Background

Pilatus Aircraft Ltd., a leading manufacturer of aircraft, recognized the growing importance of data protection in its operations. With a global presence and a diverse range of data processing activities, Pilatus needed to ensure compliance with data protection regulations such as the General Data Protection Regulation (GDPR) and the Swiss Federal Act on Data Protection (FADP). To address this need, Pilatus engaged Priverion to provide a dedicated Data Protection Officer (DPO) and support the implementation of comprehensive data protection measures using the Priverion Data Protection Management System (DPMS), a Software-as-a-Service (SaaS) solution.

Challenges

1. Complex Data Processing Activities: Pilatus handles vast amounts of personal data, including employee records, customer information, supplier details, and data from connected aircraft. Ensuring all processing activities comply with GDPR and FADP requirements was a significant challenge.

2. Vendor Management: Pilatus collaborates with numerous vendors who process personal data on their behalf. Ensuring that all data processing agreements (DPAs) with these vendors met regulatory standards was critical.

3. Connected Aircraft Data: Pilatus's aircraft are equipped with advanced sensors and connectivity features that collect and transmit operational data. Managing the privacy and security of this connected aircraft data, which may include personal data, added another layer of complexity.

4. Lack of Comprehensive Documentation: Pilatus needed a systematic approach to document and map their data processing activities, which is essential for accountability and transparency under GDPR and FADP.

Solutions Implemented

1. Priverion Data Protection Management System (DPMS): The Priverion DPMS was deployed to streamline data protection processes and ensure ongoing compliance. This SaaS solution provided:

• A centralized platform for managing all data protection activities.
• Automated tools for maintaining and updating the RoPA.
• Real-time monitoring and alerts for data protection compliance.

2. Creation of the Record of Processing Activities (RoPA): Priverion's DPO led the effort to create a detailed RoPA using the DPMS. This involved:

• Identifying all processing activities within Pilatus.
• Documenting the purpose, categories of data subjects, categories of personal data, data recipients, and retention periods for each activity.
• Ensuring the RoPA was continuously updated and easily accessible for audits and reviews.

3. Process Mapping: Priverion conducted comprehensive process mapping to gain a clear understanding of how data flows within Pilatus. This included:

• Mapping out data collection, storage, usage, and sharing processes.

• Identifying potential risks and areas where data protection measures needed to be strengthened.
• Implementing appropriate technical and organizational measures to mitigate identified risks.

4. Review of Data Processing Agreements (DPAs): Priverion reviewed and revised all existing DPAs with Pilatus’s vendors to ensure compliance with GDPR and FADP. This process involved:

• Assessing the data protection measures of each vendor.
• Updating DPAs to include necessary clauses on data protection, breach notification, and data subject rights.
• Establishing a framework for ongoing monitoring and review of vendor compliance.

5. Managing Connected Aircraft Data: Priverion addressed the unique challenges of processing connected aircraft data by:

• Ensuring that the collection and transmission of operational data from aircraft comply with GDPR and FADP.
• Implementing robust encryption and anonymization techniques to protect personal data.
• Establishing clear data retention policies and ensuring that only necessary data is retained for the required period.
• Providing transparency to customers about the types of data collected, the purposes of data processing, and their rights concerning this data.

Benefits Achieved

1. Enhanced Compliance: By having a structured and updated RoPA and leveraging the Priverion DPMS, Pilatus significantly improved its compliance with GDPR, FADP, and other relevant data protection regulations. This documentation provided a clear overview of data processing activities, aiding in audits and regulatory reviews.

2. Improved Data Governance: The process mapping exercise helped Pilatus gain a thorough understanding of their data flows, enabling them to implement more effective data protection measures. This proactive approach reduced the risk of data breaches and non-compliance.

3. Stronger Vendor Relationships: The review and revision of DPAs ensured that all vendors processing data on behalf of Pilatus adhered to the same high standards of data protection. This not only mitigated risks but also strengthened trust and collaboration with vendors.

4. Secure Management of Connected Aircraft Data: By addressing the specific challenges of connected aircraft data, Pilatus ensured that sensitive operational and personal data transmitted from their aircraft was secure. This increased the trust of customers and stakeholders in Pilatus's data management practices.

5. Operational Efficiency: With a dedicated DPO from Priverion and the use of the DPMS, Pilatus benefited from expert guidance and oversight on all data protection matters. This allowed internal teams to focus on core business activities while ensuring that data protection was managed by a specialist.

6. Streamlined Processes and Ongoing Compliance: The Priverion DPMS provided automated tools and real-time monitoring, streamlining data protection processes and ensuring ongoing compliance with data protection regulations.

7. Reputation and Trust: Demonstrating a commitment to data protection enhanced Pilatus's reputation among customers, partners, and regulators. Trust in Pilatus's ability to safeguard personal data was strengthened, providing a competitive advantage in the market.

Conclusion

The partnership between Pilatus Aircraft Ltd. and Priverion exemplifies the positive impact of having a dedicated Data Protection Officer and a robust Data Protection Management System. Through the creation of the Record of Processing Activities, process mapping, meticulous review of data processing agreements, and secure management of connected aircraft data, Priverion enabled Pilatus to achieve enhanced compliance, improved data governance, and stronger vendor relationships. This case study highlights the crucial role of expert data protection services and advanced SaaS solutions in safeguarding personal data and maintaining regulatory compliance in a complex and dynamic industry.