Privacy, Trust, and the GDPR @ Microsoft
Approach and Lessons learned
JP Clementi, Senior Program Manager
Microsoft Azure Engineering | Security, Privacy & GDPR
Microsoft as a trusted platform
GDPR: Our engineering approach and lessons learned
Microsoft Cloud: How Azure and Office 365
support GDPR and other compliance
requirements
Agenda
“Businesses and users are going to
embrace technology only if they can
trust it.”
Satya Nadella
Chief Executive Officer
Microsoft Corporation
• We take a principled approach with strong commitments
to privacy, security, compliance and transparency.
• Moving to the cloud makes it easier for you to become
compliant with privacy regulations by managing and
protecting personal data in a centralized location.
• Microsoft is the industry leader in privacy and security
with extensive expertise complying with complex
regulations.
Enhanced personal privacy rights
Increased duty for protecting data
Mandatory breach reporting
Significant penalties for noncompliance
General Data Protection Regulation
(GDPR) - imposes new rules on
organizations in the European Union (EU)
and those that offer goods and services to
people in the EU, or that collect and analyze
data tied to EU residents, no matter where
those organizations are located
Overview
Privacy - Microsoft understands that when
you, our customer, use our business cloud
services, you are entrusting us with your
most valuable asset—your data. You trust
that its privacy will be protected and that it
will be used only in a way that is consistent
with your expectations.
Right to
restriction of
processing
Security of
processing
Notification of a
personal data
breach to the
supervisory
authority
Transfers
subject to
appropriate
safeguards
Penalties
Data protection
impact
assessment
Right of access
by the data
subject
Records of
processing
activities
Right to erasure
(right to be
forgotten)
Data protection
by design and
by default
Right of
rectification
Right to data
portability
Art.
20
Art.
15
Art.
16
Art.
17
Art.
18
Art.
33
Art.
25
Art.
30
Art.
32
Art.
35
Art.
46
Art.
84
General Data
Protection
Regulation
People Process Technology
Individuals have the right to:
• Access their personal data
• Correct errors in their
personal data
• Erase their personal data
• Object to processing of their
personal data
• Export personal data
Organizations are required to:
• Protect personal data by
implementing appropriate
security
• Notify authorities of
personal data breaches
• Obtain appropriate consent
for processing data
• Keep records detailing data
processing
Organizations are required to:
• Provide clear notice of
data collection
• Outline processing
purposes and use cases
• Define data retention and
deletion policies
Organizations are required to:
• Train privacy personnel and
employees
• Audit and update data policies
• Employ a Data Protection
Officer (if required)
• Create and manage compliant
vendor contracts
What key changes result from the GDPR?
Data Subject
Rights
Controls and
notifications
Transparent
policies
IT and
training
GDPR is……
Protecting customer
privacy with GDPR
What does this mean for my data?
GDPR Overview
Consent
Management
Data Subject Request
Management
Breach
Notification
Data Inventory, Data Policies, and Data Map
Data privacy risk management reporting & portal
Data Protection Management
Risk & Compliance Management for Data Privacy Engagement
Your data sources
Your personal
data definitions
Your policies
Your business
reasons for data
capture
Responding to
data subject
requests and
consent changes
Breach response
Ongoing
compliance
programs
Reporting to
authorities
Microsoft Cloud: Trusted Platform
Transparency
& Privacy
Operational
Security
Breach
Notification
Built-in compliance and security to manage and control access to personal data
Data
Residency
Classified as Microsoft Confidential
PRIVACY
User Privacy
User Privacy enables Active Directory tenant administrators to export user specific
data and delete accounts. Learn More
Request to export user
data
Submit and manage user requests
to export stored data. Learn More
View export requests
Track and view requests to export
user specific data. Learn More
Delete user in Active Directory
Delete users from the Azure environment by
deleting the user in Active Directory. Learn More
Manage User Privacy
Classified as Microsoft Confidential
PRIVACY
Classified as Microsoft Confidential
NAME USERNAME TYPE SOURCE
15 items (15 users)
Search by name or email
Name
Deleted users
Show
Aaish Anand aanand@contoso.com Member Windows Server AD
Aaron Robins aaron.robins@contoso.com Member Windows Server AD
Abner Lominy abner.lominy@contoso.com Member Azure Active Directory
Abramo Russo abramo.russo@contoso.com Member Windows Server AD
Adrian Sommaerville asommaerville@contoso.com Member Windows Server AD
AR
Restore user Forget user
User forgotten
Successfully removed Aaditya Dakenz from
the directory.
Transparency - Compliance Manager
Compliance
Manager
View your compliance posture against
evolving regulations in real-time.
Take recommended actions to improve
your data protection capabilities.
Conduct pre-audits to prepare for
external audits.
Azure covers 79 compliance offerings
 ISO 27001:2013
 ISO 27017:2015
 ISO 27018:2014
 ISO 22301:2012
 ISO 9001:2015
 ISO 20000-1:2011
 SOC 1 Type 2
 SOC 2 Type 2
 CIS Benchmark
 CSA STAR Certification
 CSA STAR Certification
 CSA STAR Attestation
 CSA STAR Self-Assessment
 WCAG 2.0 (ISO 40500:2012)
 FedRAMP High
 FedRAMP Moderate
 EAR
 DoD DISA SRG Level 5
 DoD DISA SRG Level 4
 DoD DISA SRG Level 2
 DFARS
 DoE 10 CFR Part 810
 NIST SP 800-171
 NIST CSF
 Section 508 VPATs
 FIPS 140-2
 ITAR
 CJIS
 IRS 1075
 PCI DSS Level 1
 GLBA
 FFIEC
 Shared Assessments
 FISC (JP)
 APRA (AU)
 OSFI (CA)
 FCA + PRA (UK)
 MAS + ABS (SG)
 23 NYCRR 500
 SEC 17a-4
 CFTC 1.31
 2FINRA 4511
 SOX
 HIPAA BAA
 HITRUST
 21 CFR Part 11 (GxP)
 MARS-E
 NHS IG Toolkit (UK)
 NEN 7510:2011 (NL)
 FERPA
 CDSA
 MPAA
 DPP (UK)
 FACT (UK)
 Argentina PDPA
 Australia IRAP Unclassified
 Australia IRAP Protected
 Canada Privacy Laws
 China GB 18030:2005
 China DJCP (MLPS) Level 3
 China TRUCS / CCCPPF
 India MeitY
 Japan CS Mark Gold
 Japan My Number Act
 Netherlands BIR 2012
 New Zealand Gov CIO Fwk
 Singapore MTCS Level 3
 Spain ENS
 Spain DPA
 UK Cyber Essentials Plus
 UK G-Cloud
 UK PASF
 EN 301 549
 EU ENISA IAF
 EU Model Clauses
 EU – US Privacy Shield
 GDPR
 Germany C5
 Germany IT-Grundschutz
Industry
U.S.
Government
Global
Regional
LESSONS LEARNED
• Intensive Engineering Work
Begin early, there’s plenty of engineering work ahead.
• Continue Sharing and Learning
We will share our experience in complying with complex regulations such as the GDPR.
• Partners are key in the compliance journey
Together with our partners, we are prepared to help you meet your policy, people, process,
and technology goals on your journey to GDPR.
• Microsoft Cloud is GDPR Ready
To simplify your path to compliance, we are GDPR compliance ready
across our cloud services beginning on May 25, 2018.
• Microsoft Cloud is Built on Trust
Satya: “Businesses and users are going to embrace technology only if
they can trust it.” - Microsoft cloud is built on trust.
• Microsoft Cloud I here to enable you to succeed
Microsoft provides tools to help you in your compliance journey
KEY TAKEAWAYS
Resources
Azure sales guide, playbook, and
customizable presentation for GDPR
https://aka.ms/GDPR-Partners
GDPR on the Microsoft Trust Center
https://microsoft.com/gdpr
Compliance Manager
https://aka.ms/compliancemanager
Azure Blueprints
https://aka.ms/Azure-Blueprints
Azure Privacy & GDPR @ Service Management World

Azure Privacy & GDPR @ Service Management World

  • 1.
    Privacy, Trust, andthe GDPR @ Microsoft Approach and Lessons learned JP Clementi, Senior Program Manager Microsoft Azure Engineering | Security, Privacy & GDPR
  • 2.
    Microsoft as atrusted platform GDPR: Our engineering approach and lessons learned Microsoft Cloud: How Azure and Office 365 support GDPR and other compliance requirements Agenda
  • 3.
    “Businesses and usersare going to embrace technology only if they can trust it.” Satya Nadella Chief Executive Officer Microsoft Corporation • We take a principled approach with strong commitments to privacy, security, compliance and transparency. • Moving to the cloud makes it easier for you to become compliant with privacy regulations by managing and protecting personal data in a centralized location. • Microsoft is the industry leader in privacy and security with extensive expertise complying with complex regulations.
  • 4.
    Enhanced personal privacyrights Increased duty for protecting data Mandatory breach reporting Significant penalties for noncompliance General Data Protection Regulation (GDPR) - imposes new rules on organizations in the European Union (EU) and those that offer goods and services to people in the EU, or that collect and analyze data tied to EU residents, no matter where those organizations are located Overview Privacy - Microsoft understands that when you, our customer, use our business cloud services, you are entrusting us with your most valuable asset—your data. You trust that its privacy will be protected and that it will be used only in a way that is consistent with your expectations.
  • 5.
    Right to restriction of processing Securityof processing Notification of a personal data breach to the supervisory authority Transfers subject to appropriate safeguards Penalties Data protection impact assessment Right of access by the data subject Records of processing activities Right to erasure (right to be forgotten) Data protection by design and by default Right of rectification Right to data portability Art. 20 Art. 15 Art. 16 Art. 17 Art. 18 Art. 33 Art. 25 Art. 30 Art. 32 Art. 35 Art. 46 Art. 84 General Data Protection Regulation People Process Technology
  • 6.
    Individuals have theright to: • Access their personal data • Correct errors in their personal data • Erase their personal data • Object to processing of their personal data • Export personal data Organizations are required to: • Protect personal data by implementing appropriate security • Notify authorities of personal data breaches • Obtain appropriate consent for processing data • Keep records detailing data processing Organizations are required to: • Provide clear notice of data collection • Outline processing purposes and use cases • Define data retention and deletion policies Organizations are required to: • Train privacy personnel and employees • Audit and update data policies • Employ a Data Protection Officer (if required) • Create and manage compliant vendor contracts What key changes result from the GDPR? Data Subject Rights Controls and notifications Transparent policies IT and training
  • 7.
  • 8.
    Protecting customer privacy withGDPR What does this mean for my data?
  • 9.
    GDPR Overview Consent Management Data SubjectRequest Management Breach Notification Data Inventory, Data Policies, and Data Map Data privacy risk management reporting & portal Data Protection Management Risk & Compliance Management for Data Privacy Engagement Your data sources Your personal data definitions Your policies Your business reasons for data capture Responding to data subject requests and consent changes Breach response Ongoing compliance programs Reporting to authorities
  • 10.
    Microsoft Cloud: TrustedPlatform Transparency & Privacy Operational Security Breach Notification Built-in compliance and security to manage and control access to personal data Data Residency
  • 11.
    Classified as MicrosoftConfidential PRIVACY User Privacy User Privacy enables Active Directory tenant administrators to export user specific data and delete accounts. Learn More Request to export user data Submit and manage user requests to export stored data. Learn More View export requests Track and view requests to export user specific data. Learn More Delete user in Active Directory Delete users from the Azure environment by deleting the user in Active Directory. Learn More Manage User Privacy
  • 12.
    Classified as MicrosoftConfidential PRIVACY
  • 13.
    Classified as MicrosoftConfidential NAME USERNAME TYPE SOURCE 15 items (15 users) Search by name or email Name Deleted users Show Aaish Anand aanand@contoso.com Member Windows Server AD Aaron Robins aaron.robins@contoso.com Member Windows Server AD Abner Lominy abner.lominy@contoso.com Member Azure Active Directory Abramo Russo abramo.russo@contoso.com Member Windows Server AD Adrian Sommaerville asommaerville@contoso.com Member Windows Server AD AR Restore user Forget user User forgotten Successfully removed Aaditya Dakenz from the directory.
  • 14.
    Transparency - ComplianceManager Compliance Manager View your compliance posture against evolving regulations in real-time. Take recommended actions to improve your data protection capabilities. Conduct pre-audits to prepare for external audits.
  • 15.
    Azure covers 79compliance offerings  ISO 27001:2013  ISO 27017:2015  ISO 27018:2014  ISO 22301:2012  ISO 9001:2015  ISO 20000-1:2011  SOC 1 Type 2  SOC 2 Type 2  CIS Benchmark  CSA STAR Certification  CSA STAR Certification  CSA STAR Attestation  CSA STAR Self-Assessment  WCAG 2.0 (ISO 40500:2012)  FedRAMP High  FedRAMP Moderate  EAR  DoD DISA SRG Level 5  DoD DISA SRG Level 4  DoD DISA SRG Level 2  DFARS  DoE 10 CFR Part 810  NIST SP 800-171  NIST CSF  Section 508 VPATs  FIPS 140-2  ITAR  CJIS  IRS 1075  PCI DSS Level 1  GLBA  FFIEC  Shared Assessments  FISC (JP)  APRA (AU)  OSFI (CA)  FCA + PRA (UK)  MAS + ABS (SG)  23 NYCRR 500  SEC 17a-4  CFTC 1.31  2FINRA 4511  SOX  HIPAA BAA  HITRUST  21 CFR Part 11 (GxP)  MARS-E  NHS IG Toolkit (UK)  NEN 7510:2011 (NL)  FERPA  CDSA  MPAA  DPP (UK)  FACT (UK)  Argentina PDPA  Australia IRAP Unclassified  Australia IRAP Protected  Canada Privacy Laws  China GB 18030:2005  China DJCP (MLPS) Level 3  China TRUCS / CCCPPF  India MeitY  Japan CS Mark Gold  Japan My Number Act  Netherlands BIR 2012  New Zealand Gov CIO Fwk  Singapore MTCS Level 3  Spain ENS  Spain DPA  UK Cyber Essentials Plus  UK G-Cloud  UK PASF  EN 301 549  EU ENISA IAF  EU Model Clauses  EU – US Privacy Shield  GDPR  Germany C5  Germany IT-Grundschutz Industry U.S. Government Global Regional
  • 16.
    LESSONS LEARNED • IntensiveEngineering Work Begin early, there’s plenty of engineering work ahead. • Continue Sharing and Learning We will share our experience in complying with complex regulations such as the GDPR. • Partners are key in the compliance journey Together with our partners, we are prepared to help you meet your policy, people, process, and technology goals on your journey to GDPR.
  • 17.
    • Microsoft Cloudis GDPR Ready To simplify your path to compliance, we are GDPR compliance ready across our cloud services beginning on May 25, 2018. • Microsoft Cloud is Built on Trust Satya: “Businesses and users are going to embrace technology only if they can trust it.” - Microsoft cloud is built on trust. • Microsoft Cloud I here to enable you to succeed Microsoft provides tools to help you in your compliance journey KEY TAKEAWAYS
  • 18.
    Resources Azure sales guide,playbook, and customizable presentation for GDPR https://aka.ms/GDPR-Partners GDPR on the Microsoft Trust Center https://microsoft.com/gdpr Compliance Manager https://aka.ms/compliancemanager Azure Blueprints https://aka.ms/Azure-Blueprints

Editor's Notes

  • #11 10
  • #12 Enabling Data Subject Requests from Azure Privacy Portal
  • #15 For example, Office 365 has a tool called Compliance Manager that helps you manage compliance in a central place. It delivers real-time risk assessments on Microsoft cloud services, as well as steps you need to take to become compliant. At-a-glance summary of the shared responsibility model reflecting both Microsoft's and your organization’s data protection and compliance posture for standards and regulations such as ISO 27001:2013, NIST 800-53, the Health Insurance Portability and Accountability Act (HIPAA), the European Union General Data Protection Regulation (GDPR) and others. Each tile in the screenshot represents a control framework, which summarizes a Microsoft cloud service and the regulation you’re measuring your compliance against. Compliance for cloud services is a shared responsibility; there are pieces Microsoft controls and pieces you control. Compliance Manager shows how Microsoft meets its obligations and what actions you need to take to meet compliance standards. You can customize the dashboard to display the Microsoft cloud services and regulations relevant to you. From this dashboard, you can see what Microsoft has to do, and what your organization has to do. You can get all the information you need on Microsoft-managed controls here, including the control implementation details, test plan details, and test results. You can also find step-by-step guidance on how to meet the control requirements for the controls you manage. If you want a quick summary of where you stand, you can look at your Compliance Score for each cloud service you use. To simplify the implementation process, Compliance Manager also offers a control management tool to help you stay on top of all the actions you need to take, allowing you to assign tasks to the right person in your organization. Moreover, you can conduct pre-audits to prepare for external audits, creating audit-ready reports containing evidence you collected when implementing controls.