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

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).

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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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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:

  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.

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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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Data Privacy Day

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.

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“Drop Gmail, Outlook, and iCloud: Norwegian challenger clearly best on privacy”

Runbox is hailed in a major Norwegian news outlet for providing superior privacy protection.

The article is based on a study by Vienna University of Business and Economics, which compares Runbox to 4 other major email services.

Gmail is slammed in the same article for its poor default privacy settings and a pattern of privacy violations.

Comparison of email providersIn the study, Runbox scores high in all categories:

  • Informational Control: 7/7
  • Decisional Control: 7/7
  • Behavioral Control: 6/7
  • Privacy Friendly Defaults: 7/7
  • Technology Paternalism: 5/7
  • Privacy By Design: 6/7
  • Service Appeal: 5/7

At Runbox we are very happy with this increasing focus on privacy, which supports our long-held privacy commitment and our work on compliancy with EU’s General Data Protection Regulation.

The full digi.no article (in Norwegian) can be seen below in PDF format.

Dropp Gmail, Outlook og Icloud- Norsk u...rer klart best på personvern - Digi.no

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New Terms of Service and Privacy Policy in effect

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.

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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 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.

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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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Runbox is leaving the Facebook platform

#DeleteFacebook
#DeleteFacebook

At Runbox we work conscientiously every day to ensure that we act in accordance with our Company Values, and as an extension of these, our Terms of Service and Privacy Policy.

We have carefully implemented these policies in order to protect our users’ privacy as outlined in our Privacy Commitment, and we are currently working hard to obtain compliancy with the forthcoming General Data Protection Regulation introduced by the EU.

This also means that we are conscious about how Runbox interacts with other Internet services such as social media networks. Therefore we have been disappointed by the recent revelations about the privacy intrusions and unethical practices by Facebook.

As a consequence we have decided to remove the Runbox page from the Facebook platform.

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