Library · Travel & housing – master data in detail

DAT-080 · Collect and document consents, and process withdrawals

Creates and documents the legal basis for all processing not already covered by the contract, and turns withdrawal into a working process instead of…

Travel & housing · master data

Overview

Who it's for

Coordination, assistance, office

Trigger

Collection of special categories (DAT-050), use of a channel requiring separate consent (COM-060), ID data collection (DAT-030), or introduction of a new processing purpose.

You get

Creates and documents the legal basis for all processing not already covered by the contract, and turns withdrawal into a working process instead of a line in the privacy notice.

Status: Concept – not built yet

Creates and documents the legal basis for all processing not already covered by the contract, and turns withdrawal into a working process instead of a line in the privacy notice.

Trigger: Collection of special categories (DAT-050), use of a channel requiring separate consent (COM-060), ID data collection (DAT-030), or introduction of a new processing purpose.

1Determinepurposes thatrequire consentand those coveredDSB2Query consentseparately andgranularly perpurpose, no3Store consentwith textversion,timestamp, and4Technically blockprocessingwithout consent5Acceptwithdrawal,informally andthrough anyTHK6Assess theconsequences ofwithdrawal:ongoing bookings,THK7Trigger deletionand flag removal,send confirmationto the person8When the textversion changes,check whetherre-consent isDSB

Rule (automatable) Judgment (human decides)

Decision rules

  • R1 IF processing is required for contract fulfillment THEN don't obtain consent, but document Art. 6(1)(b) GDPR; an unnecessary consent creates a right of withdrawal that makes the process needlessly vulnerable.
  • R2 IF multiple purposes are affected THEN obtain separate consent per purpose; a bundled consent counts as not given.
  • R3 IF no consent exists for a purpose THEN the related processing is technically blocked and the person faces no disadvantages for travel or accommodation beyond the missing special service.
  • R4 IF a withdrawal is received THEN block immediately, delete within 72 h, review per R5; the lawfulness of processing up to the withdrawal remains unaffected.
  • R5 IF a data transfer already made to HOT or RDL is affected THEN request the recipient to delete it and log the request; if the booking cannot be carried out without the information, check an alternative according to CHG-020.
  • R6 IF {{EINWILLIGUNG_TEXTVERSION}} changes in substance (not just editorially) THEN obtain new consent for all affected persons.

Common pitfalls

1. A bundled consent covers diet, passport data, and messenger use in one sentence → it doesn't hold up for any of the purposes, and the first withdrawal cancels all three. 2. Withdrawal is sent via messenger to one individual and never entered into the system → processing continues even though the basis no longer applies. 3. Consent is obtained for processing already covered by the contract → unnecessary withdrawal risk for data that's mandatory. 4. Text version is changed without tracking → for existing records, it's no longer provable which text was agreed to.

Impact H × effort M → Do-first · HITL · RACI **R** THK · **A** PL · **C** DSB, LEG · **I** REI, PBH · Manual effort: Estimate: 2 min per person for digital surveys; 30–90 min per withdrawal case with data already shared

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