Microsoft Purview · Privacy Management (Priva)
Subject Rights Request Approvers
Can approve subject rights requests to which they are added as an approver. Typically used for approving delete requests or other high-risk SRRs requiring secondary authorization. Provides approval gate for sensitive SRR operations.
Scope: Approval authority for subject rights requests to which the user is specifically added as an approver. Typically used for delete request authorization.
Permissions
- Approve or reject subject rights requests assigned to them
- Review subject rights request details before approval
- View data collection scope and search criteria for SRRs
- Review files marked for deletion in delete requests
- Provide approval for export package generation
- Add approval comments and justifications
- View SRR workflow status and timeline
- Receive notifications when added as approver to SRR
- Review data subject information for identity verification
- Access SRR audit trail and activity history
- CANNOT create new subject rights requests
- CANNOT modify SRR settings or configurations
- CANNOT add/remove other approvers
- CANNOT execute deletions (only approve)
Common use cases
- Approving GDPR Article 17 "right to be forgotten" delete requests
- Authorizing deletion of employee data after termination
- Reviewing high-risk subject rights requests before fulfillment
- Approving export requests containing sensitive business data
- Providing legal counsel approval for complex SRRs
- Authorizing cross-border data transfer requests
- Approving SRRs that may impact ongoing litigation
- Reviewing delete requests for regulatory compliance
- Providing HR approval for employee data deletion
- Authorizing SRRs involving executive or board member data
- Approving SRRs requiring multiple stakeholder coordination
- Reviewing tagged list requests for follow-up actions
Best practices
- Add Approvers to all delete requests for dual authorization
- Use Approvers for SRRs involving sensitive or executive data
- Require legal counsel approval for SRRs during litigation
- Document approval justifications in SRR comments
- Review collected data scope before approving delete requests
- Verify data subject identity confirmation before approval
- Check for legal holds before approving deletion
- Coordinate with IT before approving large-scale deletions
- Use multiple Approvers for high-risk or complex SRRs
- Establish approval criteria and SLA for timely responses
- Monitor pending approvals to meet regulatory deadlines
- Reject SRRs if identity verification is insufficient
- Escalate complex approval decisions to privacy counsel
- Maintain audit trail of all approval decisions
Security considerations
- Approvers have authority to authorize irreversible data deletion
- Must verify that delete requests do not violate legal holds
- All approval decisions are logged in Microsoft 365 audit log
- Approvers may view sensitive personal data in SRR scope
- Delete approval should be treated with same care as data destruction
- Monitor audit logs for approval patterns or anomalies
- Coordinate with legal before approving SRRs during litigation
- Delete requests may expose security vulnerabilities - coordinate with SecOps
- Consider data retention policies before approving deletions
- This role is lower privilege than SRR Administrator but still sensitive
- Inappropriate approval could lead to data loss or regulatory violations
- Establish approval criteria to prevent unauthorized deletions
Common questions
When should I assign the Subject Rights Request Approvers role?
Assign Subject Rights Request Approvers when you need to: Approving GDPR Article 17 "right to be forgotten" delete requests; Authorizing deletion of employee data after termination; Reviewing high-risk subject rights requests before fulfillment; Approving export requests containing sensitive business data; and Providing legal counsel approval for complex SRRs. It is part of Microsoft Purview and should be granted as a least-privilege alternative to broader roles like Global Administrator.
What can someone with the Subject Rights Request Approvers role do?
The Subject Rights Request Approvers role grants permissions including: Approve or reject subject rights requests assigned to them; Review subject rights request details before approval; View data collection scope and search criteria for SRRs; Review files marked for deletion in delete requests; Provide approval for export package generation; and Add approval comments and justifications. See the Permissions section above for the full list.
What are the security risks of the Subject Rights Request Approvers role?
Key considerations when assigning Subject Rights Request Approvers: Approvers have authority to authorize irreversible data deletion; Must verify that delete requests do not violate legal holds; All approval decisions are logged in Microsoft 365 audit log; and Approvers may view sensitive personal data in SRR scope. Review the Security considerations section before assignment, and pair with Privileged Identity Management (PIM) for just-in-time access where possible.