Showing posts with label CCPA. Show all posts
Showing posts with label CCPA. Show all posts

Friday, September 25, 2020

Software Review: Skypoint Cloud Combines CDP and Privacy Management

There are obvious similarities between Customer Data Platforms and privacy systems: both find customer data in all company systems; both assemble that data into unified profiles; and both govern access to those profiles. Indeed, some CDP vendors have expanded into privacy management by building consent modules to their systems or by integrating third-party consent managers.

Still, the line between CDP and privacy managers is usually clear: CDPs store customer data imported from other systems while privacy managers read the data in place. There might be a small gray area where the privacy system imports a little information to do identity matching or to build a map of what each source system contains. But it’s pretty easy to distinguish systems that build huge, detailed customer data sets from those that don’t. 

There’s an exception for every rule. Skypoint Cloud is a CDP that positions itself as a privacy system, including data mapping, consent management, and DSR (Data Subject Request) fulfillment. What makes it a CDP is that Skypoint ingests all customer data and builds its own profiles. Storing the data within the system actually makes fulfilling the privacy requirements easier, since Skypoint can provide customers with copies of their data by reading its own files and can ensure that data extracts contain only permitted information. Combining CDP and privacy in a single system also saves the duplicate effort of having two systems each map and read customer data in source systems.

The conceptual advantages of having one system for both CDP and privacy are obvious. But whether you’d want to use a combined system depends on how good it is at the functions themselves. This is really just an example of the general “suite vs best-of-breed” debate that applies across all systems types. 

You won’t be surprised that a young, small vendor like Skypoint lacks many refinements of more mature CDP systems. Most obviously, its scope is limited to ingesting data and assembling customer profiles, with just basic segmentation capabilities and no advanced analytics or personalization.  That’s only a problem if you want your CDP to include those features; many companies would rather use other tools for them anyway. There’s that “suite vs best-of-breed” choice again.

When it comes to assembling the unified database, Skypoint has a bit of a secret weapon: it relies heavily on Microsoft Azure Data Lake and Microsoft’s Common Data Model. Azure lets it scale effortlessly, avoiding one set of problems that often limit new products. Common Data Model lets Skypoint tap into an existing ecosystem of data connectors and applications, again saving Skypoint from developing those from scratch. Skypoint says they’re the only CDP vendor other than Microsoft itself to use the Common Data Model: so far as I know, that’s correct. (Microsoft, Adobe, SAP, and others are working on the Open Data Initiative that will map to the Common Data Model but we haven’t heard much about that recently.) 

How it works is this: Skypoint can pull in any raw data, using its own Web tag or other sources, and store it in the data lake. Users set up a data flow to ingest each source, using either the existing or custom-built connectors. The 200+ existing connectors cover most of the usual suspects, include Web analytics, ecommerce, CRM, marketing automation, personalization, chat, Data Management Platforms, email, mobile apps, data stores, and the big cloud platforms.

Each data flow maps the source data into data entities and relations, as defined in the Common Data Model or adjusted by the user. This is usually done before the data is loaded into the data lake but can also be done later to extract additional information from the raw input.  Skypoint applies machine learning to identify likely PII within source data and lets users then flag PII entities in the data map.  Users can also define SQL queries to create calculated values. 

Each flow has a privacy tab that lets the user specify which entities are returned by Data Subject Requests, whether data subjects can order the data erased, and which data processes use each entity. The data processes, which are defined separately, can include multiple entities with details about which entities are included and what consents are required. Users can set up different data processes for customers who are subject to different privacy regulations due to location or other reasons.

Once the data is available to the system, Skypoint can link records related to the same person using either rule-based (deterministic) matches or machine learning. It’s up to the client define her own matching rules. The system maintains its own persistent ID for each individual. Matches can be either incremental – only matching new inputs to existing IDs – or can rebuild the entire matching universe from scratch. Skypoint also supports real-time identity resolution through API calls from a Web tag.

After the matching is complete, the system merges its data into unified customer profiles. Skypoint provides a basic audience builder that lets users define selection conditions. This also leverages Skypoint's privacy features by first having users define the purpose of the audience and then making available only data entities that are permitted for that purpose. Users can also apply consent flags as variables within selection rules. Audiences can be connected with actions, which export data to other systems manually or through connectors.

Users can supplement the audience builder by creating their own apps with Microsoft Azure tools or let external systems access the data directly by connecting through the Common Data Model.

Back to privacy. Skypoint creates an online Privacy Center that lets customers consent to different uses of their data, make data access requests, and review company policy statements. It creates an internal queue of access requests and tracks their progress towards fulfillment. Users can specify information to be used in the privacy center, such as the privacy contact email and URLs of the policy statements. They can also create personalized email templates for privacy-related messages such as responses to access requests or requests to verify a requestor’s email address.

This is a nicely organized set of features that includes what most companies will need to meet privacy regulations. But the real value here is the integration with data management: gathering data for subject access requests is largely automated when data is mapped into the system through the data flows, a major improvement over the manual data assembly required by most privacy solutions. Similarly, the connection between data flows, audiences, and data processing definitions makes it easier to ensure the company uses only properly consented information. There are certainly gaps – in particular, data processes must be manually defined by users, so an undocumented process would be missed by the system. But that’s a fairly common approach among privacy products.

Pricing for Skypoint starts with a free version limited mostly to the privacy center, consent manager, and data access requests. Published pricing ranges past $2,000 per month for more than ten data integrations. The company was founded in 2019 and is just selling to its first clients.

Sunday, September 13, 2020

Software Review: Osano Manages Cookie Consent and Access Requests

The next stop on our privacy software tour is Osano, which bills itself as “the only privacy platform you’ll ever need”.  That's a bit of an overstatement: Osano is largely limited to data subject interactions, which is only one of the four primary privacy system functions I defined in my first post on this topic. . (The other three are: discovering personal data in company systems, defining policies for data use, and enforcing those policies.) But Osano handles the interactions quite well and adds several other functions that are unique. So it’s certainly worth knowing.

The two main types of data subject interactions are consent management and data subject access requests (DSARs). Osano offers structured, forms-based solutions to both of these, available in a Software-as-a-Service (Saas) model that lets users deploy them on Web sites with a single line of javascript or on Android and iOS mobile apps with an SDK.

The consent management solution provides a prebuilt interface that automatically adapts its dialog to local laws, using the geolocation to determine the site visitor's location.  There are versions for 40+ countries and 30+ languages, which Osano updates as local laws change. Because it is delivered as a SaaS platform, the changes made by Osano are automatically applied to its clients. This is a major time-saver for organizations that would otherwise need their own resources to monitor local laws and update their system to conform to changes.

Details will vary, but Osano generally lets Web visitors consent to or reject different cookie uses including essential, analytics, marketing, and personalization. Where required by laws like the California Consumer Protection Act (CCPA), it will also collect permission for data sharing. Osano stores these consents in a blockchain, which prevents anyone from tampering with them and provides legally-acceptable proof that consent was obtained. Osano retains only a hashed version of the visitor’s personal identifiers, thus avoiding the risk of a PII leak while still enabling users to search for consent on a known individual.

Osano’s use of blockchain to store consent records is unusual. Also unusual: Osano will search its client’s Website to check for first- and third-party cookies and scripts. The system will tentatively categorize these, let users confirm or change the classifications, and then let site visitors decide which cookies and scripts to allow or block. There’s an option to show visitors details about each cookie or script.

Osano also provides customer-facing forms to accept Data Subject Access Requests. The system backs these with an inventory of customer data, built by users who manually define systems, data elements, and system owners. Put another way: there’s no automated data discovery. The DSAR form collects the user’s information and then sends an authentication email to confirm they are who they claim.  Once the request is accepted, Osano sends notices to the owners of the related systems, specifying the data elements included and the action requested (review, change, delete, redact), and tracks the owners’ reports on completion of the required action. Osano doesn’t collect the data itself or make any changes in the source systems.

The one place where Osano does connect directly with source systems is through an API that tracks sharing of personal data with outside entities. This requires system users to embed an API call within each application or workflow that shares such data: again, there’s no automated discovery of such flows. Osano receives notification of data sharing as its happens, encrypts the personal identifiers, and stores it in a blockchain alone with event details. Users can search the blockchain for the encrypted identifiers to build a history of when each customer’s data was shared.

Perhaps the most unusual feature of Osano is the company’s database of privacy policies and related information for more than 11,000 companies. Osano gathers this data from public Web sites and has privacy attorneys review the contents and score each company on 163 data points.  This lets Osano rate firms based on the quality of their privacy processes. It runs Web spiders continuously check for changes and will adjust privacy ratings when appropriate. Osano also keeps watch on other information, such as data breach reports and lawsuits, which might also affect ratings. This lets Osano alert its clients if they are sharing data with a risky partner.

Osano is offered in a variety of configurations, ranging from free (cookie blocking only) to $199/month (cookie blocking and consent management for up to 50,000 monthly unique Web site visitors) to enterprise (all features, negotiated prices). The company was started in 2018 and says its free version is installed on more than 750,000 Web sites.