Security is our top priority at AWS, and from the beginning we have built security into the fabric of our services. With the introduction of Gdpr (which becomes enforceable on May 25 of 2018), privacy and data protection have become even more ingrained into our security-centered culture. Three weeks ago, well ahead of the deadline, we announced that all AWS services are compliant with GDPR, meaning you can use AWS as a data processor as a way to help solve your GDPR challenges (be sure to visit our GDPR Center for additional information).
When it comes to GDPR compliance, many customers are progressing nicely and much of the initial trepidation is gone. In my interactions with customers on this topic, a few themes have emerged as universal:
- GDPR is important. You need to have a plan in place if you process personal data of EU data subjects, not only because it’s good governance, but because GDPR does carry significant penalties for non-compliance.
- Solving this can be complex, potentially involving a lot of personnel and multiple tools. Your GDPR process will also likely span across disciplines – impacting people, processes, and technology.
- Each customer is unique, and there are many methodologies around assessing your compliance with GDPR. It’s important to be aware of your own individual business attributes.
I thought it might be helpful to share some of our own lessons learned. In our experience in solving the GDPR challenge, the following were keys to our success:
- Get your senior leadership involved. We have a regular cadence of detailed status conversations about GDPR with our CEO, Andy Jassy. GDPR is high stakes, and the AWS leadership team knows it. If GDPR doesn’t have the attention it needs with the visibility of top management today, it’s time to escalate.
- Centralize the GDPR efforts. Driving all work streams centrally is key. This may sound obvious, but managing this in a distributed manner may result in duplicative effort and/or team members moving in a different direction.
- The most important single partner in solving GDPR is your legal team. Having non-legal people make assumptions about how to interpret GDPR for your unique environment is both risky and a potential waste of time and resources. You want to avoid analysis paralysis by getting proper legal advice, collaborating on a direction, and then moving forward with the proper urgency.
- Collaborate closely with tech leadership. The “process” people in your organization, the ones who already know how to approach governance problems, are typically comfortable jumping right in to GDPR. But technical teams, including data owners, have set up their software for business application. They may not even know what kind of data they are storing, processing, or transferring to other parts of the business. In the GDPR exercise they need to be aware of (or at least help facilitate) the tracking of data and data elements between systems. This isn’t a typical ask for technical teams, so be prepared to educate and to fully understand data flow.
- Don’t live by the established checklists. There are multiple methodologies to solving the compliance challenges of GDPR. At AWS, we ended up establishing core requirements, mapped out by data controller and data processor functions and then, in partnership with legal, decided upon a group of projects based on our known current state. Be careful about using a set methodology, tool or questionnaire to govern your efforts. These generic assessments can help educate, but letting them drive or limit your work could lead to missing something that is key to your own compliance. In this sense, a generic, “one size fits all” solution might not be helpful.
- Don’t be afraid to challenge prior orthodoxy. Many times we changed course based on new information. You shouldn’t be afraid to scrap an effort if you determine it’s not working. You should also not be afraid to escalate issues to senior leadership when needed. This is an executive issue.
- Look for ways to leverage your work beyond this compliance activity. GDPR requires serious effort, but are the results limited to GDPR compliance? Certainly not. You can use GDPR workflows as a way to ensure better governance moving forward. Privacy and security will require work for the foreseeable future, so make your governance program scalable and usable for other purposes.
One last tip that has made all the difference: think about protecting data subjects and work backwards from there. Customer focus drives us to ask, “what would customers and data subjects want and expect us to do?” Taking GDPR from a pure legal or compliance standpoint may be technically sufficient, but we believe the objectives of security and personal data protection require a more comprehensive view, and you can most effectively shape that view by starting with the individuals GDPR was meant to protect.
If you would like to find out more about our experiences, as well as how we can help you in your efforts, please reach out to us today.
Vice President, AWS Security Assurance
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