At AWS re:Invent 2017, the AWS Compliance team participated in excellent engagements with AWS customers about the General Data Protection Regulation (GDPR), including discussions that generated helpful input. Today, I am announcing resulting enhancements to our recently launched GDPR Center and the release of a new whitepaper, Navigating GDPR Compliance on AWS. The resources available on the GDPR Center are designed to give you GDPR basics, and provide some ideas as you work out the details of the regulation and find a path to compliance.
In this post, I focus on two of these new GDPR requirements in terms of articles in the GDPR, and explain some of the AWS services and other resources that can help you meet these requirements.
Background about the GDPR
The GDPR is a European privacy law that will become enforceable on May 25, 2018, and is intended to harmonize data protection laws throughout the European Union (EU) by applying a single data protection law that is binding throughout each EU member state. The GDPR not only applies to organizations located within the EU, but also to organizations located outside the EU if they offer goods or services to, or monitor the behavior of, EU data subjects. All AWS services will comply with the GDPR in advance of the May 25, 2018, enforcement date.
We are already seeing customers move personal data to AWS to help solve challenges in complying with the EU’s GDPR because of AWS’s advanced toolset for identifying, securing, and managing all types of data, including personal data. Steve Schmidt, the AWS CISO, has already written about the internal and external work we have been undertaking to help you use AWS services to meet your own GDPR compliance goals.
Article 25 – Data Protection by Design and by Default (Privacy by Design)
Privacy by Design is the integration of data privacy and compliance into the systems development process, enabling applications, systems, and accounts, among other things, to be secure by default. To secure your AWS account, we offer a script to evaluate your AWS account against the full Center for Internet Security (CIS) Amazon Web Services Foundations Benchmark 1.1. You can access this public benchmark on GitHub. Additionally, AWS Trusted Advisor is an online resource to help you improve security by optimizing your AWS environment. Among other things, Trusted Advisor lists a number of security-related controls you should be monitoring. AWS also offers AWS CloudTrail, a logging tool to track usage and API activity. Another example of tooling that enables data protection is Amazon Inspector, which includes a knowledge base of hundreds of rules (regularly updated by AWS security researchers) mapped to common security best practices and vulnerability definitions. Examples of built-in rules include checking for remote root login being enabled or vulnerable software versions installed. These and other tools enable you to design an environment that protects customer data by design.
An accurate inventory of all the GDPR-impacting data is important but sometimes difficult to assess. AWS has some advanced tooling, such as Amazon Macie, to help you determine where customer data is present in your AWS resources. Macie uses advanced machine learning to automatically discover and classify data so that you can protect data, per Article 25.
Article 32 – Security of Processing
You can use many AWS services and features to secure the processing of data regulated by the GDPR. Amazon Virtual Private Cloud (Amazon VPC) lets you provision a logically isolated section of the AWS Cloud where you can launch resources in a virtual network that you define. You have complete control over your virtual networking environment, including the selection of your own IP address range, creation of subnets, and configuration of route tables and network gateways. With Amazon VPC, you can make the Amazon Cloud a seamless extension of your existing on-premises resources.
AWS Key Management Service (AWS KMS) is a managed service that makes it easy for you to create and control the encryption keys used to encrypt your data, and uses hardware security modules (HSMs) to help protect your keys. Managing keys with AWS KMS allows you to choose to encrypt data either on the server side or the client side. AWS KMS is integrated with several other AWS services to help you protect the data you store with these services. AWS KMS is also integrated with CloudTrail to provide you with logs of all key usage to help meet your regulatory and compliance needs. You can also use the AWS Encryption SDK to correctly generate and use encryption keys, as well as protect keys after they have been used.
We also recently announced new encryption and security features for Amazon S3, including default encryption and a detailed inventory report. Services of this type as well as additional GDPR enablers will be published regularly on our GDPR Center.
As you prepare for GDPR, you may want to visit our AWS Customer Compliance Center or Tools for Amazon Web Services to learn about options for building anything from small scripts that delete data to a full orchestration framework that uses AWS Code services.