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ServiceNow and GDPR Compliance: Ensuring Data Privacy

Reco Security Experts
June 26, 2024
June 26, 2024

What is “GDPR”?

In the digital age, where information flows freely across borders, safeguarding personal data has become a paramount concern. The General Data Protection Regulation (GDPR) stands as a cornerstone in the European Union's (EU) efforts to fortify and streamline data protection measures for its citizens. Enforced by the European Commission, GDPR (Regulation (EU) 2016/679) aims to establish uniform standards for data protection across EU member states, ensuring greater transparency, accountability, and control over personal data.

Key Components of GDPR

GDPR introduces several pivotal changes to data protection regulations, marking a significant departure from its predecessors:

  • Unified Data Breach Notification: One prominent feature of GDPR is the mandatory requirement that organizations report data breaches within 72 hours of their occurrence. This swift notification empowers individuals to take necessary actions to mitigate potential risks to their privacy and security.
  • Regulation vs. Directive: Unlike its predecessor, GDPR is a regulation rather than a directive. This distinction means that GDPR is directly applicable across all EU member states without the need for additional national legislation.
  • Mandatory Data Protection Officer (DPO): GDPR mandates the appointment of a DPO in most organizations to oversee compliance with data protection regulations and ensure a proactive approach to safeguarding personal data.
  • Applicability to All Organizations: GDPR applies to all organizations operating within the EU, irrespective of their size or location. This broad scope ensures comprehensive protection for EU citizen's personal data.
  • Privacy by Design: GDPR emphasizes the integration of privacy measures into the design and implementation of systems and processes, fostering a culture of privacy and data protection from the outset.
  • One-Stop Shop: Introducing the concept of a one-stop shop, GDPR streamlines regulatory processes by providing a single set of rules applicable to all EU member states, facilitating smoother compliance for multinational organizations.

ServiceNow and GRC

Import GDPR Requirements and Description

ServiceNow provides some out-of-the-box content but also integrates with the Unified Compliance Framework (UCF). UCF provides over 800 authority documents, including GDPR. A license to import the GDPR content from the UCF Common Controls Hub is required. ServiceNow GRC can then map the identified GDPR requirements directly into the application, with underlying citations and controls needed for compliance checks and continuous monitoring.

Policy Management

There are many organizational policies associated with the GDPR requirements - existing ones may need to be aligned while others are developed. Some policy examples include data protection, security, and code of conduct policies. ServiceNow GRC full policy lifecycle management includes drafting a policy according to requirements through review, approval, publishing (to a knowledge base), and retirement stages. A policy can include the GDPR requirements in the description, and it is designed to align with them.

The vendor compliance status on regulatory requirements is reported on the Policy and Compliance dashboard. The controls status is automatically updated, while issues are automatically created and assigned to the responsible party. Progress is tracked to remediation.

Data Protection Impact Assessments (DPIAs)

DPIAs are required to assess processing operations that result in a high risk to data subjects. Within ServiceNow GRC, data protection assessments can be aligned with data protection policies and underlying requirements. The internal Assessment Design can be used to create the assessments, which can then be scheduled. The compliance status is reported on the Policy and Compliance dashboard. The controls status is automatically updated, while issues are automatically created and assigned to the responsible party. Progress is tracked to remediation. Vendor/Third Party Risk assessments can be managed through the Vendor Risk Management application and the vendor portal.

Risk Evaluation and Management Requirements

GDPR requires organizations to evaluate and manage data protection risks appropriately. The Risk Management application supports a full risk management lifecycle process. Risk identification and compliance statistics can be made transparent, and a notification can be sent automatically or manually to a Supervisory Authority (SA) at the time of a breach with the associated risks. Data processing on the information layer with personal data can be implemented. Pseudonymizing and encryption functionalities from ServiceNow help address compliance requirements. Finally, ServiceNow GRC provides controls to check the confidentiality, integrity, and availability of systems and applications.

Audit Requirements

ServiceNow Policy & Compliance and Audit Workbench dashboards provide the ability to monitor the global level of compliance with the GDPR. Audits can be scheduled targeting the organization and its personal data-sensitive systems — tracking any corrective actions to a conclusion.

Data Subject Requirements

Data subjects have specific rights over the processing of personal data. You can utilize the ServiceNow Customer Service Management, Vendor Risk Management, and Service Portal to interact with data subjects (e.g., customers, staff, third parties, or contacts), as well as for content, PII amendments, policy announcements, guidelines, etc.

Personal Data Asset Requirements

Protecting personal data or information requires the ability to attest to controls, assess risks, and perform audit assurance for the information assets and the systems supporting them. ServiceNow GRC is unique in that it's built on the Now platform, which includes a built-in Configuration Management Database (CMDB) to manage information assets and associate them with other Configuration Items (CIs). A few of the capabilities to fulfill personal data asset requirements are managing risks, continuous control monitoring, and data protection impact assessments on information assets as well as on business services or IT CIs.

72-Hour Breach Notification

If a breach has put personal data at risk, the Supervisory Authority must be notified within 72 hours with details and an outlined response to the breach. Security Incident Response works together with GRC and workflows in the platform to ensure the necessary information is available and communicated effectively.

Managing Third-Party GDPR Compliance

Vendor Risk Management provides the means to help you appropriately assess your 3rd-parties to ensure they are implementing the appropriate technical and organizational measures to protect the personal data you make available to them. Vendor Risk uses the unique Vendor Portal to consolidate communication and facilitate collaboration.

Data Protection Officer (DPO) Dashboard

The DPO is the individual in the organization responsible for ensuring compliance and immediately reporting breaches. ServiceNow Performance Analytics and the Service Portal offer the ability to create dashboards specific to your role and responsibility in a matter of minutes so that information like incidents by location, risk scores, and GDPR compliance is at your fingertips.

Best Practices for IT Admins Using ServiceNow for GDPR Compliance

To effectively leverage ServiceNow for GDPR Compliance, IT admins should consider the following best practices:

  • Define Clear Policies: Establish clear policies and procedures for data handling and governance within ServiceNow, aligning them with GDPR requirements.
  • Implement Access Controls: Enforce access controls within ServiceNow to ensure that only authorized personnel can access and manipulate personal data.
  • Regular Audits and Assessments: Conduct regular audits and assessments of data processing activities within ServiceNow to identify and address compliance gaps.
  • Provide Training and Awareness: Educate employees on GDPR requirements and the proper use of ServiceNow to ensure compliance throughout the organization.
  • Stay Informed: Stay updated on changes to GDPR regulations and ServiceNow features, ensuring that your compliance measures remain effective and up to date.


The General Data Protection Regulation across the EU sets up a high standard for data protection, focusing on transparency, accountability, and individual rights. ServiceNow Governance, Risk, and Compliance solutions help organizations comply with GDPR by providing management capabilities in the form of policy management, risk evaluation, audit capabilities, and real-time compliance monitoring. IT administrators can provide better compliance by providing a clear definition of policies, implementation of access controls, regular audits, and awareness of changes in the regulation. Using ServiceNow GRC will help an organization adhere to the requirements of GDPR and foster a culture of data protection.

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