GDPR: Much more than Double-Opt-In

Well, GDPR is now effective. According to a study of DSAG (German SAP User Group) from February 2018, however, only a single-digit percentage of the SAP user companies in Germany are really prepared.

Many obvious topics, such as double-opt-in or the “Right of Access” of personal data (Article 15), are x-fold in a wide range of publications, and there are different approaches how you should or could respond.

Less frequently focused areas – because they are often harder to answer at first sight – should not be forgotten either. These include, inter alia, the “right to be forgotten” / Right to Erasure (Article 17) and the Security of Processing (Article 32), which is focussed on ensuring protection objectives such as confidentiality, integrity and availability.

So each person has the right to know in a timely manner which data is stored for what purpose in company databases. With a decent data model and suitable queries or tools, this can also be wonderfully answered. So far so good.

Availability of Pesonal Data

But what happens if the system is unavailable at a very unfavorable time? What if, due to a forced restore of a single system, data suddenly becomes inconsistent with other systems?

With the Libelle BusinessShadow Libelle AG offers a solution that answers availability and disaster scenarios on a logical level. The advantage: Not only RPO and RTO, but especially the RCO (Recovery Consistency Objective) ensure that companies are knowleadgable again after a short time with consistent data.

The Right to be Forgotten: Blocking, Erasure and Distruction of Personal Data

What if people also want to exercise their right to be forgotten?

If there is no ongoing business relationship, the company must regularly ensure that personal data is no longer stored in their systems. In contrast, however, there are also legal obligations to preserve records, for which also terminated business transactions must also be tracked.

Among other things, Libelle AG’s Master Data Services Suite (MDSS) provides a toolset that works with a data vault. It stores such master data whose lifecycle has been terminated from the GDPR point of view – both regularly determined and triggered explicitly. In the productive data, only a deletion / blocking indication is visible, while the real data in the data vault is available to persons with a further legitimate interest.

Confidentiality and Protection of Personal Data

In addition to the right to be forgotten, the issue of the appropriation of personal data is also one major topic. Only data that is required for the specific business purpose may be processed, and only by a group of persons with a legitimate interest. For productive environments, this is a procedural / organizational question and, of course, the subject of the authorization system.

But what about non-productive environments? In practice, QA / project / training systems are still updated with classic system refreshes. Ergo: Productive data in non-productive environments. Usually, a large number of unauthorized persons (developers, consultants, admins) have access to this real data. Maybe not daily updated, but still very clearly personal. The possibilities of restricting unauthorized access to confidential data: either a comprehensive authorization concept analogous to the productive environment, but often contradicting the intended use of non-productive environments. Or make sure that real-life personal data becomes what these systems really need: test data. The approach for this is the anonymization of the real data, so that they no longer have a specific personal reference.

Here, however, attention is to be paid to meaningfulness and logical consistency, both within the system and across system boundaries within the landscape.

For this purpose, Libelle AG also offers Libelle DataMasking (LDM), a tool that anonymizes data on non-productive systems and system landscapes on a logical level. Thus, business processes can continue to be tested to their hearts content end-to-end.

You have questions and would like to know more?