EU-GDPR and the cloud. Heike Fiedler-Phelps January 13, 2018
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1 . EU-GDPR and the cloud Heike Fiedler-Phelps January 13, 2018
2 Disclaimer SAP does not provide legal advice The following presentation is only about a high level discussion about GDPR. 2
3 EU-GDPR Summary The EU General Data Protection Regulation (EU-GDPR) was designed to harmonize data privacy laws across Europe, to protect and empower all EU citizens data privacy and to reshape the way organizations across the region approach data privacy. The EU-GDPR came into force on 25 May 2016 with a two year implementation period Enforcement date: 25 May 2018 The EU-GDPR applies to individuals in the EU regardless of whether the processing takes place in the Union or not. It applies also to non EU organizations if they offer goods or services to data subjects in the EU or monitor of the behavior of data subjects in the EU The right of individual selfdetermination is a basic human right and finds it expression in the Data Protection and Privacy legislation. - Mathias Cellarius, Head of Data Protection and Privacy at SAP Data subject Controller Processor EU-GDPR imposes penalties of up to 4% of annual global revenue or 20 million per case - whichever is greater 3
4 Data protection is simple Processing personal data is Unless forbidden. 4
5 Personal Data 5
6 Rights of the data subject 6
7 Example of where personal data is processed 7
8 Personal data lifecycle 8
9 Before we get to the cloud Important requirements mandated by EU-GDPR: Creation of an independent Data Protection Officer with compliance, cyber, business procedure oversight Purpose of data processing + lawful reasons for doing it Data protection risk impact assessment, prior approval for high risks Data protection by design, by default Information notices, policy implementation Data breach notifications (72 hours) Data retention consent requirements vs right to ensure Data profiling restrictions (especially automated) Date portability, machine readable format Data protection audits 9
10 Security safeguards 10
11 Data controller and data processor Rights of the Data subject Self Determination Deletion Correction Information Notification Data subject Controller Processor A contract between the controller and the processor determines which data are processed and how. The controller decides which personal data to collect, store, and use. The processor only processes data that is stored by the controller, and only within the scope of the contract Obligations of Controllers and processors Non-EU data controllers and processors must also comply when processing data of EU individuals. Controllers determine the purpose and means of processing personal data and bear primary responsibility for compliance. Processors are those who process personal data on behalf of a controller. Controller is accountable for failures of the data processor, and both controller and processor are liable for breaches. 11
12 What questions do you have or get in your job? What kind of information does the GDPR apply to? What rights will individuals have under GDPR? In the cloud, all GDPR responsibility is with SAP, right? Is the cloud compliant? What are the penalties for noncompliance? What is the difference between a data processor and a data controller? What is GDPR? What responsibilities will SAP have under this new regulation? What constitutes personal data? Why should I care? Do I have to pay for GDPR solutions? 12
13 How to approach GDPR in a cloud world Dashboard to monitor across all systems and applications, across controls and tests Active threat defense and attack monitoring Central access and identity management across systems and applications Security and authorizations Org. structure and master data Policies and Governance around storing and processing personal data including controls to ensure policies and governance work, stress testing CONTROLLER Select a cloud provider who ensures processing within contractual boundaries. Questions to ask how do they protect from data loss and data breaches eg. via encrypted provisioning to prevent attacks on cloud solutions esp. during data exchange, physical penetration prevention at data center, encryption at data storage to prevent unauthorized access, adherence or excelling of industry certifications, etc. For SAP - see: PROCESSOR 13
14 GDPR workstreams Helpful information on SAP and cloud and EU-GDPR GDPR and cloud: SAP Cloud Trust Center data privacy pages GDPR overall: GDPR Landing page on GDPR User Group webinars on Governance Data protection officer Operations Governance and policies Assessments and surveys Personal data breach handling Data subject interactions Assurance and reporting Data access governance Source application functions Personal data 14
15 Get started quickly while enabling a sustainable GDPR program Monitor: Manage and report Assess: Understand what you have Sustainable processes, continuous improvement, and change management Self-assessments and internal audit of compliance Reporting for DPO and internal/external stakeholders Include reports from processor Monitor Assess GDPR requirements for your company Personal data and the business or legal need for it Privacy-related policies and procedures Existing systems to protect data Contracts with cloud provider (processor) Respond: Execute on your plan Appropriate tools for your DPO Respond Plan Plan: Find gaps and plan solutions GDPR requirements not met Required data protection, security, and access governance Data protection impact assessments (DPIA) to focus efforts Required data subject interactions to protect rights Updated policies, procedures, internal controls, and training Authorization and access management System and application alternatives to fill gaps, prioritized based upon risk and critical path 15
16 We make it happen. Thank you. Heike Fiedler-Phelps SAP Cloud Trust Center
17 2017 SAP SE or an SAP affiliate company. All rights reserved. No part of this publication may be reproduced or transmitted in any form or for any purpose without the express permission of SAP SE or an SAP affiliate company. The information contained herein may be changed without prior notice. Some software products marketed by SAP SE and its distributors contain proprietary software components of other software vendors. National product specifications may vary. These materials are provided by SAP SE or an SAP affiliate company for informational purposes only, without representation or warranty of any kind, and SAP or its affiliated companies shall not be liable for errors or omissions with respect to the materials. The only warranties for SAP or SAP affiliate company products and services are those that are set forth in the express warranty statements accompanying such products and services, if any. Nothing herein should be construed as constituting an additional warranty. In particular, SAP SE or its affiliated companies have no obligation to pursue any course of business outlined in this document or any related presentation, or to develop or release any functionality mentioned therein. This document, or any related presentation, and SAP SE s or its affiliated companies strategy and possible future developments, products, and/or platform directions and functionality are all subject to change and may be changed by SAP SE or its affiliated companies at any time for any reason without notice. The information in this document is not a commitment, promise, or legal obligation to deliver any material, code, or functionality. All forward-looking statements are subject to various risks and uncertainties that could cause actual results to differ materially from expectations. Readers are cautioned not to place undue reliance on these forward-looking statements, and they should not be relied upon in making purchasing decisions. SAP and other SAP products and services mentioned herein as well as their respective logos are trademarks or registered trademarks of SAP SE (or an SAP affiliate company) in Germany and other countries. All other product and service names mentioned are the trademarks of their respective companies. See for additional trademark information and notices.
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