Understanding GDPR and personal data

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General Data Protection Regulation (GDPR) the law imposes new rules on companies, government agencies, non-profits, and other organizations that offer goods and services to people in the European Union (EU), or that collect and analyze data tied to EU residents. The GDPR applies no matter where you are located.

I have been reading the key aspects of the GDPR from the above official site, and thought to summarize the points I came across in order to understand what GDPR is, how we can make the systems complaint to the GDPR.

  1. GDPR is a regulation will take effect in May 2018
  2. It gives more control to the EU citizens over their personal data
  3. GDPR enforces controls over data collection, usage, storage, handling breaches, transparency, expiry and etc.
  4. GDPR puts non-technical regulations as well, in few scenarios. Ex – A must to have data security officer in organization in certain scenarios.
  5. It does not explicitly mention on encryption or end-to-end data protection but the regulatory requirements will force the applications deal with personal data to use those technologies.
  6. Strict security audits, logs and documentation should be in place in order to be complaint with the GDPR.

GDPR defines ‘personal data’ as – any information related to a natural person or ‘Data Subject’, that can be used to directly or indirectly identify the person.

According to the definition name, address, credit card number, social security number, bank account number, telephone number, license number, vehicle number and any other explicit identification information is a personal data. But the following types of data also fall under the personal data category.

  1. Calls to customer care services or any other voice based services where they record the voice of the user. Though the voice record takes place without the name and with the full anonymity, still the voice data itself should be treated as a personal data.
  2. Any video surveillance recordings (CCTV) or any other visual recordings should be treated as personal data (both in the edge and cloud storages).
  3. Any forms of biometric data should be treated personal data.
  4. Drawings which represents the state of a real image like drawing of a portrait, a family or anything which exhibits the behavior of socio cultural aspects of a family or an individual can be considered as personal data.
  5. Value of an asset – this is a number but still considered as a personal when it is linked with the a person’s profile and can be used to guestimate the economic state and the obligation of the person.
  6. Call logs and any other data usage logs.
  7. Real-time geo location monitoring and geo-location data. Ex –  Uber drivers
  8. Meeting minutes and any forms of such data for official purpose which any relatable links or traceable information to a person.
  9. Any sort of medical imagery with traceable information.
  10. Photos, videos and voice recordings of any person on any sort is a personal data.
  11. Any non-aggregated data which reveals consumer patterns on goods and services.
  12. IP addresses – including dynamic IPs

The above list is does not include all, but summarizes the personal data in short from the above link. In my opinion any data seems to be a personal data as long as it can be traced and tracked to a person.

In certain scenarios GDPR ensures the organizations to have non-technical complaints such as having a data security officer and etc.

Encrypting the personal data is a one aspect of GDPR which is covered by the clause of “pseudonymous data”. This does not make the solutions complaint to the GDPR because encrypted personal data is also considered as personal data, but this gives some relaxation on on security breaches and how the breach should be handled and notified.

In summary all the solutions should have the technical and non-technical aspects of

  1. Why we collect and store the personal data
  2. How the personal data is used
  3. Transparency of the usage and sharing policies of the personal data
  4. Store personal data as pseudonymous data
  5. Continuous security auditing and monitoring
  6. Notification to the users upon breaches and policy changes
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