GDPR implementation part 6: Access Control and Permissions

In part 3 of this blog series we described how we mapped the “world” of our operations, including the following components:

  • Server infrastructure, including all servers and other hardware as well as the links between these.
  • Software components that comprise our application stack from the operating system level to the front-end application level.
  • Data networks, including how and where our serves are connected to the Internet, but also the Local Area Network at our premises.
  • Data inventory, i.e. all personal data including customer and employee data, financial records, information about partners/associates, etc.
  • Applications necessary to run the company itself, meaning software that is managerial in nature.

Access control concerns permissions attached to system-related objects. Within each of the components listed above, there may be several sub-objects — servers, software modules, data files, catalogues etc., to which restricted access should be implemented.

Creating an Access Control Table

These objects then form one axis of an Access Control matrix or table (ACT). The other axis of the table include organizational units, broken down into person-related objects, for instance segments or groups, but also individuals, for each unit.

After breaking these objects down to an appropriate level, we attached roles to each of these components. In terms of the GDPR, data processor and data controller are examples of roles to use in this context.

To each of the defined roles, we attached categories of tasks, for instance sysadmin, developer, and support staff tasks.

For our email service systems we found it convenient to structure the system-related objects in 3 main categories:

  • General software.
  • Application software.
  • Personal data.

Within each of these categories there are various numbers of objects, to which access permissions are attached, comprising the Access Control Table for the realm in question. For other realms of our “world” we used a similar approach, resulting in a number of ACTs that implement a principle of least privilege.

With this the groundwork was laid for establishing various mechanisms for implementing the access control regime, in order to secure our most precious pieces of hardware, software, and data.

In our next blog post in this series we will look at Information and Tools for Implementation of Users’ Rights.

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