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Registrants have the same rights to their personal data, no matter in what form we store them. We need to be able to communicate processing and provide data subjects with access to personal data, whether on paper, in local files or in data systems.

We separately document personal data that is stored outside of data systems.

A large amount of valuable information in an organization has often accumulated over time into hard-to-find and manageable unstructured data — excels, text documents, intranet pages, or emails.

Once this information has been identified, a determined effort can be made to minimize its amount.Important data outside data systems is subject to one of the following decisions:

• move into a data system
• get rid of (when the information is old, no longer necessary or otherwise irrelevant)
• is kept in use and a responsible person is appointed to manage the risks