Definition
Data Subject Rights Management (DSRM) refers to the technical and organizational processes that enable individuals to exercise their rights under data protection laws, such as the EU General Data Protection Regulation (GDPR). These rights include access, rectification, erasure, restriction of processing, data portability, and objection. DSRM ensures that requests are authenticated, tracked, validated, and executed in a controlled and auditable manner.
In image and video anonymization workflows, DSRM addresses requests involving visual identifiers such as faces, license plates, silhouettes, or other biometric attributes, ensuring lawful and transparent processing of visual data.
Scope of data subject rights
Systems implementing DSRM must support the full set of rights outlined in GDPR Articles 12-22.
- Right of access - obtaining information about recordings containing the person’s image.
- Right to rectification - correcting associated metadata or classification errors.
- Right to erasure - deleting identifiable visual material.
- Right to restriction - halting specific uses of video data.
- Right to object - stopping use of video data for analytics or AI model training.
- The right to obtain a copy of data – the so-called 'data subject access request (DSAR)’. The data controller is obligated to provide a copy of the data (including photographs or video recordings). These do not have to be provided on the original medium.
Applications in image and video anonymization
DSRM is essential when video systems capture sensitive identifiable information. Effective management includes:
- Identifying all recordings containing a person’s face or vehicle.
- Applying anonymization or removal as part of the erasure workflow.
- Providing anonymized versions of footage when full deletion is not required.
- Restricting access to raw video using RBAC or PAM policies.
- Guaranteeing auditability of all actions related to data subject requests.
System components
Modern DSRM platforms combine automation with governance mechanisms. Typical components include:
- Identity verification module - ensures that only the correct person may request changes.
- Data catalog - maps storage locations for visual datasets.
- Anonymization engine - masks or removes identifiable content.
- Workflow automation - orchestrates deadlines, approvals, and notifications.
- Audit logs - record all operations for compliance and reporting.
Metrics and evaluation criteria
Performance and compliance of DSRM systems can be quantified using several operational metrics.
Metric | Description |
Request Fulfillment Time | Time required to complete a request. |
Coverage Rate | Percentage of data searchable and processable automatically. |
Error Rate | Frequency of incomplete or incorrect processing. |
Traceability Score | Clarity and completeness of audit trails. |
Compliance Score | Degree of adherence to GDPR requirements. |
Role in security and compliance
DSRM is a core component of legal and operational compliance for organizations processing visual data. It enhances security by enforcing transparency and control over all actions involving personal data.
- Ensuring individuals can control how their likeness is processed.
- Reducing the risk of unauthorized exposure of raw footage.
- Supporting automated processing to minimize human errors.
- Providing a provable compliance framework through detailed logs.
Challenges and limitations
Managing data subject rights for video presents unique challenges compared to textual data.
- Difficulty identifying individuals in large archives without face-search systems.
- High storage and processing costs for long-term video footage.
- Fragmentation of recordings across multiple sources (edge, cloud, cameras).
- Need for high-accuracy anonymization tools to fulfill erasure and restriction requests.
- Complex legal verification processes, especially for shared recordings.