The Challenge
A top service provider’s client had a last-minute request driven by the California Consumer Privacy Act (CCPA). This request involved almost half a million documents (~440,000). The team effectively had a week to conduct the review and accurately identify names across three form types within this enormous document set. A solution would need to be quick, defensive, and in compliance with the CCPA.
“Even with an army, the document set couldn’t be redacted in 7 days.” – Review Manager
The Solution
For this CCPA challenge, an experienced review manager applied a nuanced Blackout job to account for how the same PII varied visually in the documents due to stylistic formatting, human error like misspellings and abbreviations. Additionally, this review manager previously ran mass redaction projects, so they knew thorough upfront planning was essential to running the project smoothly and completing it on time.
To resolve any nervousness or confusion around managing CCPA requests “correctly,” simply remember: A CCPA workflow is like any other. It will only be as effective and thorough as the planning of it and the team’s coordination behind it. Ahead of starting, the review manager aligned on communication and sign-off strategy with the teams involved. To identify the various ways names were formatted, they and a few other team members split the work into sample batches of like forms (~400 each).
They then ran quick automated jobs with Blackout until their three sample sets ran consecutively with zero missed redactions. Lastly, they shared each sample job with the legal team to confirm compliance and defensibility and to further improve markup rules.
“It would have been hugely expensive to do this. I don’t have exact numbers, but you just can’t get a team to operate at this scale; it’s not possible.”
While planning and coordination consumed the most resources, setup ultimately took only 24 hours to complete – a significant win for the provider.
With Blackout’s automated redaction jobs, the provider completed their work in under six days.
Success Factors
Whatever the timeline, always plan thoroughly – be focused and decisive upfront to be accurate and efficient in production.
Clear communication with the review team eliminates unnecessary downstream quality control.
Batch-testing smaller document sets prevents issues later when validating an automated workflow.
Controls like creating multiple rulesets dramatically reduce project review time – allowing automations to run smoothly.
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