Clouding Within the Lines: Keeping User Data Where It Belongs in the Age of GDPR

By Nathan Narayanan, Director of Product Management, Netskope

Importance around data residency hygiene has been around for a long time, but cloud services that often show up tend to focus more on user productivity and less on user data privacy. The highly-productive nature of these services increases their adoption resulting in a higher risk to the privacy of data.

According to Gartner, by May 25, 2018 (the day that GDPR takes effect) less than 50 percent of all organizations will be fully compliant with the EU’s General Data Protection Regulation (GDPR). It’s time to take steps to keep up.

Here are some things to consider.

Identify important data. Enforcing a very broad policy on all types of content can be too restrictive and may hinder productivity. Enterprises will need to identify critical data that will needs to be controlled within the geo-boundaries. This may be data relating to regulatory mandates such as health records, personally identifiable information and even company confidential data. All other content that do not fall under these constraints need not be controlled within the geo-boundaries.

Determine your geo-boundary and monitor movement of your data. According to the Netskope Cloud Report 40.7 percent of cloud services replicate data in geographically dispersed data centers. With this in mind, you need to keep your important data where it belongs, you also need to determine the boundaries where the data should reside. In some cases, PII may be required to stay with a region such as EU and in other cases it may be required to stay within the narrow bounds of a country such as Germany. A CASB can perform content inspection to identify important data as well as report on the movement of such data. To control data traveling beyond the geo-boundaries will require the CASB solution to map IP address into graphical locations and proactively apply policies to keep the data where it should reside.

Ensure cloud services enforce geo-control. Get visibility into the cloud services used by your organization and understand how ready these applications are for enterprise use. A CASB can also allow you to rate cloud services from a GDPR readiness standpoint. This rating is usually based on research on the cloud service and considers factors such as SLAs around data residency, level of encryption of the content processed, and terms in the agreement between the enterprise and the cloud service. For example, applications that take ownership of the user data will be rated poorly for GDPR readiness. Since 66.9 percent of cloud services do not specify if you or they own your data in their terms of service, finding out this information might take longer than you think.

Build policies to ensure data is within its geo-boundaries. No matter how ready the cloud services are, there may be a legitimate need to move data outside the region for business reasons. Also, sometimes employees may inadvertently move data outside its geo-boundaries. There are several steps you can take to proactively enforce geo-control in these situations. A CASB solution can help with enforcing a policy so that data is encrypted if moved outside the geo-boundaries for legitimate reasons. In all other cases, enforce policies to simply stop data from leaving the geo-boundary.

Remember employees will often travel outside the region and will need access to sensitive data so that they can continue to be productive. Ensure policies for such employees continue to respect data residency. It may be easier to simply block traffic to or from certain countries based on how your business is conducted.

Build a process for tighter geo-control. Employees play a big part in the data residency hygiene. Reduce risk by educating users on a periodic basis. A CASB solution can be setup to coach the employee at the time the risky data transfer if conducted. Coaching can also be used to discourage applications that are not ready for geo-control. It is also important to continually monitor and sharpen the policies as you learn how your sensitive data travels.

Want to learn more about GDPR and the cloud? Download Managing the Challenges of the Cloud Under the New EU General Data Protection Regulation white paper.