Marcus Belke
CEO of 2B Advice GmbH, driving innovation in privacy compliance and risk management and leading the development of Ailance, the next-generation compliance platform.
In operational data protection practice, a communication medium is still predominantly used that was not originally designed for structured governance processes: email. What began as a flexible and low-threshold tool for exchange has developed into a central vehicle for data protection-relevant processes in many organizations - with considerable legal and organizational consequences. Particularly in the context of accountability pursuant to Art. 5 para. 2 GDPR and the general organizational duties pursuant to Art. 24 GDPR it becomes clear that e-mail as a primary control instrument has structural deficits.
E-mail as a governance problem
In practice, email is often used as a key management tool for data protection-related processes. Its apparent efficiency stems from its simplicity Availability and flexibility. However, it is precisely these characteristics that foster the emergence of informal processes that elude systematic control. Data protection issues are often addressed on a case-by-case basis via email, without any structured documentation or clear process management.
This kind of approach is in tension with the requirements of the GDPR. Accountability requires not only actions that comply with the rules, but also reliable evidence of these actions. Documentation. However, communication threads that are scattered across individual mailboxes and do not follow a uniform structure can only be incorporated into verifiable governance structures to a limited extent. As a result, it remains difficult to enforce reliable standards and consistent processes.
Added to this is the strong personal nature of email communication. Knowledge, responsibilities, and decision-making processes are often tied to individual email accounts. When employees are absent or responsibilities change, gaps arise that can only be addressed with considerable effort. This leads to losses in efficiency and increases the risk of erroneous or inconsistent decisions.
Lack of transparency with e-mail
Processing data protection-related matters via email makes it difficult to maintain an overview of the entire process. Inquiries, reports, and consultations are typically spread across multiple communication threads that run in parallel or are fragmented by forwarding. As a result, it is often difficult to determine the current status of a case.
This has significant implications for operational management. For example, it is not immediately clear which tasks are pending, nor is it possible to reliably determine the stage at which they are in the process. Responsibilities also often remain implicit. The result is an increased need for coordination, which ties up resources and slows down processing.
This deficit is particularly relevant with regard to legal deadlines. The timely processing of data subject rights in accordance with Art. 12 para. 3 GDPR and compliance with the reporting deadlines in the event of data breaches in accordance with Art. 33 GDPR require information to be available in full and in a timely manner. Fragmented email communication, on the other hand, increases the risk of delays and misjudgements.
Email Histories as an Audit Pitfall
While the Transparency the current status of a process, the question of retrospective traceability also arises. Here too, the structural weakness of email becomes apparent. As a rule, communication processes are not designed to systematically map decision-making processes. Relevant information is lost in long threads, intermediate steps remain unclear and parallel coordination leads to contradictory documentation statuses.
This becomes a particular problem during inspections and audits. Regulatory authorities expect a clear account of how decisions were reached and what measures were taken. Email threads typically do not provide a reliable basis for this. They are difficult to analyze, often incomplete, and only partially audit-proof.
The result is a de facto limitation on accountability. Without a structured Documentation It is only possible to demonstrate compliance with data protection requirements to a limited extent. This applies not only to individual cases but also to the effectiveness of the entire data protection management system. This increases the risk of regulatory objections.
Reading tip: The right audit preparation in data protection
Separate processes from email communication
Against this backdrop, a system-based approach is becoming increasingly important. The goal is to separate data protection-related processes from email communication and transfer them to specialized systems. Such systems enable the structured recording of processes, a clear assignment of responsibilities, and seamless Documentation of all relevant steps.
A system-based approach lays the groundwork for standardized workflows. Incoming requests or reports are centrally recorded, categorized, and processed according to defined procedures. Status information is available at any time. Deadlines can be monitored automatically. Decisions are consistently documented and can be traced in an audit-proof manner.
In addition, such a system facilitates integration into existing Compliance- and risk management structures. The Data protection is no longer managed in isolation through individual communication channels, but is viewed as an integral part of company-wide governance.
Collaboration Model for Role-Based Collaboration
In addition to the technical aspect, a tailored collaboration model is also necessary. Since data protection is a cross-functional role, various departments—such as IT, Legal, HR, and operational units—are involved. Coordination that relies primarily on email often leads to unclear responsibilities and inefficient communication structures.
In contrast, a system-supported collaboration model enables role-based collaboration. The participants work within a shared context and access only the information that is relevant to them. Communication takes place directly within the respective process and thus remains permanently traceable.
This approach helps speed up coordination processes and reduce information loss. At the same time, such a model promotes the establishment of clear responsibilities and standardized procedures. As a result, data protection is not only organized more efficiently but also becomes structurally more resilient.
Smart Solution: Ailance as a Central Process Model
The structural deficits of an email-based data protection organization described above can only be sustainably remedied in practice through a systematic approach. Ailance shows what this can look like in practice.
Ailance maps data protection-related processes into a centralized, system-supported process model. Inquiries, incidents, and audit processes are no longer managed through disparate communication channels but are handled according to clearly defined workflows. Responsibilities are clearly assigned, processing statuses are transparent at all times, and all actions are documented in an audit-proof manner.
Ailance develops your company's data protection from a reactive email process to a controllable component of corporate governance. We would be happy to show you exactly how this works in a demo.
In particular, we illustrate how Transparency of all ongoing processes, how decision-making processes remain transparent and how deadlines can be reliably met. At the same time, it becomes clear how cooperation between data protection, specialist departments and other stakeholders can be structured and efficient.
Marcus Belke is CEO of 2B Advice as well as a lawyer and IT expert for data protection and digital Compliance. He writes regularly about AI governance, GDPR-Compliance and risk management. You can learn more about him on his Author profile page.
Questions and Answers
Why is email only suitable to a limited extent for data protection processes?
Email was not designed for the structured management of data protection processes. Inquiries, decisions, and consultations are often scattered across different email accounts and communication threads. As a result, there is a lack of standardized process management, clear responsibilities, and a robust Documentation.
What risks arise from handling data protection matters via email?
With email-based processing, it is often unclear which tasks are still pending, who is responsible for the next step, and what stage the process is at. This increases the effort required for coordination and the risk that information will be lost or that decisions will be made inconsistently.
Why does email make it difficult to meet deadlines under data protection laws?
To process data subjects’ rights and data breaches in a timely manner, it is essential that incidents be fully documented and continuously monitored. If information is scattered across multiple email threads, deadlines may be overlooked, responsibilities may be misjudged, or necessary information may be compiled too late.
Why are email histories problematic during data protection audits?
Email threads typically do not systematically and auditable document decision-making processes. Relevant information can get lost in long email threads, while parallel discussions can lead to inconsistent documentation. This makes it difficult to provide regulatory authorities with a clear, traceable record of how decisions were reached and what actions were taken.
What are the benefits of system-supported data protection workflows?
System-supported workflows enable the centralized recording, categorization, and processing of data protection-related matters. Responsibilities can be clearly assigned, processing statuses can be displayed transparently, and deadlines can be monitored automatically. At the same time, decisions and actions remain permanently documented in a traceable manner.
How does Ailance help separate data protection processes from email communication?
Ailance integrates data protection-related inquiries, incidents, and audit processes into centralized, clearly defined workflows. The departments involved work within a shared process, responsibilities and processing statuses remain transparent, and all actions are documented in an audit-proof manner.
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