GDPR implementation part 8: “Personal data” in the EU and the US is not the same

February 13, 2020 Leave a comment

We usually think of “personal data” as a term that contains for instance a person’s full name, home address, email address, telephone number, and date of birth.

These are ordinary data that can obviously identify a specific person. But in the personal data category of linked personal information are also data such as social security number, passport number, and credit card numbers – data that can identify us, and data we usually feel more restrictive about.

Linkable and non-linkable information

But there is another category of data that on its own may not be able to identify a person, but combined with other information could identify, trace, or locate a person. Such data are gender, race, sexual orientation, workplace, employment etc. These are examples of linkable personal information.

Then we have the category non-personally identifiable information. That is data that cannot be used on its own to identify or trace a person, for example IP addresses, cookies, device IDs, and software IDs (non-linkable personal information).

Privacy regulations differ in the EU and the US

Now, we know that there are industries that exist almost under the radar while taking advantage of personal data. For instance, companies in the AdTech and MarTech industry base their business on collecting and trading personal data for targeted advertising and marketing.

Many of these actors try to take protection of personal data seriously, and refer to the rules and regulations for processing personal data. In Europe this is the GDPR (General Data Protection Regulation) within the EU/EEA-area1, and in the US it is the responsibility of the FTC (Federal Trade Commission).

However, what the EU/GDPR and US government agencies mean by “personal data” is different. Specifically, the definition by EU/GDPR is more comprehensive than the definition often referenced by US agencies, such as that of NIST (National Institute of Technology).

For example, the EU concept of personal data includes information such as cookies and IP addresses, which are not considered as personal data in a US setting.2

This means that if US websites in their privacy policy state that they are GDPR compliant, but combine their data with other data sets, they may breach the GDPR. For example, they must have the user’s consent to collect their IP address under the GDPR.

Definitions of “personal data”

National Institute of Technology’s definition

NIST’s definition of personal data is contained in the definition of Personal Identifiable Information (PII):

PII is any information about an individual maintained by an agency, including (1) any information that can be used to distinguish or trace an individual‘s identity, such as name, social security number, date and place of birth, mother‘s maiden name, or biometric records; and (2) any other information that is linked or linkable to an individual, such as medical, educational, financial, and employment information.

US Office of Privacy and Open Government’s definition

Another PII-definition is from the US Office of Privacy and Open Government (OPOG) as follows:

The term personally identifiable information refers to information which can be used to distinguish or trace an individual’s identity, such as their name, social security number, biometric records, etc. alone, or when combined with other personal or identifying information which is linked or linkable to a specific individual, such as date and place of birth, mother’s maiden name, etc.

EU’s GDPR definition

Compare these PII-definitions with the GDPR Article 4(1)’s definition of personal data:

…‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

It is obvious that GDPR defines personal data much broader than both NIST’s and OPOG’s PII, and this is underlined by this statement found in GDPR’s Recital 30:

Natural persons may be associated with online identifiers provided by their devices, applications, tools and protocols, such as internet protocol addresses, cookie identifiers or other identifiers such as radio frequency identification tags. This may leave traces which, in particular when combined with unique identifiers and other information received by the servers, may be used to create profiles of the natural persons and identify them.

The US is lacking comprehensive regulation

That said, US authorities are moving towards stronger protection of privacy and personal data, but as late as March 2019, the US Congressional Research Service says:

Despite the increased interest in data protection, the legal paradigms governing the security and privacy of personal data are complex and technical, and lack uniformity at the federal level. The Supreme Court has recognized that the Constitution provides various rights protecting individual privacy, but these rights generally guard only against government intrusions and do little to prevent private actors from abusing personal data online. At the federal statutory level, while there are a number of data protection statutes, they primarily regulate certain industries and subcategories of data. The Federal Trade Commission (FTC) fills in some of the statutory gaps by enforcing the federal prohibition against unfair and deceptive data protection practices. But no single federal law comprehensively regulates the collection and use of personal data (our emphasis).

Conclusion

When US websites claim to follow the rules for processing personal data it is dubious at best, compared to the regulations in the EU/EEA – which the Norwegian legislation is based on and is what Runbox adheres to.

However, it should be mentioned that some US states, for instance California, do classify some anonymous data (i.e. IP-addresses, aliases and account data) as PII.

In addition, as stated in our Privacy Policy, the personal data we ask customers to register in order to use our service is very limited. We are conscious about the trust our customers place in us when they register personal data in our systems, and in return we can demonstrate that we are compliant with the regulations.

Addendum

Above we referred to the AdTech and MarTech industries and their usage of personal data to identify, trace, or locate a person for advertising and marketing purposes. That topic is outside the scope of this blog post, but is absolutely worth writing about in a later post.

1 EEA = European Economic Area, that is the EU and three countries: Iceland, Lichtenstein, and Norway.

2 https://www.forbrukerradet.no/out-of-control/ footnote on page 102.

Continue Reading →

GDPR implementation part 7: Information and Tools for Implementation of Users’ Rights

November 23, 2019 Leave a comment
GDPR

One of the main objectives for the European Union (EU) when they developed the replacement for the Data Protection Directive 95/46 (from 1995), was to expand individual control over the use of personal data.

This can be seen in a broader view as an implementation of the right to one’s private life, as laid down in the European Convention on Human Rights (Article 8). The right to respect for one’s private and family life is also stated in the EU Treaty on Fundamental Rights (Article 7).

Norway has signed both of these agreements, and the Constitution of Norway implements these rights in Article 100 and 102 of the Constitution and in the Norwegian Human Rights Act.

Already in GDPR1 Article 1 we see the connection between the GDPR and especially the Treaty on Fundamental Rights:

This Regulation protects fundamental rights and freedoms of natural persons and in particular their right to the protection of personal data

Article 1-2 of the GDPR

Observe the expression “rights and freedoms of natural persons“, which is very important throughout the Regulation and is used 31 times in all.

Before we go further into the subject of this post, it is important to state that Norway’s legislation on the processing of personal data was already compliant with the GDPR before the latter was declared as the new framework for the legislation in Norway. The Norwegian Personal Data Act (PDA2), as compliant with the GDPR, tok effect 20 July 2018.

First and foremost, the GDPR states that no processing of personal data shall be done unless the data subject has given consent (Article 6-1, a). Runbox obtains consent to registration of our users’ personal data when they sign up for an account and accept our Terms of Service.

The GDPR (Article 6-1, ff.) allows a controller – that is Runbox in our context – to process personal data when there is a legitimate reason for doing so, i.e. something that is necessary to use our services.

It is an important objective for the GDPR to secure one’s control of one’s own personal data. In this respect, the GDPR has given the data subjects eight fundamental rights (Article 15—17).

When implementing these rights in Runbox, we found that most of those were already there. However, the introduction of the GDPR provided us with a checklist and the opportunity to analyze our status, and to improve our services in this respect.

Our Privacy Policy provides exhaustive information about how we process personal data, but here is an overview of the data subject’s rights, and our implementation of them:

  • The right to access (Article 15): Since Runbox does not collect other types of information than what the users register by themselves, they can easily check which personal data is processed. The data processing is only done in order to process your emails, and optionally your web site and domain name.
  • The right to rectification (Article 16): You may at any time log in to your email account and change your personal information.
  • The right to erasure (‘right to be forgotten’) (Article 17): You may terminate your subscription any time, and your account contents will subsequently be deleted after 6 months. Your personal details data will be deleted after 5 years in accordance with Norwegian accounting regulations. However, you may send a request to dataprotectionofficer@nullrunbox.com for immediate erasure of your account contents.
  • The right to restriction of processing (Article 18): Runbox will never use your personal information for purposes other than providing our services to you, so restrictions are not necessary in our context.
  • The right to be informed (Article 19): Runbox uses your personal information only in order to provide our services to you..
  • The right to data portability (Article 20): In case that you wish to move to another email service provider and export your data, you will find information on how to do this through our services and documentation.
  • The right to object (Article 21): Since we never will use your personal data for other purposes than to deliver the services you have agreed to, this right is implicitly fulfilled.
  • The right to individual decision-making (Article 22): This article is intended to protect data subjects against automated data-processing that might involve profiling them based on personally identifiable information, which is something Runbox doesn’t do.

Regarding questions or concerns about our implementation of the GDPR, customers may use the email address dataprotectionofficer@nullrunbox.com as a direct channel to our appointed Data Protection Officer.

Some final remarks about consent: Runbox uses cookies in order to provide our services, and new users must give express consent to this on our signup page. On this page, and on the Account page once logged in, you may also give/revoke consent to future news and offers from Runbox.

In our next post in this series, we will consider our contractual situation regarding GDPR requirements. Stay tuned.

Footnotes

1. 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, unless stated otherwise.

2. 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).

Continue Reading →

GDPR implementation part 6: Access Control and Permissions

October 24, 2019 Leave a comment

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.

Continue Reading →

GDPR implementation part 5: Risk Assessment and Gap Analysis

September 15, 2019 1 Comment

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:

  1. Identify the assets that could be at risk.
  2. Identify possible threats and vulnerabilities.
  3. 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.

Continue Reading →

GDPR implementation part 4: Information Security Policy

July 17, 2019 2 Comments

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).

Continue Reading →

GDPR implementation part 3: Mapping our “world”

June 5, 2019 Leave a comment

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.

Continue Reading →

GDPR implementation part 2: Structuring our GDPR project

March 21, 2019 Leave a comment

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.

Continue Reading →

Data Privacy Day

January 28, 2019 Leave a comment

January 28th is Data Privacy Day, and was initiated by the Council of Europe in 2007. Since then, many advances to protect individuals’ right to privacy have been made.

The most important of these is the European Union’s General Data Protection Regulation (GDPR) which was implemented on May 25, 2018. Runbox has promoted data privacy for many years, anchored in Norway’s strong privacy legislation.

At Runbox, which is located in the privacy bastion Norway, we believe that privacy is an intrinsic right and that data privacy should be promoted every day of the year.

Your data is safe in the privacy bastion of Norway

We’re pleased that Data Privacy Day highlights this important cause. Many who use the Internet and email services in particular may think they have nothing to hide, not realizing that their data may be analyzed and exploited by corporations and nation states in ways they aren’t aware of and can’t control.

While threats to online privacy around the world are real and must be addressed, we should not be overly alarmed or exaggerate the problem. Therefore we take the opportunity to calmly provide an overview of Norway’s and Runbox’ implementation of data privacy protection.

Norway enforces strong privacy legislation

First of all, Norway has enacted strong legislation regulating the collection, storage, and processing of personal data, mainly in The Personal Data Act.

The first version of Norway’s Personal Data Act was implemented as early as 1978. This was a result of the pioneering work provided by the Department of Private Law at the University of Oslo, where one of the first academic teams within IT and privacy worldwide was established in 1970.

Additionally, the Norwegian Data Protection Authority, an independent authority, facilitates protection of individuals from violation of their right to privacy through processing of their personal data.

For an overview of privacy related regulations in the US, in Europe, and in Norway, and describes how Runbox applies the strong Norwegian privacy regulations in our operations, see this article: Email Privacy Regulations

Runbox enforces a strong Privacy Policy

The Runbox Privacy Policy is the main policy document regulating the privacy protection of account information, account content, and other user data registered via our services.

If you haven’t reviewed our Privacy Policy yet we strongly encourage you to do so as it describes how data are collected and processed while using Runbox, explains what your rights are as a user, and helps you understand what your options are with regards to your privacy.

Runbox is transparent

Runbox believes in transparency and we provide an overview of requests for disclosure of individual customer data that we have received directly from authorities and others.

Our Transparency Report is available online to ensure that Runbox is fully transparent about any disclosure of user data.

Runbox is GDPR compliant

Runbox spent 4 years planning and implementing EU’s General Data Protection Regulation, starting the process as early as 2014.

We divided the activities implementing the GDPR in Runbox into 3 main areas:

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

This blog post describes how we did it: GDPR and Updates to our Terms and Policies

Runbox' GDPR Implementation

More information

For more information about Runbox’ commitment to data privacy, we recommend reviewing the Runbox Privacy Commitment.

Continue Reading →

New Terms of Service and Privacy Policy in effect

May 25, 2018 5 Comments

As announced one month ago, our new Terms of Service and Privacy Policy implementing the European Union’s General Data Protection Regulation (GDPR) take effect today.

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.

Important principles include that personal data must be processed lawfully, for legitimate purposes, and with explicit consent from the user.

Runbox’ privacy commitment

Runbox has always been committed to the privacy of our users, and the GDPR principles are now fully integrated into our Privacy Policy. 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.

To find out more about our GDPR implementation, please see our previous blog post GDPR and Updates to our Terms and Policies.

Review the new terms and policies

If you haven’t already done so we ask that you review the revised terms and policies now, and invite you to contact us with any questions or concerns.

If you are already a Runbox user or customer you have already actively consented to our Terms of Service when registering a Runbox account, and you do not need to consent again now to the new version.

As a new Runbox user you will have the opportunity to consent to the terms and policies when registering your account.

Continue Reading →

GDPR and Updates to our Terms and Policies

April 25, 2018 2 Comments

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 implementationRunbox' 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:

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.

Continue Reading →