie to track user behavior.

### Claim 16 (depends on 14)

The non-transitory computer-readable medium of claim 14, wherein the privacy-related attribute represents at least one of a storage location of the type of personal information or an access permission of the type of personal information.

### Claim 17 (depends on 14)

The non-transitory computer-readable medium of claim 14, wherein the computer code is associated with a website and identifying the new instance of the computer code involves identifying at least one of a change made to a privacy policy displayed on the website or a change in a location of a link to the privacy policy.

### Claim 18 (depends on 14)

The non-transitory computer-readable medium of claim 14, wherein modifying the data map to reflect the privacy-related attribute comprises modifying the data map to identify a storage location for the type of personal information that the new instance of the computer code at least one of collects or accesses.

### Claim 19 (depends on 14)

The non-transitory computer-readable medium of claim 14, wherein the data map is associated with a privacy campaign and providing the data map for display to the user comprises providing a visual representation of the privacy campaign that includes the type of personal information that the new instance of the computer code at least one of collects or accesses.

### Claim 20

A system, wherein upon a new instance of a computer code being identified at a location being monitored where the computer code is located comprises:
means for comparing the new instance of the computer code with a previous instance of the computer code to identify a change has been made to the computer code; and
responsive to identifying the change, means for analyzing the new instance of the computer code to determine a privacy-related attribute of the new instance of the computer code, wherein the privacy-related attribute indicates a type of personal information that the new instance of the computer code at least one of collects or accesses and a data map representing processing of the personal information is modified to reflect the privacy-related attribute identified for the new instance of the computer code to be provided for display to a user.
