Post Syndicated from Rory Malone original https://blog.cloudflare.com/cloudflare-cbpr-a-global-privacy-first/
Cloudflare proudly leads the way with our approach to data privacy and the protection of personal information, and we’ve been an ardent supporter of the need for the free flow of data across jurisdictional borders. So today, on Data Privacy Day (also known internationally as Data Protection Day), we’re happy to announce that we’re adding our fourth and fifth privacy validations, and this time, they are global firsts! Cloudflare is the first organisation to announce that we have been successfully audited against the brand new Global Cross-Border Privacy Rules (Global CBPRs) for data controllers and the Global Privacy Recognition for Processors (Global PRP). These validations demonstrate our support and adherence to global standards that provide for privacy-respecting data flows across jurisdictions. Organizations that have been successfully audited will be formally certified when the certifications officially launch, which we expect to happen later in 2025.
Our participation in the Global CBPRs and Global PRP joins our roster of privacy validations: we were one of the first cybersecurity organizations to certify to the international privacy standard ISO 27701:2019 when it was published, and in 2022 we also certified to the cloud privacy certification, ISO 27018:2019. In 2023, we added our third privacy validation, undergoing a review by an independent monitoring body in the European Union (EU) and declared to be adherent to the first official GDPR code of conduct — the EU Cloud Code of Conduct.
Taking these privacy certifications together, Cloudflare demonstrates that we are meeting key official privacy validations in 39 jurisdictions around the world, from Australia and Austria to Sweden and the United States. An additional four jurisdictions (United Kingdom, Bermuda, Mauritius, and the Dubai International Finance Centre) are also in the process of joining and recognising the Global CBPR certifications. That’s important for Cloudflare customers as it provides reassurance that the privacy practices we have built are recognised by governments around the world.
In the last three years, governments across the world have been busy preparing two brand-new international privacy standards. A major milestone was achieved on April 30, 2024 when the Global CBPR System was established. The CBPRs are a voluntary, enforceable, international, accountability-based system that facilitates privacy-respecting data flows among members’ economies. They provide a baseline level of privacy protection for consumers through a set of rules on how to handle people’s personal information. This facilitates the free flow of data by upholding consumer privacy across participating members, despite each jurisdiction having their own individual data protection laws.
The CBPR System was developed by the Global CBPR Forum, an intergovernmental forum between the governments of Australia, Canada, Japan, Republic of Korea, Mexico, Philippines, Singapore, Chinese Taipei, and the United States. The United Kingdom is also an associate member of the CBPR Forum, as are Bermuda, Mauritius, and the Dubai IFC, signifying their intent to join as full members in the future.
Over the last year, we have been busy preparing for the launch of the Global CBPR System. On May 1, 2024 — the very first day after the establishment of the system — Cloudflare applied to join. And we have now achieved the major milestone of successfully completing audits against the requirements, meaning we expect to be the first organization in the world to be newly certified to the Global CBPR system, as well as the related Global Privacy Recognition for Processors, when companies can officially be certified, which is expected later in 2025.
The Global CBPR System contains a detailed list of fifty requirements that organizations must meet in order to be certified under the scheme. The requirements derive from the nine Global CBPR Privacy Principles, which are consistent with the core principles of the Organisation for Economic Co-operation and Development (OECD) Guidelines on the Protection of Privacy and Trans-Border Flows of Personal Data. The fifty requirements cover how organizations should collect, manage, and safeguard personal information in their custody. Organizations must meet every one of the fifty requirements in order to be Global CBPR certified. The nine principles underlying the requirements are:
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Preventing Harm |
Notice |
Collection Limitation |
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Uses of Personal Information |
Choice |
Integrity of Personal Information |
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Security Safeguards |
Access and Correction |
Accountability |
The nine Global CBPR Privacy Principles
The Global CBPR certification covers the handling of personal information controlled by the organization, such as the personal details of customers, employees, and job applicants. For Cloudflare, this also includes network information — our observations about how our global cloud platform handles server, network, or traffic data generated by Cloudflare in the course of providing our services.
The related Global Privacy Recognition for Processors (PRP) certification covers the handling of personal information processed by the organization on behalf of a different organization, usually their customer. The eighteen requirements of the PRP relate to the two privacy principles most relevant when processing this information on behalf of another organization: Security Safeguards and Accountability. For Cloudflare, this covers the processing of data pursuant to the Data Processing Addendum we sign with all of our customers, chiefly, the Customer Content flowing across our network and the Customer Logs generated by those data flows. Organizations must meet every one of the eighteen requirements in order to be Global PRP certified.
As noted, the key requirements of the Global CBPRs and the Global PRP cover the well-known data protection principles of notice, choice, collection limitation (data minimization), the right of data subject access and correction, providing adequate security, preventing harm, integrity of personal information, accountability, and uses of personal information. There are dozens of requirements that cover these principles, so we’ll just touch on a few of them here.
Let’s first look at the principle of notice. One of the more obvious requirements from the CBPRs is question 1:
Do you provide clear and easily accessible statements about your practices and policies that govern the personal information described above (a privacy statement)?
Being transparent about the collection and use of personal information is a key principle of privacy and data protection, and transparency is one of Cloudflare’s core commitments. Documenting our practices and policies in regard to how we use personal information allows individuals to decide if they want to provide their information, and that’s why it’s best practice for the privacy notice to be available and visible at the time the information is being collected. Indeed, this concept of providing notice is clear from Article 13 of the EU’s GDPR. Cloudflare meets this CBPR requirement by providing a clear and accessible privacy notice visible from the footer of each page on our website. We also provide a link to the notice when we collect personal data such as through a form on a webpage.
In terms of how we use personal information, question 8 asks:
Do you limit the use of the personal information you collect (whether directly or through the use of third parties acting on your behalf) as identified in your privacy statement?
It has long been a commitment of Cloudflare’s that we only use the personal information we collect for the purposes of providing the services we offer. Our business is built on providing customers with the tools to protect their network applications and to make them faster, more secure, more reliable, and more private. In our Privacy Policy, we commit that we will “only share or otherwise disclose your personal information as necessary to provide our Services or as otherwise described in this Policy, except in cases where we first provide you with notice and the opportunity to consent.” And we maintain internal documentation (in keeping with the CBPR’s accountability principle) to document the data we are processing and the purposes for which we process it.
Another key set of requirements in both the Global CBPRs and the Global PRP have to do with security safeguards. CBPR requirement question 27 asks:
Describe the physical, technical and administrative safeguards you have implemented to protect personal information against risks such as loss or unauthorized access, destruction, use, modification or disclosure of information or other misuses?
The similar requirement in the Global PRP is question 2:
Describe the physical, technical and administrative safeguards that implement your organization’s information security policy.
Cloudflare has implemented an information security program in accordance with the ISO/IEC 27000 family of standards. Details of Cloudflare’s security program are documented in Annex 2 (“Technical and Organizational Security Measures”) of Cloudflare’s Customer Data Processing Addendum, including the physical, technical and administrative safeguards implemented to protect personal information.
Related to the Accountability principle, question 46 asks:
Do you have mechanisms in place with personal information processors, agents, contractors, or other service providers pertaining to personal information they process on your behalf, to ensure that your obligations to the individual will be met?
When we have vendors who handle any of our, or our customers’, personal information, we require them to sign a Data Processing Addendum with us. This ensures the commitments we make to our customers in our customer agreements in turn flow through to our vendors, including the security requirements — holding them, and us, accountable.
We are excited about the launch of the Global CBPR certifications, expected later in 2025, and we are proud that on this Data Privacy Day, we can yet again demonstrate our commitment to universally held principles for protecting the privacy of personal data.
You can find more about the Global CBPR System, the Global PRP, download a full copy of the requirements, and keep up to date with related news at globalcbpr.org.
For the latest information about our certifications, please visit our Trust Hub. Customers can also find out how to download a copy of Cloudflare’s certifications and reports from the Cloudflare dashboard.
