Switzerland’s leading mobility company, the Swiss Railway (Schweizer Bundesbahn, SBB), operates a wide array of entities with changing responsibilities throughout the organization.
SBB wished to introduce an updated process to ensure each of its more than 170 digital entities was equipped with a compliant consent management solution – a highly challenging task.
This was particularly important, because the company serves a large proportion of EU-based passengers, which makes having a compliant consent management platform (CMP) in place obligatory. A timely solution was necessary, as the revised Swiss Data Protection Act (revDSG), scheduled for September 2023, was casting its regulatory shadow ahead.
Our approach
Our team began with four interviews with the most relevant stakeholders to understand the existing processes and uncertainties as well as their respective needs and wishes for the future. In addition, we audited the 30 most critical digital entities and apps thoroughly, each with more than 50 criteria that had proven themselves in numerous auditing projects.
A stakeholder-centric consent management process
Based on the information-gathering processes described above, our team gained an in-depth understanding of how the CMP tool was used.
We consolidated our findings in a presentation and discussed them with our main contacts. The legal and/or controversial questions that remained were discussed with the legal department. Additionally, we proposed design unifications and provided banner guidelines for ease of use.
The client and FELD M team collaborated on creating an SBB-wide aligned and streamlined consent management process with a coordinated approach to gaining consent of all entities as well as clear responsibilities and tasks within the organization.
Implementing the new process within the company
The project yielded a set of clear guidelines for critical issues and a process that can be used by all entities in the future. We developed guidance for the central documentation of SBB’s consent management as well as an organizational chart showing the different responsibilities of the different stakeholders, departments and entities.
We held a final presentation to ensure that all relevant stakeholders had a common understanding of consent management at SBB and that awareness of its importance as well as commitment to the new processes and responsibilities had been achieved.
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