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GDPR for DBAs

In DBA, Security and auditing on May 25, 2017 at 07:10

Exactly one year from now, from May 25th 2018, all businesses that handle personal data will have to comply with the new General Data Protection Regulation (GDPR) legislation.

At 260 pages in length, with 99 Articles and over 100 pages of explanatory notes known as ‘Annexes’, the GDPR is roughly three times the length of the Data Protection Act 1998 it is replacing.

The requirements for databases are:

– Discovery
– Classification
– Masking
– Monitoring
– Audit reporting
– Incident response and notification

The maximum penalty for non-compliance is 4% of annual revenue or €20 million, whichever is higher. Lower fines of up to 2% are possible for administrative breaches, such as not carrying out impact assessments or notifying the authorities or individuals in the event of a data breach. This puts data protection penalties into same category as anti-corruption or competition compliance.

What DBAs should start with now is account and identify 100% of the private data located in all databases!

There are 4 major categories where DBAa will be involved. The details can be found in the appendix on page 19/23 entitled Mapping of Oracle Database Security Products to GDPR.

1. Assess (Article 35 and Recital 84)
2. Prevent (Articles 5,6,29,32 and Recitals 26,28,64,83)
3. Detect (Articles 30,33,34)
4. Maximum protection (Articles 25,32)

Article 25 is about data minimization, user access limits and limit period of storage and accessibility.
Article 32 is about pseudonymization and encryption, ongoing protection and regular testing and verification.
Article 33 and 34 are about data breach notification: there is 72 hour notification following discovery of data breach.
Article 35 is about the data protection impact assessment.
Article 44 treats data transfers to third country or international organizations where the allowed transfers are only to entities in compliance with the regulation.

As you can see, DBA job ads include nowadays the GDPR skills and responsibilities:

The main lawful bases for data processing are consent and necessity. Data can be recognized as a necessity if it:

• Relates to the performance of a contract
• Illustrates compliance with a legal obligation
• Protects the vital interests of the data subject or another person
• Relates to a task that’s in the public interest
• Is used for purposes of legitimate interests pursued by the controller or a third party (expect where overridden by the rights of the data subject)

Data subjects’ requests for access should be responded to within a month and without charge. This is new legislation within the GDPR and the same one month time frame applies to rectifying inaccurate data.

Breach notifications should be made within 72 hours of becoming aware. If this time frame isn’t met, a fine of 10M€, or 2% of global turnover, can be issued as a penalty. A breach is any failure of security leading to the destruction, loss, alteration, unauthorized disclosure of/access to personal data. Supervisory authorities must be notified if a breach results in a risk to the rights and freedoms of individuals.

Data held in an encrypted or pseudonymized form isn’t deemed to be personal data and falls outside of the scope of these new rules altogether. Despite this, data that’s encrypted and considered secure using today’s technology may become readable in the future. Therefore it’s worth considering format preserving encryption/pseudonymization which renders anonymous but stills allows selected processing of that data.

Here are few interesting articles meant mostly for DBAs:

Accelerate Your Response to the EU General Data Protection Regulation (GDPR)

Data Privacy and Protection GDPR Compliance for Databases

European Union GDPR compliance for the DBA

SQL Server 2016 – Always Encrypted and the GDPR

How Oracle Security Solutions Can Help the EU GDPR

Top 10 operational impacts of the GDPR

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