Security versus privacy — when should we choose to forget?

What has changed?

  • The General Data Protection Regulation (GDPR) (EU) 2016/679 and UK Data Protection Act (2018) has expanded the definition of ‘personal data’ to a much wider scope.
  • As a result of the above, we need to pay a lot more attention to tertiary identifiers that previously didn’t receive a lot of focus — such as online identifiers.
  • GDPR programmes made people realise they were never really compliant with previous data protection legislation so did a huge catchup which took more effort than it should have done.

What hasn’t changed?

  • We should have already been thinking about how long we keep data for — regardless of purpose: function; analytics or security et al.
  • The rights of the Data Subject being important.
  • Organisational needs for analytics and security being important.
  • Personally Identifiable Information (PII) only being a subset of ‘Personal Data’.
  • Personal Data should only be collected legally and retained for as long as reasonably required.

What does this all mean?

Data retained for analytics

Data retained for security

A pseudo-informed stab at data retention timings

Internal systems

  • administrative access and activity through administrative functions like SSH Bastions and AWS Console
  • access and merge history on repository platforms such as Github.com
  • access to email accounts or document services

External systems

  • end-user logins
  • material end-user actions (for example, making a payment or what you would consider a ‘transaction’)
  • contact and password changes (not the data itself, but the changing thereof)

You *should* collect the data you *need*

Use the data you have

The concepts are simple, implementation is hard

The underlying and overriding principle

The thin blue line between technology and everything else. joelgsamuel.com

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Joel Samuel

Joel Samuel

The thin blue line between technology and everything else. joelgsamuel.com

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