[General Data Protection Regulation ③] Data Protection by Design and by Default: Technological Measures
written by Kevin
Just over five months from now, the GDPR will be enforced for a stricter, thorough, and fair protection of personal data of all EU citizens, and the organizations with the presence in the EU have a tough task of GDPR compliance in their hands. To lighten the burden, we wrote a checklist of requirements for the organizations to follow on our earlier blog. Continuing our blog series on the GDPR, we will take a closer look at a technological aspect of compliance and how organizations can approach it.
For starters, where should the organizations begin to comply with the technological requirements of the GDPR? We turn our attention to “Data Protection by Design and by Default”, or Article 25. It explains that the organizations that fall under the GDPR scope must implement appropriate technical and organizational measures, which are designed to implement data-protection principles to integrate the necessary safeguards in order to:
- meet the requirements of this Regulation and protect the rights of data subjects, and
- to ensure that only personal data which are necessary for each specific purpose of the processing are processed.
The organizations are explicitly required to implement appropriate technical measures for personal data protection. However, with a plethora of data security solutions out there, some organizations may feel lost. From the technological point of view, we understand the Article 25 as the organizations’ responsibility to apply a cohesive blend of multiple data security principles to the full extent of data life cycle, which largely consists of data storage, processing, and erasure. We believe that this approach will serve as a backbone from which the organizations can start preparing for the GDPR.
After collecting personal data by complying with the GDPR requirements, data storage follows. The fundamental security principle here is to store all the personal data in one or more secure data repositories, separate from, but accessible by individual PCs via local network. The most common data repository is the file server, which is often operated and managed in multiple numbers, dedicated to multiple groups of users that will only be allowed to work on the files while being restricted from unauthorized file exports. To make sure your file servers are kept safe from potential dangers, organizations must consider some of the key security principles as below.
- Physical security to prevent intruder breaches
- Encryption to ensure protection of data against hackers or theft
- Keeping it off Internet to restrict potentially malicious or accidental access from outside of your LAN
- Anti-virus solutions to prevent cyber attacks from the outside
- Maintain high availability to ensure continuity of work productivity in case of accidental or malicious disruption to file server(s)
Once personal data is stored in the file servers, it will be subject to data processing by diverse personnel such as employees, contractors, partners, and consultants. It is critical to realize that data processing is the breeding ground for both accidental and malicious data leak threats from inside and out. The most common form of data leaks is accidental, due to employee negligence, operational mistakes, or lack of education. However, organizations cannot overlook the risk of malicious data leaks that can be caused by greed, ego, and competition. Therefore, a stringent data security system is required to ensure that only the certain files and folders are accessible by authorized users. Furthermore, all user, file, and folder activities must be logged for auditing and only allowed to be accessible by certain users. When processing personal data, employees may also transfer or share it outside the secure premises. For secure processing of personal data, organizations can consider some of the general countermeasures as below to mitigate the risks of leaking data.
- Data loss prevention (DLP) detects potential data leaks by monitoring the important data and blocking it from leaving the secure premises from the end-points.
- Enterprise digital rights management (EDRM) provides file access control and file activity restriction features that are persistent and manageable even outside the secure premises.
- Virtual desktop infrastructure (VDI) runs multiple user desktops inside virtual machines (terminals) with persistent data security policies that only allows users to access the data within the centralized data center(s).
Once the processing of personal data is complete, organizations may undertake data erasure to free up their storage space, or to ensure that personal data remains unavailable to others. Data erasure is closely related to the Article 17, which states that the data subjects have the right to erasure, or the right to be forgotten. Therefore, organizations must be prepared to erase personal data, rendering it unrecoverable in any situation. In this case, direct data erasure on the storage devices, through one or a combination of the general methods as below, is the safest procedure.
- Data erasure software by overwriting with randomized data
- Degaussing, or elimination of magnetic fields on storage devices to erase all stored data
- Brute destruction of storage devices
Despite the advantage of complete data erasure, degaussing and brute destruction carry two distinct disadvantages. Firstly, they make the storage devices unusable, and secondly, they require the devices to be transported to the external facilities, risking them to potential theft or loss. On the other hand, data erasure via software bypasses the two disadvantages by allowing the organizations to ‘recycle’ their storage devices and perform data erasure within their office premises. Therefore, organizations can ensure complete and secure data erasure with a software initially, and by subsequently degaussing or brutely destroying devices.
Meeting the technological requirements of the “Data protection by design and by default” can help organizations to get off to a solid start in achieving GDPR compliance before the deadline. We recommend the organizations to consider implementing the technological measures for the three steps of data life cycle: storage, processing, and erasure. This approach allows the organizations to devise a cohesive blend of multiple data security solutions, which will protect personal data from leaks and breaches from both internal and external threats. Capping off our blog series on the GDPR, we will discuss how Secudrive solutions can technologically help you to achieve “Data protection by design and by default” to prepare for the GDPR.
Blog Posts in this Series:
① The GDPR Summary: The 5 Key Points
② Checklist for the Organizations to Comply with the GDPR
→ Data Protection by Design and by Default: Technological Measures
④ GDPR Compliance with Secudrive