SCENARIO
Please use the following to answer the next question:
Jonathan recently joined a healthcare payment processing solutions company as a senior privacy manager.
One morning, Jonathan awakens to several emails informing him that an individual cloud server failed due to a
flood in its server room, damaging its hardware and destroying all the data the company had stored on that
drive. Jonathan was not aware that the company had this particular cloud account or that any data was being
stored there because it was not included in the data mapping or data inventory provided to him by his
predecessor. Jonathan's predecessor conducted a data inventory and mapping exercise 4 years ago and
updated it on an annual basis.
Renee works in the sales department and tells Jonathan that she doesn't think that account had been used
since the company moved to a bigger cloud vendor three years ago. She also advised him that the account was
mostly used by Human Resources (HR) and Accounts Payable (AP). Jonathan speaks to both departments and
learns that each had met with his predecessor multiple times and explained they saved sensitive personal data
on that drive, including health and financial related personal data and "other stuff." Jonathan also learns that the
data stored in that account was not backed up pursuant to company policy. Jonathan asks his IT department
who had access to that particular account and learns that there were no access controls in place, making the
account available to anyone in the company, despite the purported sensitivity of the data being stored there.
Jonathan is panicking as the data can't be recovered, and he can't determine exactly what data was saved on
that account or to whom it belongs. Two days later, the company receives 32 data subject access requests and
Accounts Payable confirms Jonathan's worry that these data subjects' personal data was likely stored on this
account. He searches for the company's data subject access request policy, but later learns it doesn't exist.
Based on the scenario above, what is the most appropriate next step Jonathan should take?