GDPR implementation part 5: Risk Assessment and Gap Analysis

In previous posts in this blog series we have referred to our main planning document, Rules and Regulations for Information Security Management, or RRISM for short, where our road to GDPR compliance started out. In that document we worked out the structure of the project, based on descriptions and definitions of the various components.

Obviously, risk management has to be taken very seriously, and the RRISM lays the groundwork for how we should handle this aspect of information security. The baseline is that risk management is an essential part of the company’s life, and one that comprises all its assets.

Defining and assessing risks

As usual, we first had to agree upon some definitions, and we found the following to be adequate for our purpose — directly from NIST (National Institute of Standards and Technology):

Risk is the net negative impact of the exercise of a vulnerability, considering both the probability and the impact of occurrence. Risk management is the process of identifying risk, assessing risk, and taking steps to reduce risk to an acceptable level.
Risk is a function of the likelihood of a given threat-source’s exercising a particular potential vulnerability, and the resulting impact of that adverse event on the organization.

In order to assess risks, we first have to identify possible threats that may exploit vulnerabilities in our systems or our organization.

In short: Risk management shall first and foremost have as objective to protect assets that are at potential risk.

Analyzing assets

Then we outlined the methodology we adopted:

Identify the assets that could be at risk.
Identify possible threats and vulnerabilities.
Identify the possible consequences of each potential vulnerability.

Each threat was characterized by probability and criticality which together gives one of four risk levels: Very High (red), High (orange), Medium (yellow), and Low (green). This helped us decide what we should prioritize regarding improvements, measures, and other actions.

Analyzing our assets we actually found more of these than anticipated, grouped in 21 different asset types, ranging from our customer base, general software in use and our own key business systems, through hardware and communication lines, and employees and partners – and more.

Threat, vulnerability, and gap analysis

Then we reviewed the vulnerability potentials (what could go wrong) for each asset and created scenarios for possible consequences if something happened that exploited a vulnerability.

The question raised thereafter was: Do we have the necessary measures and remedies in place to eliminate the potential vulnerabilities, or mitigate the consequences if things went wrong — or is there a gap?

The next step was to find out what actions should be taken in order to close the gaps in cases where we were not satisfied with the situation, and this will be the topic of future blog posts in this series.

Conclusion

Our mantra through this process has been: Threats we can imagine will sooner or later be reality, but never as we expect them to happen, and never where we expect them.

We live in an ever-changing environment, which means that risks have to be monitored continuously, and so our risk assessment and gap analysis is continually evolving as well.

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GDPR implementation part 4: Information Security Policy

The groundwork for compliancy

Privacy and security has always been a part of the Runbox culture. However, the GDPR project made it clear to us that we had to systematically work through how to implement the various aspects of data protection and information security.

Let’s start by recalling the meaning of some important terms:

Privacy is about individual’s right to a private life, and the right to control all information about themselves. Grounded in European Convention on Human Rights (1950), the Norwegian Constitution § 102 states that “Everyone has the right to the respect of their privacy and family life, their home and their communication.” followed by “The authorities of the state shall ensure the protection of personal integrity».

Norway’s law on privacy, the Personal Data Act (PDA¹), was introduced as early as 1978, so we have tradition for this kind of legislation. That’s why the GDPR², in principle, didn’t result in significant changes.

In order to protect privacy, Information Security (IS) is crucial. It is mainly about how to prevent personal data from going astray, but we had to go for a more stringent definition: To secure confidentiality, integrity, authenticity, availability (for the approved purpose only), reliability, resilience (the ability to recover), possession (ownership), and utility (readable for the approved purpose) of the data.

With this in mind, we developed our Information Security Policy (ISP) as a documentation of the GDPR compliancy practices, and GDPR requirements to employees and states the company’s commitment to compliance. Article 24 in the GDPR demands controllers (such as Runbox) to implement appropriate data protection policies, and our ISP is an important part of our response to that requirement.

The purpose of Runbox’ Information Security Policy is to provide rules and guidance for Runbox’ employees, Runbox’ contractual employees/consultants, and everyone else working for Runbox, voluntarily or according to contract/agreement, so that they in all respects act

to comply with the company’s information security policies,
to comply with the company’s Privacy Policy and Terms of Service regarding our obligations to our customers,
to ensure that the processing of Personal Data is in accordance with the PDA/GDPR and ensure that appropriate technical and organizational measures are adapted to the purpose, extent and context of the processing, and ensure that such measures are adapted to the risks for the rights and freedoms of natural persons³.

The ISP is a very comprehensive document, stating our commitment to the protection of our customer’s data, and defining technical and organizational measures to fulfill this obligation.

For instance, we will not store customer’s data on any “cloud” (we use our own servers), we shall never disclose account information or email data to authorities (unless presented with a court order from the Norwegian prosecuting authority), and we shall never scan customer’s data to display ads. More information about this can be found on our Privacy Protection page.

An important aspect of the ISP is to define the responsibilities of two roles/positions: The Managing Director is the personified Data Controller, responsible for GDPR compliancy on behalf of the company, and the appointed Data Protection Officer, who is a watchdog regarding the company’s status where GDPR is concerned.

The ISP imposes strict rules for employees, partners, consultants etc. on how to handle systems and data, anchored in a No Disclosure Agreement and Agreement on Protection of Personal Data. This includes rules for how to process and store data and how to protect digital devices.

Finally, let’s mention that the ISP provides rules for contractual agreements with organizations Runbox has partnered with, consultants etc. so that appropriate technical and organizational measures are implemented to ensure GDPR-compliant data processing and systems development.

All together, we have developed two documents that serve as guidance, and control our behavior regarding the GDPR. These are the RRISM (planning document, mentioned in an earlier blog), and the ISP. It is worth mentioning that these documents are continuously updated when new privacy and security issues arise.

1 The Personal Data Act (the PDA) means the regulations that are currently in force in Norway for the protection of individuals in connection with the processing of personal data, which includes the implementation of GDPR in Norway (2018-07-20).

2 The GDPR means Regulation EU 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46 / EC General Data Protection, General Data Processing Regulation. Article refers to Article in the GDPR.

3 See GDPR Article 4(1).

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GDPR implementation part 3: Mapping our “world”

This is the third post in our series on Runbox’ GDPR implementation.

After having structured our GDPR project, the next piece of necessary groundwork was to map out status on relevant facts about important areas of our business. The reason is that it’s impossible to establish and maintain good security and privacy – and to determine GDPR compliancy — if the “territory” is not clearly described.

The “territory”

The “territory” in question was foremost and first of all,

The email service delivery system, that is the Webmail and backend systems and files – the development platform that is used, the components of which the system is built, the dependencies between the components, description of access points etc. – while being well aware of that the GDPR compliancy also includes Privacy of Design requirements.

Other realms that are necessary to describe were for example:

The economic system in which the company operates; i.e. mapping out the network of organizations with which our company is involved – including partners, associates, suppliers, financial institutions, government agencies, and so on – in order to serve our customers.
Server infrastructure with all physical links and channels, and not the least: All software components.
Data networks, including how and where our serves are connected to the Internet, but also the Local Area Network at our premises.
Data catalogue, including of course all personal data, that is, what kind of data are registered on customers and also employees and partners/associates as well.
Applications of all sorts necessary to run the company – applications that are managerial of nature.

Level of description

One problem encountered is how detailed the descriptions should be. Too many details will make the job unnecessarily big in the first place, followed by a lot of maintenance to keep the documentation current.

We chose to start with a “helicopter view”, to obtain an overview of the different realms with the intention to fine-grain the documentation depending on the requirements of the ultimate goal: To identify areas where privacy and security is of concern, ticking off issues that are well taken care of in light of the GDPR, or followed up with measures to improve the situation to achieve GDPR compliancy.

Of course, the GDPR Implementation Project is not a sequential one, as development projects seldom are. Therefore, from time to time we had to go back and adjust our planning tools when needs arose.

The next blog post in this series will concern our Information Security Policy.

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GDPR implementation part 2: Structuring our GDPR project

As mentioned in our previous blog post about our GDPR project plan, we structured our implementation plan in 14 sub-projects.

In this blog post we’ll take a look at the first of these sub-projects.

Mapping status compared to the Regulation

The foundation for the sub-projects was (of course) the requirements in the GDPR Regulation, which we had mapped in subproject # 1: Compliancy Status Tables mapping Runbox’ status compared to regulations.

In order to prepare ourselves, we did that before the final regulation was decided. We also did this for the requirements from the Norwegian Personal Data Regulation at that point in time.

Of course, the mapping had to be made compliant with the final version of the GDPR after the EU decision in 2016 – and so we did.

Controller and processor

At that point in time, we had our project nicely structured in the 14 sub-projects mentioned above. That was pretty easy, because of the mapping we had done. An important fact in this context, is that Runbox is a controller and a processor as well, depending on the circumstances, according to the GDPR definitions. It was important to be exact about where and when.

Subprojects definitions and delimitations

In the GDPR we found some important points that we had to consider:

Our agreement with our main processor, Copyleft Solutions – and what about the agreements with our affiliates, partners and the like? Are confidentiality clauses regarding protection of personal data adequate any longer?
Do our Terms of Service and Privacy Policy correspond to the new requirements?
What changes have to be done in our systems to fulfill GPDRs requirement regarding customers’ rights?
Do we have a systematic documentation of our systems, and what about access control?
Does our information security policy cover the necessary elements, and is our risk analysis up to date?
What about the processing of personal data we do for internal processing? Obviously it was necessary to take a look into the agreements we have with internal and external personnel.
What about the internal control mechanism we have – do they comply?

Those points (and some more) made the foundation for establishing delimitations between each sub-project, which we will continue blogging about in the weeks to come.

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Runbox’ road to GDPR compliance

How we did it and what we learned on the way

In our blog post May 25, 2018 we described the main areas of Runbox’ GDPR implementation.

On this Data Privacy Day we’d like to update you on our GDPR implementation, how we did it, and what we learned on the way.

There is an enormous amount of information out there describing GDPR content, simple copies of the regulation, some templates of varying quality – and a lot of warnings.

So first of all, let’s recap what the GDPR is.

What is the GDPR, and why did it come about?

In 2012, the European Union (EU) first proposed a set of rules for protection of data inside and outside the EU. An important reason for this decision was a desire to improve the ability for individuals to control data registered about themselves.

In 2016, the GDPR (General Data Protection Regulation) was formally adopted by the European Parliament and the Council of the European Union to take effect for all individuals within the EU and the European Economic Area (EEA).

Runbox’ approach to the GDPR

At Runbox, which is located in the privacy bastion Norway and within the EEA, we started the GDPR planning and implementation process as early as 2014.

At that point in time, we had followed the process in the EU about a comprehensive reform of the EU’s 1995 data protection rules. In the spring of 2014, the European Parliament demonstrated strong support for the GDPR proposal set forward by the Article 29 Working Party. (You can find more information about the history of the GDPR in the article The History of the General Data Protection Regulation.) Shortly thereafter, in September 2014, our GDPR Compliancy Project was launched.

We didn’t know at that time when the GDPR would take effect, but we knew the direction – that is: The GDPR was indicated to move in the direction of existing Norwegian privacy regulations, based on Article 29 Working Party documents.

Our GDPR project plan

We structured our implementation project in 14 partly parallel sub-projects, and after the decision by the European Parliament and of the Council by April 27, 2016, we updated our project plan towards the target date May 25, 2018.

We started out mapping exactly our position compared to Article 29 proposal, which in 2015 was replaced by The European Data Protection Board, and then we went ahead to work out our main planning document, Rules and Regulations for Information Security Management.

The groundwork was done, and we proceeded the project towards fulfillment of our obligations regarding privacy under the new legislation, implemented in Norwegian law by July 20, 2018.

We will share more information in forthcoming blog posts, so stay tuned!

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GDPR and Updates to our Terms and Policies

On May 25, 2018 the European Union’s General Data Protection Regulation (GDPR) takes effect in all countries in the European Economic Area (EEA).

Norway, where Runbox is located, is part of the EEA and is implementing these regulations through its own legislation.

We welcome these new regulations as they greatly strengthen the rights of the individual to digital privacy and security, which we always have promoted and supported.

What is the GDPR?

The GDPR is a set of regulations declaring that the individual should have control over their personal data by specifying how such data may be collected, processed, and stored.

The regulations require that businesses and organizations integrate this right into their business practices through policies, procedures, and technologies that safeguard the users’ privacy.

Important principles are that personal data are processed lawfully, for legitimate purposes, and with explicit consent from the user. This means that your personal data can only be collected with your permission.

The regulation also sets forth a number of rights on the part of users of digital services:

The right to transparency about how data is processed.
The right to access and information about collected data.
The right to rectify stored data.
The right to erase data (“right to be forgotten”).
The right to restriction of processing.
The right to data portability.

GDPR also recognizes the term “privacy by design”, which means that privacy shall be considered in all circumstances when personal data is processed or stored. By also introducing “privacy by default”, GDPR states that appropriate measures must be implemented to ensure that personal data collected is only used for the specific purpose for which the consent is given.

How does Runbox implement the GDPR?

At Runbox we believe that the privacy and security of your data is essential, and that it’s important for you to be aware of your rights and your options when it comes to your personal data.

Runbox has therefore been working on the implementation of the GDPR throughout our organization and our services over the past three years.

The activities that implement the GDPR in Runbox can be divided into 3 main areas:

Internal policies and procedures
Partners and contractors
Protection of users’ rights

The first two areas include documentation of information security management and internal policies and procedures, as well as data processing and confidentiality agreements with our partners, contractors, and staff.

The third area relates directly to you as a Runbox user, and includes the terms and policies that govern your use of our services, how we aim to inform and educate our users about privacy, and how we are implementing tools and utilities that safeguard your privacy rights.

Runbox’ main areas of GDPR implementation

Revised Terms of Service and Privacy Policy

As part of our GDPR implementation the Runbox Terms of Service and Privacy Policy have been revised:

New Terms of Service effective 25.05.2018
New Privacy Policy effective 25.05.2018

While the Terms of Service has only been updated with minor changes, the Privacy Policy has been restructured and amended. It provides a comprehensive overview of the policies that govern your privacy as a Runbox user, and describes in an accessible way the types of data Runbox collects in order to responsibly and reliably operate an email service.

It also lays out how user data are processed and stored, how they are being protected, and what rights you have as a user of our services.

It’s important to us that you are informed about your rights and your options with regards to your privacy. We ask that you review the revised terms and policies by May 25, 2018 when they take effect, and invite you to contact us with any questions or concerns.

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Our path to GDPR compliance — and how it will strengthen the protection of your personal data

Runbox has been focusing on privacy and information security from day one, and have paid attention to the strict Norwegian legislation concerning the processing of personal data ever since.

Norway is a member of European Economic Area (EEA) and as such has to implement certain EU regulations, even if Norway is not a member of the European Union (EU). When the European Parliament and the Council decided new legislation for the protection of personal data, that legislation also applied in Norway and has to be implemented by May 25, 2018.

The legislation, titled General Data Protection Regulation (GDPR), contains rules for how personal data should be processed. Using the terms of GDPR, this includes how, when, and under which conditions, personal data

can be collected, processed and stored, which demands explicit consent, and explicit stated purpose;
shall be rectified;
shall be deleted (right to be forgotten);
shall be released to the person that owns the data (right to portability);
could be transferred to third parties for processing, where a Data Processing Agreement (DPA) is mandatory;
could be transferred to processors outside EEA.

At Runbox we have followed the development of this new EU legislation from the very beginning, and as early as 2014 we initiated a project in order to become GDPR compliant.

As a first step we started developing a planning document which includes detailed plans for making our information security management complete and consistent. The document laid out a number of activities which are now outlined in 15 sub-projects, of which some are completed, and others are in process of being completed.

However, information security is a continuous effort and the sub-projects will give rise to additional activities far beyond the GDPR framework.

We will keep you updated.

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The Power of Big Tech

Big Tech red letters on black backround with words like market dominance, influence, antitrust probes, corporate power.

The influence of big tech companies on our lives is undeniable. With limited oversight and a focus on maximizing profits, these corporations have become increasingly powerful. They rely on unrestricted access to our personal data to maximize profits, which puts them at odds with any form of regulation. They actively seek to shape policies that protect their lucrative revenue streams, and resist regulatory measures that could limit their power.

Without accountability, big tech companies put profits ahead of our privacy. They leave us vulnerable to misinformation and bias, and contribute to the shaping and manipulation of public opinion. As the digital world continues to develop, we’re likely to see more attempts to deregulate to protect their bottom lines.

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Is Your Email Safe? Why Storing Data in the U.S. is Becoming Riskier

In today’s digital world, protecting our personal data has never been more crucial. With governments, corporations, and hackers all vying for access to our information, it’s important to understand where our data is being stored and who has access to it. Certain countries, such as the United States, have become a concerning destination for data, with its extensive surveillance infrastructure and lack of robust privacy protections.

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