Considerations for GDPR Readiness
This section provides information about using IBM InfoSphere Master Data Management Collaborative Edition to help your organization achieve GDPR readiness.
This document is intended to help you in your preparations for GDPR readiness. It provides information about features of DevOps Deploy, IBM DevOps Deploy with Patterns that you can configure, and aspects of the product's use, that you should consider to help your organization with GDPR readiness. This information is not an exhaustive list, due to the many ways that clients can choose and configure features, and the large variety of ways that the product can be used in itself and with third-party applications and systems.
Clients are responsible for ensuring their own compliance with various laws and regulations, including the European Union General Data Protection Regulation. Clients are solely responsible for obtaining advice of competent legal counsel as to the identification and interpretation of any relevant laws and regulations that may affect the clients' business and any actions the clients may need to take to comply with such laws and regulations.
The products, services, and other capabilities described herein are not suitable for all client situations and may have restricted availability. IBM does not provide legal, accounting, or auditing advice or represent or warrant that its services or products will ensure that clients are in compliance with any law or regulation.
Table of Contents
GDPR
Product Configuration for GDPR
Data Life Cycle
Data Collection
Data Storage
Data Access
Data Processing
Data Deletion
Data Monitoring
Responding to Data Subject Rights
GDPR
General Data Protection Regulation (GDPR) has been adopted by the European Union ("EU") and applies from May 25, 2018.
Why is GDPR important?
GDPR establishes a stronger data protection regulatory framework for processing of personal data of individuals. GDPR brings:
New and enhanced rights for individuals
Widened definition of personal data
New obligations for processors
Potential for significant financial penalties for non-compliance
Compulsory data breach notification
Read more about GDPR
Product Configuration - Considerations for GDPR Readiness
The following sections provide considerations for configuring DevOps Deploy, IBM DevOps Deploy with Patterns to help your organization with GDPR readiness.
Data Life Cycle
What is the end-to-end process through which personal data go through when using our offering?
IBM DevOps Deploy uses a client-server model with a network of agents and relays that communicate with target systems. The server provides the web-based front-end and core services, such as workflow, agent management, and security. Services can be consumed by clients and agents or other services. Deployments are orchestrated by the server and performed by agents distributed throughout the network. Clients access the server through web browsers, the REST API, or the command-line client.
Server-agent communication is done with Java Message Service (JMS) and HTTPS protocols. JMS is used for basic commands and information that is exchanged between the server and an agent. HTTPS is used for file transfers between the server and agents, such as uploading or downloading component version artifacts.
The core installation of Deploy includes a server, agents, and a license server. Agents, which do the application processing, can be installed on cloud environments, virtual machines (VMs), containers, or physical systems. The artifact repository comes with a client application that provides remote access to the repository. In addition to the client application, the artifact repository exposes REST-based web services.
There are several third-party products that interact with Deploy via plug-ins, and might exchange data. Some of these are IBM-owned, and many others are provided by other technology suppliers. The Deploy system requirements website provides links to Software Product Compatibility Reports (SPCR) pages that list the associated software. For considerations for GDPR readiness of a third-party product, see that product’s documentation.
What types of data flow through Deploy?
As a software deployment an integration engine, Deploy does not require sensitive personal data to be gathered from the client or the client's clients.
Personal data used for online contact with IBM
DevOps Deploy, IBM DevOps Deploy with Patterns clients can submit online comments/feedback/requests to contact IBM about product topics in a variety of ways, primarily the comment areas of the following, as applicable:
Typically, only the client name and email address are used, to enable personal replies for the subject of the contact, and the use of personal data conforms to the IBM Online Privacy Statement.
Data Collection
Data Storage
Deployments are orchestrated by the server and performed by agents distributed throughout the network. The file store, CodeStation, contains log files, artifacts, and other non-structured data objects. Reporting tools can connect directly to the relational database.
The file store manages artifacts in a secure and and tamper-proof repository that ensures deployed artifacts are identical to those tested in preproduction environments.
Read more: * A relational database stores configuration and run-time data.
Protection
Deploy uses several technologies to provide security. Some features cannot be disabled, such as Transport Layer Security (TLS) for JMS communication. Other features can be configured to meet client requirements. Some features are enabled by default, such as end-to-end JMS encryption, while others are disabled by default, such as mutual authentication.
Data Access
The Deploy team- and role-based security system manages user interactions and secures product features. Roles control virtually every product area, including the objects that users can create and who can modify the security system itself. User-created objects are managed by teams. Team members can only access objects, such as applications, managed by their team. Team members interact with team-managed objects according to the permissions granted to their role.
Read more: * Deploy team-based security model.
Authentication:
Deploy uses mutual authentication for JMS-based server-agent communication. In this mode, the server provides a digital certificate to each agent and agent relay, and each agent and agent relay provides one to the server. Certificate checks are performed by the JVM according to its own algorithm. Certificates can be issued from a certification authority (CA) if desired, in which instance certificates do not have to be swapped. The integrity of the content is established by the mechanisms built into TLS technology.
Logging administration activity:
Administrative activity is kept in the system logs. instances when the admin user adds a user or changes a users role and permissions are tracked in the log.
Data Processing
Users control the way in which Deploy interacts with data passing through it by their definition of application processes. A process is commonly constructed by a user acting in the role of “developer” working with the component plug-in toolkit. A process is composed of discrete building blocks (known as steps) that are joined together by the developer.
Agents play a central role in Deploy processing. An agent is a lightweight process that runs on a deployment-target host and communicates with the Deploy server. Agents perform the actual work of software deployment which relieves the server of the task. All processes requested by the server are executed on hardware assigned to agents.
Who has access to the Data?
Most customers import users from external LDAP realms. Clients filter LDAP account data for the information they need, such as user IDs, email addresses, and passwords. Groups that the imported users belong to are also imported.
Permissions are assigned to roles and users and groups are placed into roles when they are placed onto teams. Users without roles have read-only privileges and cannot access data let alone modify it.
Encryption:
Communication between server and agents uses a JMS-based (Java Message Service) protocol and can be secured using SSL and TLS, with optional mutual key-based authentication for each end-point. This communication protocol is stateless and resilient to network outages. End-to-end JMS encryption ensures that agents cannot send messages to one another after they are connected to the JMS mesh. It also ensures that JMS clients cannot read messages that are not sent to them. End-to-end encryption ensures that agents do not accept messages from rogue servers or other malicious entities.
When mutual authentication mode is active, Deploy uses it for JMS-based server-agent communication. In this mode, the server provides a digital certificate to each agent and agent relay, and each agent and agent relay provides one to the server. Certificate checks are performed by the JVM according to its own algorithm. Certificates can be issued from a certification authority (CA) if desired. The integrity of the content is established by the mechanisms built into TLS technology.
Unless the client uses a certification authority, the server stores the certificate from each agent in its trust store, and each agent stores the server’s certificate in its trust store. If the client uses agent relays, certificates are swapped between agents, agent relays, and the server. Connections are rejected if the recipient cannot find the sender’s certificate in its trust store.
Read more: * Deploy security features white paper.
Data Deletion
When client-created objects are deleted, they are removed from the Deploy user interface. For auditing purposes, deleted objects remain in the database.
Data Monitoring
With an external monitoring tools, clients can use Managed Beans (MBeans) to review numerous details about Deploy, such as statistics that specify how many components are available or see how long it takes for an application process to run to completion. Clients can use these statistics and details to assess the health of their deployments and deployment processes.
Activity monitoring
Audit and diagnostic logs are under user control. Clients control the amount of user activity maintained and the frequency with which it is stored.
Responding to Data Subject Rights
On premises product managed by the client, please review links provided in earlier sections for configuration information.