- France 2019 – The French Data Protection Authority (CNIL) fined Google €50 million for an alleged violation of GDPR.
- EU 2019: Marriott International faced a GDPR-related fine of £99 million from the ICO in 2019.
- Germany 2020: H&M was fined €35.3 million by the Hamburg Data Protection Authority for data protection breaches.
- Luxemburg 2021: Amazon was hit with a record-breaking GDPR fine of €746 million by the Luxembourg National Commission for being non-compliant on Data Protection (CNPD).
Can you guess the common factor among all these instances of GDPR non-compliance?
Each is a leading name in its space, with all the resources required to ensure compliance.
On May 25, 2018, GDPR introduced stricter regulations on protecting personal data and the privacy rights of individuals within the EU. Organizations worldwide, regardless of industry and location, that process, store, and collect personal data of individuals within the EU need to become GDPR compliant if they are to build their presence in the EU.
In this blog post, we will discuss how GDPR impacts software testing, the additional challenges that testers face and how to overcome them smoothly while remaining GDPR compliant.
GDPR compliance requires testing teams to prioritize data protection, privacy, and the rights of data subjects consistently across the testing lifecycle. It primarily comes down to making the following elaborate tweaks to your testing approach:
Thorough Awareness of GDPR Compliance
GDPR compliance begins with a detailed understanding of its principles and requirements. While training and awareness programs help teams, keeping up with the nuances requires implementing a standard approach to user data across the testing lifecycle and strong collaboration for fostering knowledge sharing. Herein lies the first and most critical challenge for your testing teams, especially when they are part of agile software development processes.
Challenge #1: Maintaining a close collaboration with stakeholders to ensure a shared understanding of GDPR requirements and implications is tough, especially when there is a lack of standard frameworks for cross-functional knowledge and best practices sharing!
Solution: Robust test automation frameworks, including detailed guidelines for GDPR compliance across STLC and reusable test scripts and libraries, enable seamless knowledge transfer and consistent GDPR compliance measures across the board. This also ensures that testers spend more time focusing on all the more critical aspects of testing rather than keeping track of the changes in GDPR.
Alternatives to Real User Data for Testing
Testers need realistic test data to simulate real-world scenarios for exhaustive testing of the software functionalities. But GDPR mandates minimizing the use of real personal data.
Alternatives your team might employ masking data, anonymizing/ pseudonymizing real data or generating synthetic data. But each of these approaches comes with its own set of challenges. Herein lies the second challenge that your testing teams face while becoming GDPR compliant
Challenge #2: Using test data that perfectly balances realism and data protection can be a multi-pronged challenge.
– Masking/anonymizing data becomes problematic when the data set is extensive and involves multiple variables
– A considerable amount of testing bandwidth is spent on generating synthetic data
– Both the above alternatives, when done manually, are prone to errors and misleading assumptions
Solution: Whether you are keen on masking user data or generating synthetic test data, automating the process and feeding it with all the relevant GDPR requirements not only makes it faster but also frees up testing bandwidth and the resulting data is more accurate, closer to real-world scenarios and well aligned with GDPR mandates.
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Securing the Test Environment
Test environments often contain copies of production data for testing purposes. Hence, GDPR requires you to secure these environments to prevent unauthorized access and potential data breaches. Typically, you employ measures like appropriate access controls, encryption, and continuous monitoring of test environments to ensure user data protection while maintaining their relevance and integrity. However, add to this the increasing scale and complexity of large test environments, and you will know the next challenge that your testers face:
Challenge #3: Keeping the test environment secure requires additional bandwidth and expertise in security compliance to ensure appropriate access controls, standard security configurations and necessary data privacy and protection.
Solution: Configuring and maintaining secure test environments with test automation helps in minimizing manual errors, build execution, reduce false positives, and improve efficiency in test coverage and execution.
Keeping the User Data Secure, No Matter What
GDPR mandates that whenever user data is involved, it must be dealt with the utmost responsibility to ensure data protection and privacy. So, whether your team employs user data for testing functionalities or needs to do cross-border data transfer across systems, environments or third-party services, ensuring proper safeguards such as data transfer agreements, Standard Contractual Clauses, or encryption protocols is essential to compliance.
GDPR also requires you to have consistent policies in place for data retention and deletion. While doing all this due diligence is relatively linear for simpler testing processes, once your workflows start getting more complex and interconnected, your manual testers may find it overwhelming to keep track of all the user data compliance measures along with their core testing activities.
Challenge #4: Sheer volume of activities to ensure proper data retention and deletion compliance can get challenging to keep up once your product starts to scale.
Solution: Testing teams have managed this workflow more efficiently with test automation. Automating data retention and deletion activities based on predefined timelines and rules streamlines data management better, mitigates the scope of manual intervention and error, and results in improved accuracy, consistent implementation and greater conformity to GDPR.
Exhaustive Documentation for Complete Visibility
GDPR compliance necessitates thorough documentation and record-keeping for enhanced accountability and transparency. This includes maintaining detailed records of data processing activities, conducting data protection impact assessments, and documenting data breach incidents and responses. While these documentation requirements are essential for compliance, they may require additional time and effort from your testing team, potentially impacting their productivity.
Challenge #5: Due to a lack of a standard approach to documentation, there is always a scope of incoherence and misses in the testing documentation of the testing practices.
Solution: Test automation frameworks often provide custom dashboards and exhaustive reporting capabilities, which you can utilize to generate comprehensive documentation and audit trails of testing activities. These automated reports are robust evidence of compliance, facilitating audits and assessments and providing detailed STLC visibility to all stakeholders.
GDPR compliance and non-compliance have fairly straightforward consequences. Complexities step in on your journey towards becoming GDPR compliant. So, if you are a tech-led firm aiming to grow your footprints globally and rethinking your testing approach for GDPR compliance, ensure you look at the nuances involved at each step.
The devil is in the details!