Chapter 6 — Privacy and data protection: system model
Lesson map
Lesson 06 published. Map, example, EX021.
flowchart TD
N0["Learning outcomes"]
N1["6.1 Purposes and systems"]
N2["6.2 Lawful bases and conditions"]
N3["6.3 Recipients"]
N4["6.4 Transfers"]
N0 --> N1 --> N2 --> N3 --> N4
N4 --> EX["Worked example"]
EX --> Q["Exercise EX021"]
Logical drawing
flowchart LR
N0["Learning outcomes"]
N1["6.1 Purposes and systems"]
N2["6.2 Lawful bases and conditions"]
N3["6.3 Recipients"]
N4["6.4 Transfers"]
N0 --> N1 --> N2 --> N3 --> N4 --> Q["EX021"]
[Learning outcomes]
|
v
[6.1 Purposes and systems]
|
v
[6.2 Lawful bases and conditions]
|
v
[6.3 Recipients]
|
v
[6.4 Transfers]
|
v
[Worked example] --> [Exercise EX021]
Learning outcomes
You will (1) model processing activities technically; (2) link systems to purposes and lawful bases; (3) identify recipients and transfers.
6.1 Purposes and systems
Leila turns her service map into a processing model. Each purpose, such as providing dental care, booking appointments, sending reminders, billing and staff payroll, is linked to the systems that support it. Providing care uses the practice-management system and imaging servers. Reminders use the practice-management system and the SMS gateway. She notes that the GDPR's record of processing under Article 30 is organised by purpose, so a technical model built the same way can feed the record directly. Payroll uses only the external payroll service.
6.2 Lawful bases and conditions
With the data protection officer, Leila notes the lawful basis for each purpose. Care relies on the provision of health care, with Article 9(2)(h) as the condition for health data. Billing relies on contract and legal obligation. Reminders rely on legitimate interests, with an easy opt-out. Marketing of whitening offers requires consent. Leila's role is not to decide these, but her model shows which systems process data for each basis, so that a change in one place does not silently alter another.
6.3 Recipients
The model lists recipients: the practice-management vendor and SMS gateway as processors, the dental laboratory receiving impressions and prescriptions, specialist referral clinics and the payroll provider. Each processor needs a contract under Article 28. Leila checks that contracts exist and finds none for a small courier company that carries printed lab prescriptions with patient names. She flags this for the operations director, noting that paper flows are part of the system model even though no software is involved. Paper still carries patient names across town.
6.4 Transfers
Leila asks each vendor where data are stored. The practice-management system hosts data in the EU. The SMS gateway routes messages through a provider whose support team is in another country outside the EU. She records this as a possible transfer that needs safeguards under Chapter V of the GDPR and passes it to the data protection officer. Mr. Okafor reminds her that technical staff often discover transfers first, because they see network destinations and support arrangements. Her note lists the vendor's support location.
Worked example
Leila links purposes to systems, records lawful bases with the data protection officer, lists recipients, finds a courier without a contract and flags an SMS support transfer outside the EU.
Synthetic case. The model is synthetic; GDPR Articles 9(2)(h), 28 and 30 and Chapter V are real.
Errors and limits
Lawful bases are decided by the controller with advice; technical staff document them.
Exercises
- EX021 — Model structure. How is Leila's processing model organised? Rubric: 3 = by purpose, like the Article 30 record;; 2 = mentions purpose;; 1 = systems only;; 0 = none.
- EX022 — Care condition. Which Article 9 condition supports care? Rubric: 3 = Article 9(2)(h);; 2 = partly correct;; 1 = consent;; 0 = none.
- EX023 — Courier gap. What gap did Leila find with the courier? Rubric: 3 = no processor contract;; 2 = partly correct;; 1 = vague;; 0 = none.
- EX024 — Possible transfer. What possible transfer did Leila flag? Rubric: 3 = SMS provider support outside the EU;; 2 = partly correct;; 1 = vague;; 0 = none.
Continue studying — lesson 06 (chapter 06 of 18)
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