"There is always an easy solution to every problem - neat, plausible, and wrong.
Finally, it's beginning: GDPR gains more and more visibility.
Do you also get more and more GDPR-related marketing communication from IAM and security vendors, consulting firms and, ehm, analyst companies? They all offer some pieces of advice for starting your individual GDPR project/program/initiative. And of course, they want you to register your personal data (Name, company, position, the size of a company, country, phone, mail etc...) for sending that ultimate info package over to you. And obviously, they want to acquire new customers and provide you and all the others with marketing material.
It usually turns out that the content of these packages is OK, but not really overwhelming. A summary of the main requirements of the GDPR. Plus, in the best cases, some templates that can be helpful, if you can find them between the marketing material included in the "GDPR resource kit". But the true irony lies in the fact that according to the GDPR it is not allowed to offer a service that has a mandatory consent on data that is not needed for the service being offered (remember?… Name, company, position, the size of a company, country, phone, mail etc...).
The truth is, that GDPR compliance does not come easily and the promise of a shortcut and an easy shortcut via any GDPR readiness kit won't work out. Instead, newly designed but also already implemented processes of how personal and sensitive data is stored and processed, will have to be subject to profound changes.
Don't get me wrong: Having a template for a data protection impact analysis, a prescanned template for breach notification, a decision tree for deciding whether you need a DPO or not, and some training material for your staff are all surely important. But they are only a small part of the actual solution.
So in the meantime, while others promise to give you simple solutions, the Kantara Initiative is working on various aspects for providing processes and standards for adequate and especially GDPR-compliant management of Personally Identifiable Information. These initiatives include UMA (User-Managed Access), Consent and Information Sharing, OTTO (Open Trust Taxonomy for Federation Operators) and IRM (Identity Relationship Management).
Apart from several other objectives and goals, one main task is to be well-prepared for the requirements of GDPR (and e.g. eIDAS). The UMA standards is now reaching a mature 2.0 status. Just a few days ago two closely interrelated documents have been made available for public review, that makes the cross-application implementation of access based on provided consent possible. "UMA 2.0 Grant for OAuth 2.0 Authorization" enables asynchronous party-to-party authorization (between requesting party = client and resource owner) based on rules and policies. "Federated Authorization for User-Managed Access (UMA) 2.0" on the server side defines and implements authorization methods that are interoperating between various trust domains. This, in turn, allows the resource owner to define her/his rules and policies for access to protected resource in one single place.
These methods and technologies serve two major aspects: They enable the resource owner (you and me) to securely and conveniently define consent and implement and ensure it through technology. And it enables requesting partners (companies, governments, and people, again you and me) to have reliable and well-defined access in highly distributed environments.
So, they need to be verified if they can be adequate methods to getting to GDPR compliance and far beyond: By empowering the individual, enabling compliant business models, providing shared infrastructure and by designing means for implementing reliable und user-centric technologies. Following these principles can help achieving compliance. "Beyond" means: Take the opportunity of becoming and being a trusted and respected business partner that is known for proactively valuing customer privacy and security. Which is for sure much better than only preparing for the first/next data breach.
This surely is not an easy approach, but it goes to the core of the actual challenge. Suggested procedures, standards, guidelines and first implementations are available. They are provided to support organizations in moving towards security and privacy from the ground up. The UMA specifications including the ones described above are important building blocks for those who want to go beyond the simple (and insufficient) toolkit approach.
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