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© 2019 Delphix. All Rights Reserved. Private and Confidential.© 2019 Delphix. All Rights Reserved. Private and Confidential.
Karun Bakshi | Delphix
Alex Redlich | Capgemini
Secure Your
Enterprise Data Now
and be Ready for CCPA in 2020
© 2019 Delphix. All Rights Reserved. Private and Confidential.
Introductions
Alex Redlich, Capgemini
Senior Director | Insights & Data
Karun Bakshi, Delphix
VP, Product Marketing
3© Capgemini 2019. All rights reserved |
California Consumer Privacy Act
California residents
Jan 1, 2020; 12 month lookback of certain rights
Annual gross revenues > $25m; Personal information of > 50,000
consumers, households, or devices; Sale of Personal information
accounts for > 50% of annual revenue
Rights: Information, Disclosure, Deletion, Opt-out / Opt-in, Equal
Service, Data portability
Up to $2,500 for each violation or up to $7,500 per each
intentional violation; Private Right of action and Class Action
General Data Protection Regulation
EU Residents
Adopted in April 2016, Effective May 25th, 2018
All EU and foreign companies processing data of EU citizens
Rights: Informed & Access, Rectification, Erasure (right to be
forgotten), Restrict processing, Data portability, Object
Fines of up to 20 million euros or 4% of world wide annual
turnover
Payment Cardholder Industry Data
Security Standards
Global Cardholders
PCI DSS 3.2.1 effective May 2018
All entities that store, process or transmit cardholder data
(Issuers, Acquirers, Merchants etc.)
Ranging from $5,000 to $100,000 per month world wide annual
turnover
Health Insurance Portability and
Accountability Act
All entities under US Health Care Industry
HIPAA law signed on Aug 21st, 1996; HIPAA Privacy Rule effective -
Apr 14th, 2003; HIPAA Security Rule effective - Apr 21st, 2005
Use and disclosure of PHI; Security safeguards (administrative, physical
& technical)
Covered Entities (Health Plans, Health Care Providers, Health Care
Clearinghouses), Business associates contracted by CE
Common themes across regulations and standards
Data
Protection
& Privacy
Data Subject Rights Data Protection Data Access Data Processor AccountabilityConsent Management Privacy NoticesData Minimization Legal Basis
Major regulations and standards that
impact your business…
4© Capgemini 2019. All rights reserved |
It’s all about
individuals’
rights and their
data
Privacy for the individual,
accountability for enterprises,
power for regulators
Adopted in
Jun 2018
Comes into effect
1 Jan 2020
Who
Any organization with:
- Annual gross revenues >
$25m;
- Personal information of >
50,000 consumers,
households, or devices;
- Sale of Personal information
accounts for > 50% of annual
revenue
Why
Individuals regain
control over their
personal data
The CCPA
5© Capgemini 2019. All rights reserved |
To get insight into what data
organizations hold of them
To limit how their data is used
To give and withdraw consent
To have their data deleted
To control how they are profiled
To opt-out of selling personal
information
Processing Record
Controlling and monitoring
Responding to Requests
Opt-out / Opt-in
Data Retention
Technical & organizational
measures
Privacy by design
Privacy Impact Assessment
Data breach notification
Extraterritoriality
On one side data
subjects have been
given Rights… and on the other, there are
business implications
5© Capgemini 2018. All rights reserved |
6© Capgemini 2019. All rights reserved |
What’s in the minds of
best CIOs / CDOs?
RISK,
BREACH,
FINES
Non-compliance may harm our reputation. The fines are huge.
3 Will our framework allow us to respond to data subject requests
5 Enable minimum viability before the regulation is effective
2
Our application and data landscape need a lot of work in order to get
compliant
6
Enable remediation and achieve overall data and application
compliance
7
Build a roadmap for a comprehensive global data privacy and risk
management framework
Are we able to handle data breaches in line with the Regulation4
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Security
privacy
Chief
Data
Officers
Business
line
Leaders
Data Security Remediation
7© Capgemini 2019. All rights reserved |
Delivers holistic compliance..
Enhance
Privacy
notices and
Incident
response
Remediate
apps &
data
Review your
Data
Processor
Accountabi
lity
Optimize
your
operations
Opt-out / Opt-in
Applications & Data
Privacy by Design
Request for Access,
Deletion, Portability
Enhance
Data
Security &
Life Cycle
Management
Data
Privacy &
Compliance
Manage
Data
Subject
Rights
Breach Notification
Awareness & Training
Consent Management
Privacy Notice
Third Party Contracts
Risk Management
Policies & Processes
Encryption /
Pseudonymization
Data Retention
7
© Capgemini 2018. All
How?
Record of Processing
8© Capgemini 2019. All rights reserved |
..through an integrated privacy framework foundation
 Develop, validate and execute the plan of mobilization
and communication to create awareness amongst all
employees
 Create training material , plan and track the progress and
embed the training in the procedure for new employees
Awareness
& Training
Governance
& Data
Classification
Policies
Processes
 BCR and privacy policies will be translated into IT requirements
and processes
 Overview of systems where personal data is stored
 Take measures to ensure compliance and integrate privacy in the
information life cycle (PIA’s)
 Implement Privacy by design
 Plan, validate and implement privacy governance, risk
controls and reports
 Plan, conduct and manage data privacy assessments
and embed them in the organization
 Identification of « Crown Jewels »
 Create and validate clear privacy requirements for e.g.
processes, governance planning, IT and data security
 Align the current privacy policies with the privacy
mission and vision of the organization
 Conduct a privacy impact assessment on relevant
processes
 Create and adapt processes, develop and validate
improvements and take measures
 Create procedure for easy adaption of future
amendments in privacy regulations and policies
 Implement Privacy by design
IT security & Technology
Data Classification
9© Capgemini 2019. All rights reserved |
We help you answer the key Privacy questions
What should my Privacy roadmap cover, and what should I prioritize?
What’s your strategy to manage process and cultural change?
Where is all your employee and consumer
/ citizen data held?
How do consumers give you consent to
use their data?
How will you pseudonymize consumer
data so it’s still usable?
How do you deal with the data lifecycle
from retention to final disposal?
Can you ensure only the right people
have access to the right data?
How exactly will you report a data breach?
What is your on-going compliance monitoring strategy?
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10© Capgemini 2019. All rights reserved |
With a menu of comprehensive services…
Assessment services
Delivers a view on your processing compliance, strategic vision, Privacy awareness, and integrates all internal and external teams.
Program services
Designs the program to get you moving towards Privacy compliance and allows you to adapt and customize Privacy principles
to your specific challenges, context, processes, and culture.
Data Discovery services
Allows you to understand and document where personal data exists
throughout your organization and is the starting point for many
aspects of the Privacy program, such as responding to access
requests.
Consent and Consumers' rights management
services
Analysis where consent is needed and how it
can be (re)obtained.
Implements processes and systems, which allow consumers to
invoke their rights, such as the right to access their data, right to
erasure, right to Opt-out of sharing to third parties.
Pseudonymizing services
Provides role-based access, anonymized data for marketing and
analytics, and allows you to share with external and internal
audiences.
Data lifecycle services
Privacy regulations requires organizations to only use as much data
as is required to successfully complete a given task. It cannot be
reused for another task without further consent. Consumers’ have the
right to request that their data erased after a specific task, and our
lifecycle services ensure that care is taken during the creation,
processing and disposal of data.
Data protection services
Defines and implements controls and solutions to ensure the proper
protection of structured and unstructured data, and so reduce risk.
Controls include access, encryption, key management and database
access monitoring.
Breach management and reporting services
Security-operations-center-as-a-Service for monitoring external threats and vulnerabilities, plus Data-leak-prevention-as-a-Service for monitoring
personal data repositories and flows.
Assurance services
Once you are compliant, our Assurance Services ensure you remain so by monitoring, maintaining, and updating your systems, processes, and policies.
Pick and
choose… we
customize for
your security
needs
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11© Capgemini 2019. All rights reserved |
Strategy & Governance
Develop strategy and establish governance
for coordination and execution of
assessment and implementation of CCPA
Privacy Compliance
Control Gaps Remediation
Define enterprise controls for Privacy
compliance and conduct Control Gap
Assessments. Plan and remediate gaps
(Applications, Processes & Procedures) to
be compliant with all Privacy regulations
Lawfulness of Processing
Design and develop a centralized,
enterprise repository / inventory for
mapping of privacy data. Capture data
flows, reasons for data collection, how data
is processed
Data Subject Rights
Develop capabilities to intake (portal, mail,
phone), manage (tools & services, workflow
process) and respond (pdf, zip file, print) to
Data Subject Rights Requests including
right to access data, right to deletion, right
to opt-out
Data Life Cycle Management
Review and enhance existing policies and
processes for Data Retention, Data
Encryption, Data Pseudonymization to
incorporate CCPA requirements
Consent Management & Privacy Notice
Enhance consent management process for
capturing, storing and propagating consent
choices to various business processes and
applications. Update Privacy notices as required
by the law
Breach Management & Incident Response
Develop / enhance Breach Management and
Reporting policies / processes to adhere to
CCPA requirements
Policy and Process Updates
Embed Privacy requirements into Information
Security and IT Policies & Processes (SDLC,
ALM)
Training and Awareness
Communicate and train employees on the
policy and process changes due CCPA and
other Privacy regulations
Data Processor Accountability
Amend vendor contracts to comply with Third
Party (internal & external) requirements
A 360°
end-to-end compliance
through a core set of
privacy components
11© Capgemini 2018. All rights reserved |
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We partner with you to implement
12© Capgemini 2019. All rights reserved |
Privacy Impact Assessment
Initiation Analysis
Expert
Guidance
Understand current state
Minimum Viable Product
Core Team
Setup
Identify
Workable
Solutions
Execute
Projects
Enterprise Privacy Compliance
Steady State
Privacy Compliance Maturity Assessment using Capgemini’s Privacy
Impact Assessment Tool
Complexity and Compliance needs
Organization needs
 Complete Remediation of all applications and data
 Review ongoing Initiatives and incorporate remediations within these
initiatives
 Evaluate and enhance MVP - Individual Rights Processing, Consent
Management and Privacy Notice
 Enhance policies and processes to incorporate Privacy requirements
 Develop risk dashboards and metrics for measuring privacy and risk
framework
 Complete needed changes to all 3rd party contracts and agreements
 Create a centralized registry to measure the impact and plan for new Data
Privacy Regulations
 Constant monitoring and enhancement of Privacy and Risk processes
 Periodical training and awareness among employees on the new laws and
regulations
 Conduct periodic assessments and audits to policies, processes and assets
 Define and monitor enterprise metrics and take corrective actions
Baseline Compliance Document Compliance Maturity
Strategic Roadmap
Executive
Reporting
 Conduct stakeholder analysis
 Conduct Enterprise policies and processes gap-analysis
 Evaluate Privacy tools and solutions (Data protection, discovery,
lineage)
 Personal and Sensitive data discovery. Identify, Scope & Prioritize the
applications/systems that hold PII
 Build PII lineage to depict PII information flow
 Define operating model, program structure and planning for next
phases. Finalize RACI
 Define Requirements for managing and responding to Individual
Rights requests
 Define Minimum Viable Product for meeting the January 1, 2020
target date - Identify work streams and define milestones
 Create Roadmap, enterprise privacy framework target picture
 Socialize and get approval / agreement from key stakeholders
 Establish the Governance structure for Privacy framework
 Onboard key teams and resources – Data Management, Digital
Channels, Technology, Legal, Audit
 Implement Individual Rights Management tools, processes &
operations
 Develop Privacy Portal,
 Implement Work flow Management / Tool
 Setup Operations team, Call center
 Define risk rating criteria. Conduct application control gap analysis &
define corrective action plans.
 PII gap assessment and remediation including data
pseudonymization / masking, data protection
 Complete training and awareness – front line teams, call centers,
technology, data management etc.
 Evaluate 3rd party impact /updates to contracts/agreements
Program Governance
Launch
MVP
Discover PII Data and Lineage
Application Assessment & Gap
analysis
Individual Rights Management
Third Party Contracts
Remediation
Privacy Processes & Operations
Risk
Complete
Remediation
Global rollout
Execute
Projects
Execute
Projects
Phase IIIPhase IIPhase I
Operational
Execution
Track SLA/
Metrics
Monitor Risk
Continuous
Improvement
1 2 3
4
An end to end approach to achieve CCPA compliance
January 1, 2020
© 2019 Delphix. All Rights Reserved. Private and Confidential.© 2019 Delphix. All Rights Reserved. Private and Confidential.
Delphix for CCPA
© 2017 Delphix. All Rights Reserved. Private and Confidential.
Key CCPA Challenges
Sensitive Data
Protection
Management of
Data Copies
Compliance
Auditing
“How do you deal with the data lifecycle
from retention to disposal?”
“Can you ensure only the
right people have access
to the right data?”
“How will you pseudonymize consumer
data so it’s still usable?”
“What is your ongoing compliance
monitoring strategy”
“Where is all your personal data
held?”
Identification
and
Assessment
“What environments do
you prioritize?”
© 2017 Delphix. All Rights Reserved. Private and Confidential.
Key CCPA Challenges
Sensitive Data
Protection
Identification
and
Assessment
Management of
Data Copies
Data Virtualization Profiling
Compliance
Auditing
Scalable Flexible Deployment Configurations Any Data Source
Masking Auditing
• Sensitive data identification
• Pre-built templates for
industries, apps, regulations
• Provision / de-provision
environments
• Centralized management
• Preconfigured or customized
algorithms
• Referential integrity
• Comprehensive logging
• Report generation
© 2017 Delphix. All Rights Reserved. Private and Confidential.
Key CCPA Challenges
Identification and
Assessment
Management of
Data Copies
Sensitive Data
Protection
Compliance
Auditing
© 2017 Delphix. All Rights Reserved. Private and Confidential.
Non-Production Data Represents a Major Hidden CCPA Risk
NON-PRODUCTION (80%)
PRODUCTION DATA (20%)
» Names, Email, Phone Numbers, Property Records
» Products purchased, biometrics, internet activity,
geolocated data
» Employment info, educational background, consumer
preferences
Non-prod environments contains most
sensitive data subject to CCPA:
82% of enterprises maintain at
least 10 copies for every
production DB
© 2019 Delphix. All Rights Reserved. Private and Confidential.
Delphix Dynamic Data Platform
Control Who Has Access to What Data, When, and Where
Applications
Files
Databases
Secure,
Personal Data
Environments
On-
Prem
Any
Server
Private
Cloud
Public
Cloud
Sync
Compress
Provision
Compliance
Policy
Masking
Distribute
Audit &
Report
Manage
VIRTUALIZE SECURE MANAGE
DBA
18
© 2017 Delphix. All Rights Reserved. Private and Confidential.
Key CCPA Challenges
Identification and
Assessment
Management of
Data Copies
Sensitive Data
Protection
Compliance
Auditing
© 2017 Delphix. All Rights Reserved. Private and Confidential.
Continuously Identify Risk
20
Pinpoint sensitive data
• Scan metadata and values to identify
sensitive data subject to the CCPA
• Determine where and how much risk exists
• Profile data on an ongoing basis, by policy
Positions businesses
to continuously detect, triage, and
respond to sensitive data risk
© 2017 Delphix. All Rights Reserved. Private and Confidential.
Key CCPA Challenges
Identification and
Assessment
Management of
Data Copies
Sensitive Data
Protection
Compliance
Auditing
© 2019 Delphix. All Rights Reserved. Private and Confidential.
Delphix Masking Protects Sensitive Data
“DATA AT
RISK” IS IN
DATABASES
Claimant Table
ID First_Name
1 George
2 Mary
3 John
Employee Table
ID First_Name
5 John
6 George
7 Mary
Claimant Table
ID First_Name
1 Romanth
2 Clara
3 Damien
Employee Table
ID First_Name
5 Damien
6 Romanth
7 Clara
UNMASKED DATA MASKED DATA
✓ REALISTIC ✓ IRREVERSIBLE ✓ REFERENTIAL
INTEGRITY
SENSITIVE DATA IN PRODUCTION
Social Security Numbers, Credit Card Information, Patient
Information, Email Addresses
© 2017 Delphix. All Rights Reserved. Private and Confidential.
Key CCPA Challenges
Identification and
Assessment
Management of
Data Copies
Sensitive Data
Protection
Compliance
Auditing
© 2017 Delphix. All Rights Reserved. Private and Confidential.
Ensure Continuous Compliance
24
Comprehensive Auditing and
Reporting Capabilities
• Maintain inventory of masking policies
• Log and report against policy enforcement
• Automatic report generation
• Integration with 3rd-party monitoring tools,
e.g. Splunk
Positions businesses
to prove that effective CCPA controls
have been implemented
© 2017 Delphix. All Rights Reserved. Private and Confidential.
Key CCPA Challenges
Enterprise Complexity
Identification and
Assessment
Management of
Data Copies
Sensitive Data
Protection
Compliance
Auditing
© 2019 Delphix. All Rights Reserved. Private and Confidential.
BECU (Boeing Employee Credit Union) Reduces Data Risk with Delphix
Fourth largest credit union in the United States, with over $17 billion in assets and over 1 million members
26
“Not only does Delphix allow us to reduce our risk footprint by masking sensitive data, but we can also give developers realistic,
production-like environments, which ensures we’re not introducing defects because of bad data.” KYLE WELSH | Chief Information
Security Officer
THE CHALLENGE THE SOLUTION THE RESULT
Build an agile testing
infrastructure while upholding
the highest data privacy and
security standards
Identify sensitive data values
across all environments
including flat files and automate
masking those values
Delphix automated data
masking and maintains the
referential integrity of masked
data both within and across all
databases and flat files
37% less
time to mask data than initial
requirement
2x faster
product deployment
ROI in less than 6 weeks
© 2019 Delphix. All Rights Reserved. Private and Confidential.
Dentegra Protects Sensitive Data in the Cloud with Delphix
The largest dental benefits system in the United States
27
“Delphix transforms how we use AWS and increases our development velocity. We immediately increased our ability to scale to meet new
business requirements.” SAI ADIVI | Director of Application Development, Dentegra
THE CHALLENGE THE SOLUTION THE RESULT
Provision secure data
environments in AWS to
support over 200
developers
Needed to protect PII
(personally identifiable
information) and PHI (protected
health information) before
moving data to AWS
Hybrid cloud architecture with
Delphix automatically masking
and delivering data from on-
prem to cloud environments
Hours instead of 8 weeks
to migrate data to AWS
HIPAA compliance
with masked non-prod data
On-demand data for dev/test
environments drives
Faster time to market
© 2019 Delphix. All Rights Reserved. Private and Confidential.
63
FINANCIAL SERVICES
54
INSURANCE
33
BANKING
22
CONSUMER SERVICES/RETAIL
19
TELECOM/COMMUNICATIONS
12
IT SERVICES
11
HIGH TECH
11
HOSPITALS/HEALTHCARE
10
GOVERNMENT/STATE
JPMC | Fannie Mae | S&P Global
Proven across multiple industries
28
Sample Set Of Delphix Customers
HSBC | Wells Fargo | BNP ParibasNew York Life | United Health | AETNA
Vodafone | Comcast | SwisscomNike | Macys | Nordstrom
Dell | IBM | HP
Bottomline | ADP | T-Systems
Sutter Health | UPMC | Select Health States of : Indiana | Hawaii | California
© 2019 Delphix. All Rights Reserved. Private and Confidential.© 2019 Delphix. All Rights Reserved. Private and Confidential.
Q&A
© 2019 Delphix. All Rights Reserved. Private and Confidential.© 2019 Delphix. All Rights Reserved. Private and Confidential.
Thank You
karun.bakshi@delphix.com
alex.redlich@capgemini.com

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Secure Your Enterprise Data Now and Be Ready for CCPA in 2020

  • 1. © 2019 Delphix. All Rights Reserved. Private and Confidential.© 2019 Delphix. All Rights Reserved. Private and Confidential. Karun Bakshi | Delphix Alex Redlich | Capgemini Secure Your Enterprise Data Now and be Ready for CCPA in 2020
  • 2. © 2019 Delphix. All Rights Reserved. Private and Confidential. Introductions Alex Redlich, Capgemini Senior Director | Insights & Data Karun Bakshi, Delphix VP, Product Marketing
  • 3. 3© Capgemini 2019. All rights reserved | California Consumer Privacy Act California residents Jan 1, 2020; 12 month lookback of certain rights Annual gross revenues > $25m; Personal information of > 50,000 consumers, households, or devices; Sale of Personal information accounts for > 50% of annual revenue Rights: Information, Disclosure, Deletion, Opt-out / Opt-in, Equal Service, Data portability Up to $2,500 for each violation or up to $7,500 per each intentional violation; Private Right of action and Class Action General Data Protection Regulation EU Residents Adopted in April 2016, Effective May 25th, 2018 All EU and foreign companies processing data of EU citizens Rights: Informed & Access, Rectification, Erasure (right to be forgotten), Restrict processing, Data portability, Object Fines of up to 20 million euros or 4% of world wide annual turnover Payment Cardholder Industry Data Security Standards Global Cardholders PCI DSS 3.2.1 effective May 2018 All entities that store, process or transmit cardholder data (Issuers, Acquirers, Merchants etc.) Ranging from $5,000 to $100,000 per month world wide annual turnover Health Insurance Portability and Accountability Act All entities under US Health Care Industry HIPAA law signed on Aug 21st, 1996; HIPAA Privacy Rule effective - Apr 14th, 2003; HIPAA Security Rule effective - Apr 21st, 2005 Use and disclosure of PHI; Security safeguards (administrative, physical & technical) Covered Entities (Health Plans, Health Care Providers, Health Care Clearinghouses), Business associates contracted by CE Common themes across regulations and standards Data Protection & Privacy Data Subject Rights Data Protection Data Access Data Processor AccountabilityConsent Management Privacy NoticesData Minimization Legal Basis Major regulations and standards that impact your business…
  • 4. 4© Capgemini 2019. All rights reserved | It’s all about individuals’ rights and their data Privacy for the individual, accountability for enterprises, power for regulators Adopted in Jun 2018 Comes into effect 1 Jan 2020 Who Any organization with: - Annual gross revenues > $25m; - Personal information of > 50,000 consumers, households, or devices; - Sale of Personal information accounts for > 50% of annual revenue Why Individuals regain control over their personal data The CCPA
  • 5. 5© Capgemini 2019. All rights reserved | To get insight into what data organizations hold of them To limit how their data is used To give and withdraw consent To have their data deleted To control how they are profiled To opt-out of selling personal information Processing Record Controlling and monitoring Responding to Requests Opt-out / Opt-in Data Retention Technical & organizational measures Privacy by design Privacy Impact Assessment Data breach notification Extraterritoriality On one side data subjects have been given Rights… and on the other, there are business implications 5© Capgemini 2018. All rights reserved |
  • 6. 6© Capgemini 2019. All rights reserved | What’s in the minds of best CIOs / CDOs? RISK, BREACH, FINES Non-compliance may harm our reputation. The fines are huge. 3 Will our framework allow us to respond to data subject requests 5 Enable minimum viability before the regulation is effective 2 Our application and data landscape need a lot of work in order to get compliant 6 Enable remediation and achieve overall data and application compliance 7 Build a roadmap for a comprehensive global data privacy and risk management framework Are we able to handle data breaches in line with the Regulation4 1 Security privacy Chief Data Officers Business line Leaders Data Security Remediation
  • 7. 7© Capgemini 2019. All rights reserved | Delivers holistic compliance.. Enhance Privacy notices and Incident response Remediate apps & data Review your Data Processor Accountabi lity Optimize your operations Opt-out / Opt-in Applications & Data Privacy by Design Request for Access, Deletion, Portability Enhance Data Security & Life Cycle Management Data Privacy & Compliance Manage Data Subject Rights Breach Notification Awareness & Training Consent Management Privacy Notice Third Party Contracts Risk Management Policies & Processes Encryption / Pseudonymization Data Retention 7 © Capgemini 2018. All How? Record of Processing
  • 8. 8© Capgemini 2019. All rights reserved | ..through an integrated privacy framework foundation  Develop, validate and execute the plan of mobilization and communication to create awareness amongst all employees  Create training material , plan and track the progress and embed the training in the procedure for new employees Awareness & Training Governance & Data Classification Policies Processes  BCR and privacy policies will be translated into IT requirements and processes  Overview of systems where personal data is stored  Take measures to ensure compliance and integrate privacy in the information life cycle (PIA’s)  Implement Privacy by design  Plan, validate and implement privacy governance, risk controls and reports  Plan, conduct and manage data privacy assessments and embed them in the organization  Identification of « Crown Jewels »  Create and validate clear privacy requirements for e.g. processes, governance planning, IT and data security  Align the current privacy policies with the privacy mission and vision of the organization  Conduct a privacy impact assessment on relevant processes  Create and adapt processes, develop and validate improvements and take measures  Create procedure for easy adaption of future amendments in privacy regulations and policies  Implement Privacy by design IT security & Technology Data Classification
  • 9. 9© Capgemini 2019. All rights reserved | We help you answer the key Privacy questions What should my Privacy roadmap cover, and what should I prioritize? What’s your strategy to manage process and cultural change? Where is all your employee and consumer / citizen data held? How do consumers give you consent to use their data? How will you pseudonymize consumer data so it’s still usable? How do you deal with the data lifecycle from retention to final disposal? Can you ensure only the right people have access to the right data? How exactly will you report a data breach? What is your on-going compliance monitoring strategy? 1 2 3 4 5 6 7 8 9
  • 10. 10© Capgemini 2019. All rights reserved | With a menu of comprehensive services… Assessment services Delivers a view on your processing compliance, strategic vision, Privacy awareness, and integrates all internal and external teams. Program services Designs the program to get you moving towards Privacy compliance and allows you to adapt and customize Privacy principles to your specific challenges, context, processes, and culture. Data Discovery services Allows you to understand and document where personal data exists throughout your organization and is the starting point for many aspects of the Privacy program, such as responding to access requests. Consent and Consumers' rights management services Analysis where consent is needed and how it can be (re)obtained. Implements processes and systems, which allow consumers to invoke their rights, such as the right to access their data, right to erasure, right to Opt-out of sharing to third parties. Pseudonymizing services Provides role-based access, anonymized data for marketing and analytics, and allows you to share with external and internal audiences. Data lifecycle services Privacy regulations requires organizations to only use as much data as is required to successfully complete a given task. It cannot be reused for another task without further consent. Consumers’ have the right to request that their data erased after a specific task, and our lifecycle services ensure that care is taken during the creation, processing and disposal of data. Data protection services Defines and implements controls and solutions to ensure the proper protection of structured and unstructured data, and so reduce risk. Controls include access, encryption, key management and database access monitoring. Breach management and reporting services Security-operations-center-as-a-Service for monitoring external threats and vulnerabilities, plus Data-leak-prevention-as-a-Service for monitoring personal data repositories and flows. Assurance services Once you are compliant, our Assurance Services ensure you remain so by monitoring, maintaining, and updating your systems, processes, and policies. Pick and choose… we customize for your security needs 1 2 3 4 5 6 7 8 9
  • 11. 11© Capgemini 2019. All rights reserved | Strategy & Governance Develop strategy and establish governance for coordination and execution of assessment and implementation of CCPA Privacy Compliance Control Gaps Remediation Define enterprise controls for Privacy compliance and conduct Control Gap Assessments. Plan and remediate gaps (Applications, Processes & Procedures) to be compliant with all Privacy regulations Lawfulness of Processing Design and develop a centralized, enterprise repository / inventory for mapping of privacy data. Capture data flows, reasons for data collection, how data is processed Data Subject Rights Develop capabilities to intake (portal, mail, phone), manage (tools & services, workflow process) and respond (pdf, zip file, print) to Data Subject Rights Requests including right to access data, right to deletion, right to opt-out Data Life Cycle Management Review and enhance existing policies and processes for Data Retention, Data Encryption, Data Pseudonymization to incorporate CCPA requirements Consent Management & Privacy Notice Enhance consent management process for capturing, storing and propagating consent choices to various business processes and applications. Update Privacy notices as required by the law Breach Management & Incident Response Develop / enhance Breach Management and Reporting policies / processes to adhere to CCPA requirements Policy and Process Updates Embed Privacy requirements into Information Security and IT Policies & Processes (SDLC, ALM) Training and Awareness Communicate and train employees on the policy and process changes due CCPA and other Privacy regulations Data Processor Accountability Amend vendor contracts to comply with Third Party (internal & external) requirements A 360° end-to-end compliance through a core set of privacy components 11© Capgemini 2018. All rights reserved | 1 2 3 4 5 6 7 8 9 10 We partner with you to implement
  • 12. 12© Capgemini 2019. All rights reserved | Privacy Impact Assessment Initiation Analysis Expert Guidance Understand current state Minimum Viable Product Core Team Setup Identify Workable Solutions Execute Projects Enterprise Privacy Compliance Steady State Privacy Compliance Maturity Assessment using Capgemini’s Privacy Impact Assessment Tool Complexity and Compliance needs Organization needs  Complete Remediation of all applications and data  Review ongoing Initiatives and incorporate remediations within these initiatives  Evaluate and enhance MVP - Individual Rights Processing, Consent Management and Privacy Notice  Enhance policies and processes to incorporate Privacy requirements  Develop risk dashboards and metrics for measuring privacy and risk framework  Complete needed changes to all 3rd party contracts and agreements  Create a centralized registry to measure the impact and plan for new Data Privacy Regulations  Constant monitoring and enhancement of Privacy and Risk processes  Periodical training and awareness among employees on the new laws and regulations  Conduct periodic assessments and audits to policies, processes and assets  Define and monitor enterprise metrics and take corrective actions Baseline Compliance Document Compliance Maturity Strategic Roadmap Executive Reporting  Conduct stakeholder analysis  Conduct Enterprise policies and processes gap-analysis  Evaluate Privacy tools and solutions (Data protection, discovery, lineage)  Personal and Sensitive data discovery. Identify, Scope & Prioritize the applications/systems that hold PII  Build PII lineage to depict PII information flow  Define operating model, program structure and planning for next phases. Finalize RACI  Define Requirements for managing and responding to Individual Rights requests  Define Minimum Viable Product for meeting the January 1, 2020 target date - Identify work streams and define milestones  Create Roadmap, enterprise privacy framework target picture  Socialize and get approval / agreement from key stakeholders  Establish the Governance structure for Privacy framework  Onboard key teams and resources – Data Management, Digital Channels, Technology, Legal, Audit  Implement Individual Rights Management tools, processes & operations  Develop Privacy Portal,  Implement Work flow Management / Tool  Setup Operations team, Call center  Define risk rating criteria. Conduct application control gap analysis & define corrective action plans.  PII gap assessment and remediation including data pseudonymization / masking, data protection  Complete training and awareness – front line teams, call centers, technology, data management etc.  Evaluate 3rd party impact /updates to contracts/agreements Program Governance Launch MVP Discover PII Data and Lineage Application Assessment & Gap analysis Individual Rights Management Third Party Contracts Remediation Privacy Processes & Operations Risk Complete Remediation Global rollout Execute Projects Execute Projects Phase IIIPhase IIPhase I Operational Execution Track SLA/ Metrics Monitor Risk Continuous Improvement 1 2 3 4 An end to end approach to achieve CCPA compliance January 1, 2020
  • 13. © 2019 Delphix. All Rights Reserved. Private and Confidential.© 2019 Delphix. All Rights Reserved. Private and Confidential. Delphix for CCPA
  • 14. © 2017 Delphix. All Rights Reserved. Private and Confidential. Key CCPA Challenges Sensitive Data Protection Management of Data Copies Compliance Auditing “How do you deal with the data lifecycle from retention to disposal?” “Can you ensure only the right people have access to the right data?” “How will you pseudonymize consumer data so it’s still usable?” “What is your ongoing compliance monitoring strategy” “Where is all your personal data held?” Identification and Assessment “What environments do you prioritize?”
  • 15. © 2017 Delphix. All Rights Reserved. Private and Confidential. Key CCPA Challenges Sensitive Data Protection Identification and Assessment Management of Data Copies Data Virtualization Profiling Compliance Auditing Scalable Flexible Deployment Configurations Any Data Source Masking Auditing • Sensitive data identification • Pre-built templates for industries, apps, regulations • Provision / de-provision environments • Centralized management • Preconfigured or customized algorithms • Referential integrity • Comprehensive logging • Report generation
  • 16. © 2017 Delphix. All Rights Reserved. Private and Confidential. Key CCPA Challenges Identification and Assessment Management of Data Copies Sensitive Data Protection Compliance Auditing
  • 17. © 2017 Delphix. All Rights Reserved. Private and Confidential. Non-Production Data Represents a Major Hidden CCPA Risk NON-PRODUCTION (80%) PRODUCTION DATA (20%) » Names, Email, Phone Numbers, Property Records » Products purchased, biometrics, internet activity, geolocated data » Employment info, educational background, consumer preferences Non-prod environments contains most sensitive data subject to CCPA: 82% of enterprises maintain at least 10 copies for every production DB
  • 18. © 2019 Delphix. All Rights Reserved. Private and Confidential. Delphix Dynamic Data Platform Control Who Has Access to What Data, When, and Where Applications Files Databases Secure, Personal Data Environments On- Prem Any Server Private Cloud Public Cloud Sync Compress Provision Compliance Policy Masking Distribute Audit & Report Manage VIRTUALIZE SECURE MANAGE DBA 18
  • 19. © 2017 Delphix. All Rights Reserved. Private and Confidential. Key CCPA Challenges Identification and Assessment Management of Data Copies Sensitive Data Protection Compliance Auditing
  • 20. © 2017 Delphix. All Rights Reserved. Private and Confidential. Continuously Identify Risk 20 Pinpoint sensitive data • Scan metadata and values to identify sensitive data subject to the CCPA • Determine where and how much risk exists • Profile data on an ongoing basis, by policy Positions businesses to continuously detect, triage, and respond to sensitive data risk
  • 21. © 2017 Delphix. All Rights Reserved. Private and Confidential. Key CCPA Challenges Identification and Assessment Management of Data Copies Sensitive Data Protection Compliance Auditing
  • 22. © 2019 Delphix. All Rights Reserved. Private and Confidential. Delphix Masking Protects Sensitive Data “DATA AT RISK” IS IN DATABASES Claimant Table ID First_Name 1 George 2 Mary 3 John Employee Table ID First_Name 5 John 6 George 7 Mary Claimant Table ID First_Name 1 Romanth 2 Clara 3 Damien Employee Table ID First_Name 5 Damien 6 Romanth 7 Clara UNMASKED DATA MASKED DATA ✓ REALISTIC ✓ IRREVERSIBLE ✓ REFERENTIAL INTEGRITY SENSITIVE DATA IN PRODUCTION Social Security Numbers, Credit Card Information, Patient Information, Email Addresses
  • 23. © 2017 Delphix. All Rights Reserved. Private and Confidential. Key CCPA Challenges Identification and Assessment Management of Data Copies Sensitive Data Protection Compliance Auditing
  • 24. © 2017 Delphix. All Rights Reserved. Private and Confidential. Ensure Continuous Compliance 24 Comprehensive Auditing and Reporting Capabilities • Maintain inventory of masking policies • Log and report against policy enforcement • Automatic report generation • Integration with 3rd-party monitoring tools, e.g. Splunk Positions businesses to prove that effective CCPA controls have been implemented
  • 25. © 2017 Delphix. All Rights Reserved. Private and Confidential. Key CCPA Challenges Enterprise Complexity Identification and Assessment Management of Data Copies Sensitive Data Protection Compliance Auditing
  • 26. © 2019 Delphix. All Rights Reserved. Private and Confidential. BECU (Boeing Employee Credit Union) Reduces Data Risk with Delphix Fourth largest credit union in the United States, with over $17 billion in assets and over 1 million members 26 “Not only does Delphix allow us to reduce our risk footprint by masking sensitive data, but we can also give developers realistic, production-like environments, which ensures we’re not introducing defects because of bad data.” KYLE WELSH | Chief Information Security Officer THE CHALLENGE THE SOLUTION THE RESULT Build an agile testing infrastructure while upholding the highest data privacy and security standards Identify sensitive data values across all environments including flat files and automate masking those values Delphix automated data masking and maintains the referential integrity of masked data both within and across all databases and flat files 37% less time to mask data than initial requirement 2x faster product deployment ROI in less than 6 weeks
  • 27. © 2019 Delphix. All Rights Reserved. Private and Confidential. Dentegra Protects Sensitive Data in the Cloud with Delphix The largest dental benefits system in the United States 27 “Delphix transforms how we use AWS and increases our development velocity. We immediately increased our ability to scale to meet new business requirements.” SAI ADIVI | Director of Application Development, Dentegra THE CHALLENGE THE SOLUTION THE RESULT Provision secure data environments in AWS to support over 200 developers Needed to protect PII (personally identifiable information) and PHI (protected health information) before moving data to AWS Hybrid cloud architecture with Delphix automatically masking and delivering data from on- prem to cloud environments Hours instead of 8 weeks to migrate data to AWS HIPAA compliance with masked non-prod data On-demand data for dev/test environments drives Faster time to market
  • 28. © 2019 Delphix. All Rights Reserved. Private and Confidential. 63 FINANCIAL SERVICES 54 INSURANCE 33 BANKING 22 CONSUMER SERVICES/RETAIL 19 TELECOM/COMMUNICATIONS 12 IT SERVICES 11 HIGH TECH 11 HOSPITALS/HEALTHCARE 10 GOVERNMENT/STATE JPMC | Fannie Mae | S&P Global Proven across multiple industries 28 Sample Set Of Delphix Customers HSBC | Wells Fargo | BNP ParibasNew York Life | United Health | AETNA Vodafone | Comcast | SwisscomNike | Macys | Nordstrom Dell | IBM | HP Bottomline | ADP | T-Systems Sutter Health | UPMC | Select Health States of : Indiana | Hawaii | California
  • 29. © 2019 Delphix. All Rights Reserved. Private and Confidential.© 2019 Delphix. All Rights Reserved. Private and Confidential. Q&A
  • 30. © 2019 Delphix. All Rights Reserved. Private and Confidential.© 2019 Delphix. All Rights Reserved. Private and Confidential. Thank You karun.bakshi@delphix.com alex.redlich@capgemini.com

Editor's Notes

  1. Background if required: There are several new requirements, five core rights for individuals and a requirement to cure any breach within 30 days of notice. This will require a re-engineering of your systems and processes, plus your culture. The regulator can issue instructions to cease data processing, while non-compliance can lead to loss of brand reputation and trust. Individuals have a number of rights regarding their personal data, such as: The right to access it The right to have it deleted The right to disclose why the data is collected and whom it is sold to The right to opt-out of selling personal information. If between 13-16, explicit opt-in. The right to equal service (no discrimination) Consent should be freely given, specific, unambiguous and per purpose. The most fundamental principle of GDPR & CCPA is the obligation to process personal data “lawfully, adequately, accurately and securely “. Controllers of personal data must implement the principles of “Data Protection by design and by default”, which addresses topics like data minimization, pseudonymizing, transparency and security.
  2. We have 10 blocks of services. While clients can choose end to end services, they also can choose separate services. We deliver per your needs. For example, you can only choose Data Discovery, Data Lifecycles and Data Protection services.
  3. This is the original 10 components / workstreams slide. We recommend that the privacy program consist of these 10 components or work streams. Led by the Strategy & Governance workstream. Each workstream addresses specific requirements of a privacy program.
  4. Data breach: there have been breaches across the private and public sector that have cost millions in damages. That’s just considering the data breaches that have made the news and cost millions to resolve—but there are many more breaches that can go undiscovered for months or even years. Customer churn, fines, reputational risk—those are all the real dangers of data breach. Regulations: HIPAA and PCI-DSS in the U.S., as well as GDPR in EMEA—mandate protection and deidentification of certain kinds of data.
  5. Let’s go into a bit more detail around how Delphix works. Our Dynamic Data Platform installs on prem or in the cloud and ingests data from various sources– oftentimes this is an RDBMS such as Oracle, SQL Server, DB2, ASE, but we can also work with data from file systems. Delphix virtualizes that data, allowing users to create lightweight virtual copies that are space-efficient and highly portable. These are complete copies of the source data that fully readable and writable. We automatically identify sensitive data values and apply data masking within those virtual copies to protect sensitive information. Finally, we package those virtual copies into personal data pods that are delivered to end users in just minutes. Data pods contain secure, virtual copies of data along with data controls that allows users to manipulate that data: users can instantly refresh, rewind, branch, or share those copies as a self service. Delphix is totally unique in that we integrate data masking with data delivery. For GDPR compliance, this means that you can ensure that all of the data you’ve sent to non-prod environments has been scrubbed of sensitive information. You no longer have to worry about compliance for a large proportion of your environments.
  6. Continuously Identify Risk Delphix Notes: Many organizations find themselves in a state where they have limited visibility into their exposure to data risk. If they do have visibility, it may be limited to a certain set of data sources or it might reflect only a specific time period. This slide zeroes in on our ability to assess data risk at an enterprise level, and on an ongoing basis. We provide an easy and automated approach for pinpointing sensitive data that easily scales, is highly automated, and that can be repeated by policy. Narrative: For many organizations, the first step in securing their data and enabling compliance is determining where their sensitive data resides. Delphix provides a built-in capability to automatically pinpoint sensitive information that might be subject to privacy laws or your own internal security standards. The same capability works across different sources, and allows teams to leverage both pre-configured profiling sets tuned for specific apps, regulations, or verticals, as well as flexible templates that allow you to discover sensitive data types specific to your business. This capability can be deployed across large data estates and be triggered by policy via API, giving you continuous, enterprise-wide visibility into data risk.
  7. We often get questions about the masking process and how it affects the usability of the data and how we know that the data is really secure. What a masking solution does is that it transforms sensitive data values – names, email addresses, social security numbers, credit card numbers – into fictitious yet realistic values The key here is that we scramble the data in a way that’s irreversible, secure, and yet intelligent. The data is still usable after its masked. So if you’re a developer, you often don’t need the actual information resident in the data, but you do need that data to look, feel, and operate like the real thing. That’s what a masking solution does and we offer a variety of different masking algorithms that all achieve this goal. In this example here, Mary is masked to another name Clara and John is masked to Damian. We do this very quickly and in a way that preserves the referential integrity of the data. Again, in his example, Mary is masked to Clara consistently, across the Oracle tables and the SQL Server tables. Referential integrity is a really common requirement that we encounter at Delphix.
  8. Continuously Identify Risk Delphix Notes: Many organizations find themselves in a state where they have limited visibility into their exposure to data risk. If they do have visibility, it may be limited to a certain set of data sources or it might reflect only a specific time period. This slide zeroes in on our ability to assess data risk at an enterprise level, and on an ongoing basis. We provide an easy and automated approach for pinpointing sensitive data that easily scales, is highly automated, and that can be repeated by policy. Narrative: For many organizations, the first step in securing their data and enabling compliance is determining where their sensitive data resides. Delphix provides a built-in capability to automatically pinpoint sensitive information that might be subject to privacy laws or your own internal security standards. The same capability works across different sources, and allows teams to leverage both pre-configured profiling sets tuned for specific apps, regulations, or verticals, as well as flexible templates that allow you to discover sensitive data types specific to your business. This capability can be deployed across large data estates and be triggered by policy via API, giving you continuous, enterprise-wide visibility into data risk.
  9. CHALLENGE BECU needed to quickly roll out enhancements to its online banking systems, without interrupting services or compromising security. A key challenge faced by BECU was building an agile testing infrastructure while upholding the highest data privacy and security standards. BECU needed a secure DataOps solution that met these specific requirements: Sensitive data discovery: BECU needed a solution that would identify sensitive data values across all of its environments and automate the process of consistently masking those values. Masking consistency and repeatability: Applications needed to be masked the same way every time and function the same using masked and unmasked data. The solution also needed to maintain referential integrity across masked flat files and databases. Out-of-the-box masking templates: The BECU team needed a simple solution with preset rules that the company could start using immediately. Breadth of supported databases and flat files: BECU needed a solution that could mask Oracle, SQL Server, and more than 100 flat files across the nine key applications, including CRM, loan originations, and member portal systems. Reporting and auditing of masked data: The credit union needed a way to track masked data across sources over time to verify that masked environments were not being polluted with unmasked confidential data. SOLUTION After evaluating three separate vendors, BECU selected the Delphix Dynamic Data Platform for masking data in its new testing infrastructure because: Delphix consistently masks data across relational database platforms and flat files, even as data changes over time. Delphix also maintains the referential integrity of masked data both within and across databases and files. Delphix addresses the first crucial step in securing sensitive data at risk: discovering where the risk lies by providing built-in data profiling. Delphix provides pre-built masking functionality that requires no programming knowledge or administrative involvement to create custom masking rules. Delphix is platform-agnostic, offering a wide range of support for heterogeneous databases—such as Oracle, SQL server, DB2, and file systems. RESULTS Delphix enabled BECU to exceed its goal for data masking, helping the firm bolster rigorous standards for protecting confidential information: BECU masked 662 tables, 3,507 columns, and 680 million rows of data in 15 hours, far exceeding the initial requirement that masking not take more than 24 hours. They completed the implementation process in 6 weeks, meeting compliance requirements ahead of schedule. The team estimated that competitors’ tools would have taken an estimated 18-24 weeks to install and start masking data with. Delphix experts worked side-by-side with BECU team members to establish the foundation of a masking Center of Excellence, enabling BECU to continue with minimal support. BECU also leverages the virtualization capabilities of the Delphix Dynamic Data Platform to reduce the overall time and effort to distribute masked data, which makes it possible for BECU to deploy products up to twice as fast.
  10. CHALLENGE Dentegra depends heavily on software applications to support the orchestration of core business processes such as contracts management, customer onboarding, and claims processing. Moving to the cloud is part of Dentegra’s long-term digital strategy to improve scalability and time to market across its application portfolio. However, data-related challenges stood in the way of realizing the full potential of cloud: While Dentegra leveraged Amazon Web Services (AWS) to quickly provision compute and storage resources for dev/test environments, those environments were not complete without application data. Initial migration efforts involved data extraction followed by the physical shipment of an appliance, a process that took 8 weeks to complete. Dentegra needed to secure PII (personally identifiable information) and PHI (protected health information) before moving data to AWS. Amazon Web Services allows teams to quickly spin up and tear down infrastructure at unprecedented speeds. But without a sound methodology to also deliver secure, high-quality data to that infrastructure – and at a similar, accelerated pace – Dentegra would be unable to maximize the cloud-related benefit of rapid time to market. SOLUTION Delphix empowers teams to stand up complete dev/test environments in a matter of minutes. Delphix non-disruptively collects data from Dentegra’s production applications and applies masking to that data to protect any confidential information. Delphix then replicates masked data to a second instance of the Dynamic Data Platform that resides in AWS. From that cloud-based instance, teams can instantly provision virtual, space-efficient data copies to dev/test environments running on AWS EC2 instances. Legacy approaches to refreshing data in AWS require teams to repeat the full, manual process of extracting, moving, and importing data to the cloud. But with a hybrid cloud architecture leveraging Delphix, Dentegra can keep on-prem and cloud environments in sync: Delphix continually gathers data from production sources. The data is then masked and replicated to AWS. With fresh, secure data available in the cloud, Dentegra can easily deliver new virtual data copies to a team of over 200 developers, in just minutes. RESULTS By leveraging Delphix and AWS solutions together, Dentegra is in process of transforming environment setup processes that can result in lead times that slow down Application Development. Instead of having to wait for multiple, serial processes to procure and configure hardware and software followed by a paralyzingly slow migration of production data, Dentegra can create cloud environments—infrastructure plus data—in a single motion. With Delphix, Dentegra teams have been able to: Reduce the time it takes to move data to cloud environments from 8 weeks to hours. Mask sensitive PII and PHI before replicating data to AWS. Decrease storage requirements in AWS by leveraging virtual instead of physical data copies. In addition, for its 16TB on-premise claims processing database, Dentegra has realized significant reduction in the storage it needs for non-production environments. In concert with AWS, Delphix brings dramatically greater scalability and speed to development: Dentegra can determine requirements for a new application project on one day, then marshal the necessary data and compute resources to execute against those requirements within 24 hours.