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GDPR Compliance: Challenge or opportunity?

Case Studie

 

Erfolgreiche H4S4 Migration bei Stadtwerke München mit Unterstützung von Natuvion


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Brewery | Copenhagen | approx. 40,000 employees | DDK 58.5 B revenue

Established in 1847 by brewer J.C. Jacobsen, Carlsberg Group is one of the leading brewery groups in the world today. More than 40,000 people work for Carlsberg Group, and products are sold in more than 150 markets. The large portfolio of more than 140 beer and other beverage brands spans core beer brands, craft and specialty, and non-alcoholic brews. Core beer includes international brands Carlsberg and Tuborg, and strong local power brands, such as Ringnes in Norway, Lvivske in Ukraine and Wusu in China.

Further information is available at www.carlsberggroup.com 

 

 

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Über die Stadtwerke München

Umsatz: 9.672 Mrd. Euro

Industrie: Energie

Produkte | Services: Strom, Gas, Wasser, Bäder, Elektromobilität,
Photovoltaik, Telekommunikation

Natuvion Leistung: Conversion auf HCM für SAP S/4 HANA

Challenge
  • Large volumes of historical HR data that were no longer required.

  • Lack of regular review and deletion processes for stored data.

  • Complex compliance requirements driven by varying retention periods.

  • Increased risk of GDPR violations and financial penalties. 

Solution
  • Risk-based analysis and prioritization of existing data inventories.

  • Development of tailored deletion programs and governance rules.

  • Customization of the SAP Information Lifecycle Management (SAP ILM) standard to meet specific business requirements.

  • Agile implementation including testing, validation, and knowledge transfer. 

Result
  • Deletion of millions of obsolete personal data records.

  • Significant reduction of data privacy and business risks.

  • Leaner databases and improved system performance.

  • Solid foundation for future system modernization initiatives (e.g., SAP HANA).

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Objective

With the introduction of the General Data Protection Regulation (GDPR) and the associated “right to be forgotten,” Carlsberg faced the challenge of fundamentally redesigning the handling of personal data within its HCM systems. The objective of the project was to establish sustainable data privacy compliance by ensuring that personal data would be deleted in accordance with regulatory requirements once its processing purpose had expired.

To achieve this, the standard SAP Information Lifecycle Management (SAP ILM) framework was to be implemented and adapted to Carlsberg’s specific requirements. At the same time, the company aimed to minimize compliance risks and establish a long-term, scalable solution for managing sensitive HR data. For the implementation, Carlsberg relied on Natuvion’s expertise in SAP ILM and SAP HCM and adopted an agile project approach with clearly defined timelines.

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Industry:

Brewery

Key service:

Implementation of SAP ILM for HCM

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Project approach:

SAP ILM integration

Project duration:

4 months

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Source system:

SAP HCM system

Target system:

SAP HCM system

Detailed project overview

Growing data volumes and increasing compliance risks

Over the years, Carlsberg’s HCM systems had continuously grown without regular reviews or cleansing of the stored data. The result: large amounts of personal data remained in the systems even though the original business purpose for processing that data no longer existed. This not only created significant data privacy risks but also increased the financial exposure associated with potential GDPR violations and regulatory penalties.

In addition, the complexity of the data landscape made the implementation of appropriate deletion processes particularly challenging. Different data categories, legal retention requirements, and individual conditions – such as employee-specific entry dates – had to be taken into account. To address these challenges, a structured analysis of the existing data landscape was required in order to prioritize the most critical datasets and define a clear deletion strategy.

Customized SAP ILM implementation with an agile project approach

Based on a risk-weighted data analysis, Natuvion and Carlsberg jointly developed a tailored SAP ILM solution for the company’s HCM systems. The first step involved categorizing and prioritizing the relevant data sets in order to design targeted deletion programs. The standard SAP ILM framework was then enhanced with custom developments to address Carlsberg’s specific requirements.

This included the definition of custom deletion objects, the implementation of dedicated governance rules, and the consideration of complex legal and regulatory requirements. The project was executed using an agile delivery model, initially rolled out in the United Kingdom and subsequently implemented in Poland.

Throughout the project, Natuvion supported the business departments during testing activities, coordinated all relevant stakeholders, and ensured the correct functionality of the deletion processes through continuous validation. At the same time, operational teams were trained to ensure a smooth transition into long-term productive operations.

Leaner databases, faster processes, and full data privacy compliance

Through the successful implementation of SAP ILM, Carlsberg achieved full data privacy compliance within its HCM systems. Millions of personal data records whose processing purpose had expired were securely deleted. As a result, both data privacy risks and potential financial liabilities were significantly reduced.

In addition, the data cleansing initiative resulted in leaner databases, positively impacting system performance and process efficiency. The introduction of regular deletion routines also ensures that data volumes remain under control in the long term and that the systems can continue to operate in compliance with GDPR requirements.

Beyond the technical improvements, Carlsberg also achieved measurable business benefits, including reduced storage requirements and lower operating costs. At the same time, the optimized data foundation now provides an ideal basis for future system modernization initiatives, such as migration to SAP HANA.

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Download the full success story as a PDF

If I may give one advice, it would be to choose your vendor wisely. Natuvion over-delivered on our already high expectations! Our collaboration was extraordinary in terms of trust, productivity and relationship.
Dawid Wierzbowski
Senior program Manager, Carlsberg

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Denise Sikula

Denise Sikula

Solution Advisor

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