5 ms·
A lot of not great advice in here. A slightly more realistic approach I’ve seen to a lot of these issues basically boils down to: - minimise PII collection as
by mhoad 4y ago
A lot of not great advice in here.
A slightly more realistic approach I’ve seen to a lot of these issues basically boils down to:
- minimise PII collection as much as possible in general and start thinking of it more like a liability than an asset.
- Isolate the actual PII in your backend and stop passing it around from system to system.
- start working more with “references” to the PII data which is isolated and can be tombstoned when required.
It takes a little bit of thinking around the concept of “identities” and a deep understanding of how data flows through your various systems but getting on that early right from the point of collection makes life a lot easier.
- robin_reala 4y agoPII doesn’t exist in GDPR so certainly don’t start there. “Personal data” is the nearest equivalent, but that includes any data that could be aggregated to identify and individual and is consequently a wider concept.
- mhoad 4y agoYou are certainly correct that the term PII never appears in the legislation but instead the focus is on the ability to identify someone. What I’m saying is that by isolating PII as much as possible you can make that larger task much easier to achieve. You can actually learn a lot from places you might not think of at first like how intel agencies and LE do things like source protection where you have to deal with the concept of a particular identity in a lot of different scenarios and different groups but it’s essential that the person remain unidentifiable at the same time to almost everyone. It’s a very similar set of problems and they have been thinking about this for a long time already.
- gghhzzgghhzz 4y agoagree with this. If done well, then this has all sorts of secondary benefits. better engineered systems, more agility through implicit fire breaks, stronger devops processes, faster backups etc. I don't think GDPR should have been enforced on existing systems as in many cases it became a tick box exercise. Best practice and certification for new development would have made more sense.
- bzxcvbn 4y agoWhy should established companies get even more of a head start on new players?
- gghhzzgghhzz 4y agoEstablishment companies are always writing new systems or rewriting systems. They will be easy competition if they don't.
- FourthProtocol 4y agoThese are technical controls - are you sure they're the right ones for your organisation - - or even needed? Organisations that comply with the GDPR typically employ a data protection officer - the person responsible for creating or overseeing the creation and ongoing maintenance of a privacy impact assessment. That feeds into requirements long before any code is written, let alone implementing other procedural or technical controls.
- mhoad 4y agoIn theory I agree, in practice GDPR compliance is lots of poorly bolted on band-aid solutions to legacy systems.