Tag Archives: GDPR

SuiteCRM 7.10 released

Post Syndicated from corbet original https://lwn.net/Articles/747522/rss

SuiteCRM is a fork of the formerly
open-source SugarCRM customer relationship management system.

The 7.10 release
has been announced. “SuiteCRM 7.10 includes a long list of
enhancements, improving user experience, adding new functionality and
providing a new REST API. This edition of SuiteCRM also assists companies
to be ready for GDPR, including opt-in functionality to track the consent
of individuals.

Backblaze and GDPR

Post Syndicated from Andy Klein original https://www.backblaze.com/blog/gdpr-compliance/

GDPR General Data Protection Regulation

Over the next few months the noise over GDPR will finally reach a crescendo. For the uninitiated, “GDPR” stands for “General Data Protection Regulation” and it goes into effect on May 25th of this year. GDPR is designed to protect how personal information of EU (European Union) citizens is collected, stored, and shared. The regulation should also improve transparency as to how personal information is managed by a business or organization.

Backblaze fully expects to be GDPR compliant when May 25th rolls around and we thought we’d share our experience along the way. We’ll start with this post as an introduction to GDPR. In future posts, we’ll dive into some of the details of the process we went through in meeting the GDPR objectives.

GDPR: A Two Way Street

To ensure we are GDPR compliant, Backblaze has assembled a dedicated internal team, engaged outside counsel in the United Kingdom, and consulted with other tech companies on best practices. While it is a sizable effort on our part, we view this as a waypoint in our ongoing effort to secure and protect our customers’ data and to be transparent in how we work as a company.

In addition to the effort we are putting into complying with the regulation, we think it is important to underscore and promote the idea that data privacy and security is a two-way street. We can spend millions of dollars on protecting the security of our systems, but we can’t stop a bad actor from finding and using your account credentials left on a note stuck to your monitor. We can give our customers tools like two factor authentication and private encryption keys, but it is the partnership with our customers that is the most powerful protection. The same thing goes for your digital privacy — we’ll do our best to protect your information, but we will need your help to do so.

Why GDPR is Important

At the center of GDPR is the protection of Personally Identifiable Information or “PII.” The definition for PII is information that can be used stand-alone or in concert with other information to identify a specific person. This includes obvious data like: name, address, and phone number, less obvious data like email address and IP address, and other data such as a credit card number, and unique identifiers that can be decoded back to the person.

How Will GDPR Affect You as an Individual

If you are a citizen in the EU, GDPR is designed to protect your private information from being used or shared without your permission. Technically, this only applies when your data is collected, processed, stored or shared outside of the EU, but it’s a good practice to hold all of your service providers to the same standard. For example, when you are deciding to sign up with a service, you should be able to quickly access and understand what personal information is being collected, why it is being collected, and what the business can do with that information. These terms are typically found in “Terms and Conditions” and “Privacy Policy” documents, or perhaps in a written contract you signed before starting to use a given service or product.

Even if you are not a citizen of the EU, GDPR will still affect you. Why? Because nearly every company you deal with, especially online, will have customers that live in the EU. It makes little sense for Backblaze, or any other service provider or vendor, to create a separate set of rules for just EU citizens. In practice, protection of private information should be more accountable and transparent with GDPR.

How Will GDPR Affect You as a Backblaze Customer

Over the coming months Backblaze customers will see changes to our current “Terms and Conditions,” “Privacy Policy,” and to our Backblaze services. While the changes to the Backblaze services are expected to be minimal, the “terms and privacy” documents will change significantly. The changes will include among other things the addition of a group of model clauses and related materials. These clauses will be generally consistent across all GDPR compliant vendors and are meant to be easily understood so that a customer can easily determine how their PII is being collected and used.

Common GDPR Questions:

Here are a few of the more common questions we have heard regarding GDPR.

  1. GDPR will only affect citizens in the EU.
    Answer: The changes that are being made by companies such as Backblaze to comply with GDPR will almost certainly apply to customers from all countries. And that’s a good thing. The protections afforded to EU citizens by GDPR are something all users of our service should benefit from.
  2. After May 25, 2018, a citizen of the EU will not be allowed to use any applications or services that store data outside of the EU.
    Answer: False, no one will stop you as an EU citizen from using the internet-based service you choose. But, you should make sure you know where your data is being collected, processed, and stored. If any of those activities occur outside the EU, make sure the company is following the GDPR guidelines.
  3. My business only has a few EU citizens as customers, so I don’t need to care about GDPR?
    Answer: False, even if you have just one EU citizen as a customer, and you capture, process or store data their PII outside of the EU, you need to comply with GDPR.
  4. Companies can be fined millions of dollars for not complying with GDPR.
    Answer:
    True, but: the regulation allows for companies to be fined up to $4 Million dollars or 20% of global revenue (whichever is greater) if they don’t comply with GDPR. In practice, the feeling is that such fines will be reserved (at least initially) for egregious violators that ignore or merely give “lip-service” to GDPR.
  5. You’ll be able to tell a company is GDPR compliant because they have a “GDPR Certified” badge on their website.
    Answer: There is no official GDPR certification or an official GDPR certification program. Companies that comply with GDPR are expected to follow the articles in the regulation and it should be clear from the outside looking in that they have followed the regulations. For example, their “Terms and Conditions,” and “Privacy Policy” should clearly spell out how and why they collect, use, and share your information. At some point a real GDPR certification program may be adopted, but not yet.

For all the hoopla about GDPR, the regulation is reasonably well thought out and addresses a very important issue — people’s privacy online. Creating a best practices document, or in this case a regulation, that companies such as Backblaze can follow is a good idea. The document isn’t perfect, and over the coming years we expect there to be changes. One thing we hope for is that the countries within the EU continue to stand behind one regulation and not fragment the document into multiple versions, each applying to themselves. We believe that having multiple different GDPR versions for different EU countries would lead to less protection overall of EU citizens.

In summary, GDPR changes are coming over the next few months. Backblaze has our internal staff and our EU-based legal council working diligently to ensure that we will be GDPR compliant by May 25th. We believe that GDPR will have a positive effect in enhancing the protection of personally identifiable information for not only EU citizens, but all of our Backblaze customers.

The post Backblaze and GDPR appeared first on Backblaze Blog | Cloud Storage & Cloud Backup.

Join Us for AWS Security Week February 20–23 in San Francisco!

Post Syndicated from Craig Liebendorfer original https://aws.amazon.com/blogs/security/join-us-for-aws-security-week-february-20-23-in-san-francisco/

AWS Pop-up Loft image

Join us for AWS Security Week, February 20–23 at the AWS Pop-up Loft in San Francisco, where you can participate in four days of themed content that will help you secure your workloads on AWS. Each day will highlight a different security and compliance topic, and will include an overview session, a customer or partner speaker, a deep dive into the day’s topic, and a hands-on lab or demos of relevant AWS or partner services.

Tuesday (February 20) will kick off the week with a day devoted to identity and governance. On Wednesday, we will dig into secure configuration and automation, including a discussion about upcoming General Data Protection Regulation (GDPR) requirements. On Thursday, we will cover threat detection and remediation, which will include an Amazon GuardDuty lab. And on Friday, we will discuss incident response on AWS.

Sessions, demos, and labs about each of these topics will be led by seasoned security professionals from AWS, who will help you understand not just the basics, but also the nuances of building applications in the AWS Cloud in a robust and secure manner. AWS subject-matter experts will be available for “Ask the Experts” sessions during breaks.

Register today!

– Craig

GDPR for Developers [presentation]

Post Syndicated from Bozho original https://techblog.bozho.net/gdpr-developers-presentation/

On a recent meetup in Amsterdam I talked about GDPR from a technical point of view, effectively turning my “GDPR – a practical guide for developers” article into a talk.

You can see the slides here:

If you’re interested, you can also join a webinar on the same topic, organized by AxonIQ, where I will join Frans Vanbuul. You can find more information about the webinar here.

The interesting thing that I can share after the meetup and after meeting with potential clients is that everyone (maybe unsurprisingly) has a very specific question that doesn’t get an immediate answer even after you follow the general guidelines. That is maybe a problem on the Regulation’s side, as it has not brought sufficient clarity to businesses.

As I said during the presentation – in technology we’re used with binary questions. In law and legal compliance an answer is somewhere on a scale between 1 and 10. “Do I have to encrypt my data at rest”? Well, I guess yes, but in terms of compliance I’d say “6 out of 10”, as it is not strict, depends on the multiple people’s interpretation of the sensitivity of the data and on other factors like access control.

So the communication between legal and technical people is key to understand what exactly implementation changes are needed.

The post GDPR for Developers [presentation] appeared first on Bozho's tech blog.

Now Open AWS EU (Paris) Region

Post Syndicated from Jeff Barr original https://aws.amazon.com/blogs/aws/now-open-aws-eu-paris-region/

Today we are launching our 18th AWS Region, our fourth in Europe. Located in the Paris area, AWS customers can use this Region to better serve customers in and around France.

The Details
The new EU (Paris) Region provides a broad suite of AWS services including Amazon API Gateway, Amazon Aurora, Amazon CloudFront, Amazon CloudWatch, CloudWatch Events, Amazon CloudWatch Logs, Amazon DynamoDB, Amazon Elastic Compute Cloud (EC2), EC2 Container Registry, Amazon ECS, Amazon Elastic Block Store (EBS), Amazon EMR, Amazon ElastiCache, Amazon Elasticsearch Service, Amazon Glacier, Amazon Kinesis Streams, Polly, Amazon Redshift, Amazon Relational Database Service (RDS), Amazon Route 53, Amazon Simple Notification Service (SNS), Amazon Simple Queue Service (SQS), Amazon Simple Storage Service (S3), Amazon Simple Workflow Service (SWF), Amazon Virtual Private Cloud, Auto Scaling, AWS Certificate Manager (ACM), AWS CloudFormation, AWS CloudTrail, AWS CodeDeploy, AWS Config, AWS Database Migration Service, AWS Direct Connect, AWS Elastic Beanstalk, AWS Identity and Access Management (IAM), AWS Key Management Service (KMS), AWS Lambda, AWS Marketplace, AWS OpsWorks Stacks, AWS Personal Health Dashboard, AWS Server Migration Service, AWS Service Catalog, AWS Shield Standard, AWS Snowball, AWS Snowball Edge, AWS Snowmobile, AWS Storage Gateway, AWS Support (including AWS Trusted Advisor), Elastic Load Balancing, and VM Import.

The Paris Region supports all sizes of C5, M5, R4, T2, D2, I3, and X1 instances.

There are also four edge locations for Amazon Route 53 and Amazon CloudFront: three in Paris and one in Marseille, all with AWS WAF and AWS Shield. Check out the AWS Global Infrastructure page to learn more about current and future AWS Regions.

The Paris Region will benefit from three AWS Direct Connect locations. Telehouse Voltaire is available today. AWS Direct Connect will also become available at Equinix Paris in early 2018, followed by Interxion Paris.

All AWS infrastructure regions around the world are designed, built, and regularly audited to meet the most rigorous compliance standards and to provide high levels of security for all AWS customers. These include ISO 27001, ISO 27017, ISO 27018, SOC 1 (Formerly SAS 70), SOC 2 and SOC 3 Security & Availability, PCI DSS Level 1, and many more. This means customers benefit from all the best practices of AWS policies, architecture, and operational processes built to satisfy the needs of even the most security sensitive customers.

AWS is certified under the EU-US Privacy Shield, and the AWS Data Processing Addendum (DPA) is GDPR-ready and available now to all AWS customers to help them prepare for May 25, 2018 when the GDPR becomes enforceable. The current AWS DPA, as well as the AWS GDPR DPA, allows customers to transfer personal data to countries outside the European Economic Area (EEA) in compliance with European Union (EU) data protection laws. AWS also adheres to the Cloud Infrastructure Service Providers in Europe (CISPE) Code of Conduct. The CISPE Code of Conduct helps customers ensure that AWS is using appropriate data protection standards to protect their data, consistent with the GDPR. In addition, AWS offers a wide range of services and features to help customers meet the requirements of the GDPR, including services for access controls, monitoring, logging, and encryption.

From Our Customers
Many AWS customers are preparing to use this new Region. Here’s a small sample:

Societe Generale, one of the largest banks in France and the world, has accelerated their digital transformation while working with AWS. They developed SG Research, an application that makes reports from Societe Generale’s analysts available to corporate customers in order to improve the decision-making process for investments. The new AWS Region will reduce latency between applications running in the cloud and in their French data centers.

SNCF is the national railway company of France. Their mobile app, powered by AWS, delivers real-time traffic information to 14 million riders. Extreme weather, traffic events, holidays, and engineering works can cause usage to peak at hundreds of thousands of users per second. They are planning to use machine learning and big data to add predictive features to the app.

Radio France, the French public radio broadcaster, offers seven national networks, and uses AWS to accelerate its innovation and stay competitive.

Les Restos du Coeur, a French charity that provides assistance to the needy, delivering food packages and participating in their social and economic integration back into French society. Les Restos du Coeur is using AWS for its CRM system to track the assistance given to each of their beneficiaries and the impact this is having on their lives.

AlloResto by JustEat (a leader in the French FoodTech industry), is using AWS to to scale during traffic peaks and to accelerate their innovation process.

AWS Consulting and Technology Partners
We are already working with a wide variety of consulting, technology, managed service, and Direct Connect partners in France. Here’s a partial list:

AWS Premier Consulting PartnersAccenture, Capgemini, Claranet, CloudReach, DXC, and Edifixio.

AWS Consulting PartnersABC Systemes, Atos International SAS, CoreExpert, Cycloid, Devoteam, LINKBYNET, Oxalide, Ozones, Scaleo Information Systems, and Sopra Steria.

AWS Technology PartnersAxway, Commerce Guys, MicroStrategy, Sage, Software AG, Splunk, Tibco, and Zerolight.

AWS in France
We have been investing in Europe, with a focus on France, for the last 11 years. We have also been developing documentation and training programs to help our customers to improve their skills and to accelerate their journey to the AWS Cloud.

As part of our commitment to AWS customers in France, we plan to train more than 25,000 people in the coming years, helping them develop highly sought after cloud skills. They will have access to AWS training resources in France via AWS Academy, AWSome days, AWS Educate, and webinars, all delivered in French by AWS Technical Trainers and AWS Certified Trainers.

Use it Today
The EU (Paris) Region is open for business now and you can start using it today!

Jeff;

 

Introducing the New GDPR Center and “Navigating GDPR Compliance on AWS” Whitepaper

Post Syndicated from Chad Woolf original https://aws.amazon.com/blogs/security/introducing-the-new-gdpr-center-and-navigating-gdpr-compliance-on-aws-whitepaper/

European Union flag

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.

Other resources

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.

-Chad

GDPR – A Practical Guide For Developers

Post Syndicated from Bozho original https://techblog.bozho.net/gdpr-practical-guide-developers/

You’ve probably heard about GDPR. The new European data protection regulation that applies practically to everyone. Especially if you are working in a big company, it’s most likely that there’s already a process for gettign your systems in compliance with the regulation.

The regulation is basically a law that must be followed in all European countries (but also applies to non-EU companies that have users in the EU). In this particular case, it applies to companies that are not registered in Europe, but are having European customers. So that’s most companies. I will not go into yet another “12 facts about GDPR” or “7 myths about GDPR” posts/whitepapers, as they are often aimed at managers or legal people. Instead, I’ll focus on what GDPR means for developers.

Why am I qualified to do that? A few reasons – I was advisor to the deputy prime minister of a EU country, and because of that I’ve been both exposed and myself wrote some legislation. I’m familiar with the “legalese” and how the regulatory framework operates in general. I’m also a privacy advocate and I’ve been writing about GDPR-related stuff in the past, i.e. “before it was cool” (protecting sensitive data, the right to be forgotten). And finally, I’m currently working on a project that (among other things) aims to help with covering some GDPR aspects.

I’ll try to be a bit more comprehensive this time and cover as many aspects of the regulation that concern developers as I can. And while developers will mostly be concerned about how the systems they are working on have to change, it’s not unlikely that a less informed manager storms in in late spring, realizing GDPR is going to be in force tomorrow, asking “what should we do to get our system/website compliant”.

The rights of the user/client (referred to as “data subject” in the regulation) that I think are relevant for developers are: the right to erasure (the right to be forgotten/deleted from the system), right to restriction of processing (you still keep the data, but mark it as “restricted” and don’t touch it without further consent by the user), the right to data portability (the ability to export one’s data), the right to rectification (the ability to get personal data fixed), the right to be informed (getting human-readable information, rather than long terms and conditions), the right of access (the user should be able to see all the data you have about them), the right to data portability (the user should be able to get a machine-readable dump of their data).

Additionally, the relevant basic principles are: data minimization (one should not collect more data than necessary), integrity and confidentiality (all security measures to protect data that you can think of + measures to guarantee that the data has not been inappropriately modified).

Even further, the regulation requires certain processes to be in place within an organization (of more than 250 employees or if a significant amount of data is processed), and those include keeping a record of all types of processing activities carried out, including transfers to processors (3rd parties), which includes cloud service providers. None of the other requirements of the regulation have an exception depending on the organization size, so “I’m small, GDPR does not concern me” is a myth.

It is important to know what “personal data” is. Basically, it’s every piece of data that can be used to uniquely identify a person or data that is about an already identified person. It’s data that the user has explicitly provided, but also data that you have collected about them from either 3rd parties or based on their activities on the site (what they’ve been looking at, what they’ve purchased, etc.)

Having said that, I’ll list a number of features that will have to be implemented and some hints on how to do that, followed by some do’s and don’t’s.

  • “Forget me” – you should have a method that takes a userId and deletes all personal data about that user (in case they have been collected on the basis of consent, and not due to contract enforcement or legal obligation). It is actually useful for integration tests to have that feature (to cleanup after the test), but it may be hard to implement depending on the data model. In a regular data model, deleting a record may be easy, but some foreign keys may be violated. That means you have two options – either make sure you allow nullable foreign keys (for example an order usually has a reference to the user that made it, but when the user requests his data be deleted, you can set the userId to null), or make sure you delete all related data (e.g. via cascades). This may not be desirable, e.g. if the order is used to track available quantities or for accounting purposes. It’s a bit trickier for event-sourcing data models, or in extreme cases, ones that include some sort of blcokchain/hash chain/tamper-evident data structure. With event sourcing you should be able to remove a past event and re-generate intermediate snapshots. For blockchain-like structures – be careful what you put in there and avoid putting personal data of users. There is an option to use a chameleon hash function, but that’s suboptimal. Overall, you must constantly think of how you can delete the personal data. And “our data model doesn’t allow it” isn’t an excuse.
  • Notify 3rd parties for erasure – deleting things from your system may be one thing, but you are also obligated to inform all third parties that you have pushed that data to. So if you have sent personal data to, say, Salesforce, Hubspot, twitter, or any cloud service provider, you should call an API of theirs that allows for the deletion of personal data. If you are such a provider, obviously, your “forget me” endpoint should be exposed. Calling the 3rd party APIs to remove data is not the full story, though. You also have to make sure the information does not appear in search results. Now, that’s tricky, as Google doesn’t have an API for removal, only a manual process. Fortunately, it’s only about public profile pages that are crawlable by Google (and other search engines, okay…), but you still have to take measures. Ideally, you should make the personal data page return a 404 HTTP status, so that it can be removed.
  • Restrict processing – in your admin panel where there’s a list of users, there should be a button “restrict processing”. The user settings page should also have that button. When clicked (after reading the appropriate information), it should mark the profile as restricted. That means it should no longer be visible to the backoffice staff, or publicly. You can implement that with a simple “restricted” flag in the users table and a few if-clasues here and there.
  • Export data – there should be another button – “export data”. When clicked, the user should receive all the data that you hold about them. What exactly is that data – depends on the particular usecase. Usually it’s at least the data that you delete with the “forget me” functionality, but may include additional data (e.g. the orders the user has made may not be delete, but should be included in the dump). The structure of the dump is not strictly defined, but my recommendation would be to reuse schema.org definitions as much as possible, for either JSON or XML. If the data is simple enough, a CSV/XLS export would also be fine. Sometimes data export can take a long time, so the button can trigger a background process, which would then notify the user via email when his data is ready (twitter, for example, does that already – you can request all your tweets and you get them after a while).
  • Allow users to edit their profile – this seems an obvious rule, but it isn’t always followed. Users must be able to fix all data about them, including data that you have collected from other sources (e.g. using a “login with facebook” you may have fetched their name and address). Rule of thumb – all the fields in your “users” table should be editable via the UI. Technically, rectification can be done via a manual support process, but that’s normally more expensive for a business than just having the form to do it. There is one other scenario, however, when you’ve obtained the data from other sources (i.e. the user hasn’t provided their details to you directly). In that case there should still be a page where they can identify somehow (via email and/or sms confirmation) and get access to the data about them.
  • Consent checkboxes – this is in my opinion the biggest change that the regulation brings. “I accept the terms and conditions” would no longer be sufficient to claim that the user has given their consent for processing their data. So, for each particular processing activity there should be a separate checkbox on the registration (or user profile) screen. You should keep these consent checkboxes in separate columns in the database, and let the users withdraw their consent (by unchecking these checkboxes from their profile page – see the previous point). Ideally, these checkboxes should come directly from the register of processing activities (if you keep one). Note that the checkboxes should not be preselected, as this does not count as “consent”.
  • Re-request consent – if the consent users have given was not clear (e.g. if they simply agreed to terms & conditions), you’d have to re-obtain that consent. So prepare a functionality for mass-emailing your users to ask them to go to their profile page and check all the checkboxes for the personal data processing activities that you have.
  • “See all my data” – this is very similar to the “Export” button, except data should be displayed in the regular UI of the application rather than an XML/JSON format. For example, Google Maps shows you your location history – all the places that you’ve been to. It is a good implementation of the right to access. (Though Google is very far from perfect when privacy is concerned)
  • Age checks – you should ask for the user’s age, and if the user is a child (below 16), you should ask for parent permission. There’s no clear way how to do that, but my suggestion is to introduce a flow, where the child should specify the email of a parent, who can then confirm. Obviosuly, children will just cheat with their birthdate, or provide a fake parent email, but you will most likely have done your job according to the regulation (this is one of the “wishful thinking” aspects of the regulation).

Now some “do’s”, which are mostly about the technical measures needed to protect personal data. They may be more “ops” than “dev”, but often the application also has to be extended to support them. I’ve listed most of what I could think of in a previous post.

  • Encrypt the data in transit. That means that communication between your application layer and your database (or your message queue, or whatever component you have) should be over TLS. The certificates could be self-signed (and possibly pinned), or you could have an internal CA. Different databases have different configurations, just google “X encrypted connections. Some databases need gossiping among the nodes – that should also be configured to use encryption
  • Encrypt the data at rest – this again depends on the database (some offer table-level encryption), but can also be done on machine-level. E.g. using LUKS. The private key can be stored in your infrastructure, or in some cloud service like AWS KMS.
  • Encrypt your backups – kind of obvious
  • Implement pseudonymisation – the most obvious use-case is when you want to use production data for the test/staging servers. You should change the personal data to some “pseudonym”, so that the people cannot be identified. When you push data for machine learning purposes (to third parties or not), you can also do that. Technically, that could mean that your User object can have a “pseudonymize” method which applies hash+salt/bcrypt/PBKDF2 for some of the data that can be used to identify a person
  • Protect data integrity – this is a very broad thing, and could simply mean “have authentication mechanisms for modifying data”. But you can do something more, even as simple as a checksum, or a more complicated solution (like the one I’m working on). It depends on the stakes, on the way data is accessed, on the particular system, etc. The checksum can be in the form of a hash of all the data in a given database record, which should be updated each time the record is updated through the application. It isn’t a strong guarantee, but it is at least something.
  • Have your GDPR register of processing activities in something other than Excel – Article 30 says that you should keep a record of all the types of activities that you use personal data for. That sounds like bureaucracy, but it may be useful – you will be able to link certain aspects of your application with that register (e.g. the consent checkboxes, or your audit trail records). It wouldn’t take much time to implement a simple register, but the business requirements for that should come from whoever is responsible for the GDPR compliance. But you can advise them that having it in Excel won’t make it easy for you as a developer (imagine having to fetch the excel file internally, so that you can parse it and implement a feature). Such a register could be a microservice/small application deployed separately in your infrastructure.
  • Log access to personal data – every read operation on a personal data record should be logged, so that you know who accessed what and for what purpose
  • Register all API consumers – you shouldn’t allow anonymous API access to personal data. I’d say you should request the organization name and contact person for each API user upon registration, and add those to the data processing register. Note: some have treated article 30 as a requirement to keep an audit log. I don’t think it is saying that – instead it requires 250+ companies to keep a register of the types of processing activities (i.e. what you use the data for). There are other articles in the regulation that imply that keeping an audit log is a best practice (for protecting the integrity of the data as well as to make sure it hasn’t been processed without a valid reason)

Finally, some “don’t’s”.

  • Don’t use data for purposes that the user hasn’t agreed with – that’s supposed to be the spirit of the regulation. If you want to expose a new API to a new type of clients, or you want to use the data for some machine learning, or you decide to add ads to your site based on users’ behaviour, or sell your database to a 3rd party – think twice. I would imagine your register of processing activities could have a button to send notification emails to users to ask them for permission when a new processing activity is added (or if you use a 3rd party register, it should probably give you an API). So upon adding a new processing activity (and adding that to your register), mass email all users from whom you’d like consent.
  • Don’t log personal data – getting rid of the personal data from log files (especially if they are shipped to a 3rd party service) can be tedious or even impossible. So log just identifiers if needed. And make sure old logs files are cleaned up, just in case
  • Don’t put fields on the registration/profile form that you don’t need – it’s always tempting to just throw as many fields as the usability person/designer agrees on, but unless you absolutely need the data for delivering your service, you shouldn’t collect it. Names you should probably always collect, but unless you are delivering something, a home address or phone is unnecessary.
  • Don’t assume 3rd parties are compliant – you are responsible if there’s a data breach in one of the 3rd parties (e.g. “processors”) to which you send personal data. So before you send data via an API to another service, make sure they have at least a basic level of data protection. If they don’t, raise a flag with management.
  • Don’t assume having ISO XXX makes you compliant – information security standards and even personal data standards are a good start and they will probably 70% of what the regulation requires, but they are not sufficient – most of the things listed above are not covered in any of those standards

Overall, the purpose of the regulation is to make you take conscious decisions when processing personal data. It imposes best practices in a legal way. If you follow the above advice and design your data model, storage, data flow , API calls with data protection in mind, then you shouldn’t worry about the huge fines that the regulation prescribes – they are for extreme cases, like Equifax for example. Regulators (data protection authorities) will most likely have some checklists into which you’d have to somehow fit, but if you follow best practices, that shouldn’t be an issue.

I think all of the above features can be implemented in a few weeks by a small team. Be suspicious when a big vendor offers you a generic plug-and-play “GDPR compliance” solution. GDPR is not just about the technical aspects listed above – it does have organizational/process implications. But also be suspicious if a consultant claims GDPR is complicated. It’s not – it relies on a few basic principles that are in fact best practices anyway. Just don’t ignore them.

The post GDPR – A Practical Guide For Developers appeared first on Bozho's tech blog.

КЗЛД: Десет практически стъпки за прилагане на новия Регламент относно защитата на данните (GDPR)

Post Syndicated from nellyo original https://nellyo.wordpress.com/2017/11/28/gdpr/

На 25 май 2018 г. влиза в сила новият Общ регламент относно защитата на   данните –  Регламент (ЕС) 2016/679 на Европейския парламент и на Съвета от 27 април 2016 година относно защитата на физическите лица във връзка с обработването на лични данни и относно свободното движение на такива данни и за отмяна на Директива 95/46/EО 

Комисията за защита на личните данни е издала указания – десет практически стъпки за прилагане на новия Общ регламент.

 

 

Filed under: Digital, EU Law, Media Law Tagged: gdpr

AWS Announces Amazon Macie

Post Syndicated from Stephen Schmidt original https://aws.amazon.com/blogs/security/aws-announces-amazon-macie/

I’m pleased to announce that today we’ve launched a new security service, Amazon Macie.

This service leverages machine learning to help customers prevent data loss by automatically discovering, classifying, and protecting sensitive data in AWS. Amazon Macie recognizes sensitive data such as personally identifiable information (PII) or intellectual property, providing customers with dashboards and alerts that give visibility into how data is being accessed or moved. This enables customers to apply machine learning to a wide array of security and compliance workloads, we think this will be a significant enabler for our customers.

To learn more about the see the full AWS Blog post.

–  Steve

 

Да разберем GDPR. Готова ли е компанията ви?

Post Syndicated from Йовко Ламбрев original https://yovko.net/gdpr-event/

Вероятно сте чували, а може би още не сте, но Регламентът за защита на личните данни (GDPR) е вече факт. След 4 години на обсъждане, лобиране и събиране на примери и добри практики Европейският съюз създаде нормативен акт, който променя мисленето ни за личните данни. Разбирането на нуждата от GDPR минава през осъзнаването, че четвъртата индустриална революция се случва сега. Все по–често конкурентното предимство на новите бизнес модели спрямо утвърдените такива се състои в достъпа, анализа и управлението на данни.

Политически кампании се печелят и компании излизат на върха на класациите чрез дейности по профилиране, анализ на големи масиви от данни и персонализиран маркетинг.

Какво променя GDPR и готова ли е компанията ви за новите правила или по-точно – кога е трябвало да бъде готова? Какво реално ще трябва да промените – организация, техническа инфраструктура или нагласа на служителите и ръководството? Ще може ли френския държавен орган по защитата на данните да вземе отношение спрямо нарушение, извършено от компания в Пазарджик? Какво е доклад относно въздействието от защитата на данни? Можете ли да продадете бизнеса си или да сключите стратегически договор без такъв доклад?

На 30 август в Пловдив експерти от адвокатско дружество Точева и Мандажиева заедно с Trakia Tech ще се опитат да отговорят на тези въпроси. Обещаваме Ви да е интересно и полезно. Нетърпеливи сме да чуем Вашите въпроси, които ще ни накарат да мислим още по-задълбочено в тази насока. Събитието организираме съвместно с нашите партньори от Капитал и ETNHost.

Работният език е български, а събитието е в малък формат и местата са ограничени, затова регистрацията на адрес capital.bg/gdpr е задължителна.

Очакваме ви в Център за събития Limacon, чийто адрес е: Пловдив, бул. Марица 154A (до големия паркинг на Билла).

ЕС: защита на данните – правила за оценка на въздействието

Post Syndicated from nellyo original https://nellyo.wordpress.com/2017/05/22/dp-20/

Работната група за защита на данните (Article 29 Data Protection Working Party, WP29) е публикувала проект за ръководни правила за оценка на въздействието на регламента за защита на данните (General Data Protection Regulation, GDPR).

 Проектът за правила

Filed under: Digital, EU Law, Media Law Tagged: dp

AWS and the General Data Protection Regulation (GDPR)

Post Syndicated from Stephen Schmidt original https://aws.amazon.com/blogs/security/aws-and-the-general-data-protection-regulation/

European Union image

Just over a year ago, the European Commission approved and adopted the new General Data Protection Regulation (GDPR). The GDPR is the biggest change in data protection laws in Europe since the 1995 introduction of the European Union (EU) Data Protection Directive, also known as Directive 95/46/EC. The GDPR aims to strengthen the security and protection of personal data in the EU and will replace the Directive and all local laws relating to it.

AWS welcomes the arrival of the GDPR. The new, robust requirements raise the bar for data protection, security, and compliance, and will push the industry to follow the most stringent controls, helping to make everyone more secure. I am happy to announce today that all AWS services will comply with the GDPR when it becomes enforceable on May 25, 2018.

In this blog post, I explain the work AWS is doing to help customers with the GDPR as part of our continued commitment to help ensure they can comply with EU Data Protection requirements.

What has AWS been doing?

AWS continually maintains a high bar for security and compliance across all of our regions around the world. This has always been our highest priority—truly “job zero.” The AWS Cloud infrastructure has been architected to offer customers the most powerful, flexible, and secure cloud-computing environment available today. AWS also gives you a number of services and tools to enable you to build GDPR-compliant infrastructure on top of AWS.

One tool we give you is a Data Processing Agreement (DPA). I’m happy to announce today that we have a DPA that will meet the requirements of the GDPR. This GDPR DPA is available now to all AWS customers to help you prepare for May 25, 2018, when the GDPR becomes enforceable. For additional information about the new GDPR DPA or to obtain a copy, contact your AWS account manager.

In addition to account managers, we have teams of compliance experts, data protection specialists, and security experts working with customers across Europe to answer their questions and help them prepare for running workloads in the AWS Cloud after the GDPR comes into force. To further answer customers’ questions, we have updated our EU Data Protection website. This website includes information about what the GDPR is, the changes it brings to organizations operating in the EU, the services AWS offers to help you comply with the GDPR, and advice about how you can prepare.

Another topic we cover on the EU Data Protection website is AWS’s compliance with the CISPE Code of Conduct. The CISPE Code of Conduct helps cloud customers ensure that their cloud infrastructure provider is using appropriate data protection standards to protect their data in a manner consistent with the GDPR. AWS has declared that Amazon EC2, Amazon S3, Amazon RDS, AWS Identity and Access Management (IAM), AWS CloudTrail, and Amazon Elastic Block Storage (Amazon EBS) are fully compliant with the CISPE Code of Conduct. This declaration provides customers with assurances that they fully control their data in a safe, secure, and compliant environment when they use AWS. For more information about AWS’s compliance with the CISPE Code of Conduct, go to the CISPE website.

As well as giving customers a number of tools and services to build GDPR-compliant environments, AWS has achieved a number of internationally recognized certifications and accreditations. In the process, AWS has demonstrated compliance with third-party assurance frameworks such as ISO 27017 for cloud security, ISO 27018 for cloud privacy, PCI DSS Level 1, and SOC 1, SOC 2, and SOC 3. AWS also helps customers meet local security standards such as BSI’s Common Cloud Computing Controls Catalogue (C5) that is important in Germany. We will continue to pursue certifications and accreditations that are important to AWS customers.

What can you do?

Although the GDPR will not be enforceable until May 25, 2018, we are encouraging our customers and partners to start preparing now. If you have already implemented a high bar for compliance, security, and data privacy, the move to GDPR should be simple. However, if you have yet to start your journey to GDPR compliance, we urge you to start reviewing your security, compliance, and data protection processes now to ensure a smooth transition in May 2018.

You should consider the following key points in preparation for GDPR compliance:

  • Territorial reach – Determining whether the GDPR applies to your organization’s activities is essential to ensuring your organization’s ability to satisfy its compliance obligations.
  • Data subject rights – The GDPR enhances the rights of data subjects in a number of ways. You will need to make sure you can accommodate the rights of data subjects if you are processing their personal data.
  • Data breach notifications – If you are a data controller, you must report data breaches to the data protection authorities without undue delay and in any event within 72 hours of you becoming aware of a data breach.
  • Data protection officer (DPO) – You may need to appoint a DPO who will manage data security and other issues related to the processing of personal data.
  • Data protection impact assessment (DPIA) – You may need to conduct and, in some circumstances, you might be required to file with the supervisory authority a DPIA for your processing activities.
  • Data processing agreement (DPA) – You may need a DPA that will meet the requirements of the GDPR, particularly if personal data is transferred outside the European Economic Area.

AWS offers a wide range of services and features to help customers meet requirements of the GDPR, including services for access controls, monitoring, logging, and encryption. For more information about these services and features, see EU Data Protection.

At AWS, security, data protection, and compliance are our top priorities, and we will continue to work vigilantly to ensure that our customers are able to enjoy the benefits of AWS securely, compliantly, and without disruption in Europe and around the world. As we head toward May 2018, we will share more news and resources with you to help you comply with the GDPR.

– Steve