29 April 2011

5 Tips To Avoid Troubles In The Cloud


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Lightningphoto © 2010 scyllarides | more info (via: Wylio)

Couple of days ago I had to review an agreement on cloud computing services that one of the major suppliers in this realm had submitted. When I went through the terms and conditions, I could not gain the impression that the supplier has a great confidence in its capability to deliver the service in question. I found some of the terms even so onerous that I had to consider a strategy to protect my client from getting electrocuted in that supplier’s cloud!

Having thought that sharing some tips on the Reguligence Weblog would be of interest for its readers, I have composed the following list:

1. Service Availability

This agreement reminded me of a telecommunications contract: the supplier basically grants recipient an access to its infrastructure environment and the recipient pays a use-based fee in return.
However, the supplier offers its service on an “as-is” basis and does not warrant any specific availability or quality.
Hence, you should not go for it, if you intend to run a mission critical system in the cloud or your business requires a reliable service performance. You can either endeavour to negotiate different terms or opt for a specifically tailored solution. In both cases the payments are very likely to increase. If you re-sell your services, you should endeavour to limit your liability towards your recipients.

2. Warranties

As mentioned in the beginning of the article – the service supplier seems not confident in its service capabilities. The supplier merely warrants to perform the service with a reasonable care and workmanship. Should you accept it? Well, unless your business model mandates otherwise… You could also suggest a discretionary payment language, something like payment shall be subject to recipient’s overall satisfaction and wait for supplier’s reaction.

3. Liability

What damage are you likely to suffer during such a service delivery? Hmm, maybe loss of data and loss of profit due to a service interruption or an outage? Yes, I guess they are the likeliest to occur, but I  feel you can already assume that, they are –  what? – excluded, what else?
So, make sure you have not entered into an obligation to recover your customer for such losses because this could ruin your business!

4. Data Security

From what I did read, I would never encourage you to upload sensitive data onto the cloud… Again, your supplier is neither liable to keep them secret and confidential nor to retrieve them if they happen to disappear.

5. Data Protection

Albeit this is the last topic on my list, it is very wise to pay special attention to it because data protection may be a very tricky issue under the jurisdiction of a EU member state. Beware if you have to upload personal data onto the cloud – your supplier has access to them and is eager to process them for its own purposes! And this is the catch: personal data must be obtained and processed only for a specified purpose. I bet your purpose will differ from the one of your supplier. Besides, as a general rule personal data must not be transferred outside the European Economic Area, so make sure you have read and understood your cloud services agreement or process previously anonymized data only.

My Final Say

Cloud services may be a great thing if you need a specific infrastructure whose purchase for a single project would not pay off.
On the other hand, cloud services agreements seem to be too much supplier oriented and, as a matter of fact, detrimental to the recipient.

Make sure you do not use cloud services to run mission critical tasks, at least not before you have spoken with your trusted lawyer!

Cloud Texture 11photo © 2009 Jacob Gube | more info (via: Wylio)

Questions, suggestions, opinions? Just use the comment function below.

18 January 2010

Austria’s data protection council disfavours new bill on data retention


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The Data Protection Council is an advisory body within the Austrian Federal Chancellery’s administration. In a recent session the Council debated on the newly presented bill on data retention and passed an opinion to the government. The authority’s chair publicly presented the opinion’s upshot: the bill conflicts with Articles 8 and 9 of the ECHR, hence the Council moves for a balance between the privacy right of the persons concerned and the public interest to maintain security and order.

The Council further calls for a restrictive definition of a “serious crime” in order to achieve the data retention directive’s goal to fight organised crime and terrorism.

The Council seems to carefully observe the international, in particular the European, development on data retention. This is mirrored in Council’s recommendation to await the inauguration of the new European Commission and the enactment of the Stockholm Programme, which, given a sufficient consideration to certain privacy aspects, may lead to the data retention directive’s annulment.

I personally share that view and strongly hope for the Council to be proved correct.

24 November 2009

The US cares for data protection


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IMG_1458photo © 2011 John Taylor | more info (via: Wylio)

 

Well, I agree the title of this post reads somewhat provocative. Nevertheless, it is driven by the criticism that European data protection practitioners usually express towards their US colleagues’ approach when dealing with privacy and protection of personal data.

This should not surprise as the right to privacy is a highly developed area of law in Europe. Accordingly, the European Union has long had a privacy framework for the processing of personal information that is different – and more restrictive — than privacy practices in the US. By contrast, the United States prefers what is called a “sectoral” approach to data protection legislation, relying on a combination of legislation, regulation, and self-regulation, rather than overarching governmental regulations (see “A Framework for Global Electronic Commerce“. To date, the US has no single, overarching privacy law comparable to the EU Directive.

The EU Data Protection Directive requires EU member states to provide for legislation that prohibits the transfer of personal data outside the EU. However, there are some exemptions from that rule, one of which applies where the EU has determined that the laws of the country of destination provide “adequate” protection for personal data. Among others, Switzerland and Argentina were determined to be such countries. In the late 1990s, the EU determined that the laws of the United States did not meet its adequacy standard.

However and in order not to totally prohibit the personal data transfer between the largest economies, the US Department of Commerce in consultation with the European Commission developed the “Safe Harbor Arrangement”. As a consequence, US companies that are under the jurisdiction of the Federal Trade Commission or the US Department of Transportation may enrol to that arrangement and process personal data submitted by European partners (subsidiaries) of theirs.

A company under the FTC’s jurisdiction that self-certifies its compliance with the Safe Harbor Arrangement, but fails to observe them may be subject to an enforcement action under Section 5 of the FTC Act, which prohibits unfair or deceptive trade practices.

After a decade without any enforcement actions, the FTC recently proceeded against seven companies and obtained consent orders against them.

While these actions by the FTC are said not to represent substantive enforcement within the Safe Harbor Arrangement, they do signify that companies need to be even more vigilant about the content of their privacy policies and marketing assertions.

13 November 2009

The retention of internet traffic data saves New Yorker Teen from robbery charges


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No, this is not a text dedicated to advocate company policies or governmental prescriptions on data retention, even though defenders of retaining communications networks’ data might well use it for such purposes.

It is the story of the 19-year-old New York City Teen Rodney Bradford which shows that a policy to retain user’s traffic data may also have an yet undiscovered “bright side”.
Just imagine Rodney’s life given a verdict sending him to jail….
And yes, I believe that Facebook’s policy to keep certain log files stored for a while literally saved this boy’s life.

Hence my Friday’s message to the audience: Try listening to “Always look on the bright side of life” when thinking of data retention -).

29 October 2009

Commission steps up UK legal action over privacy and personal data protection


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The European Commission has moved to the second phase of an infringement proceeding over the UK to provide its citizens with the full protection of EU rules on privacy and personal data protection when using electronic communications. European laws state that EU countries must ensure the confidentiality of people’s electronic communications like email or internet browsing by prohibiting their unlawful interception and surveillance without the user’s consent. As these rules have not been fully put in place in the national law of the UK, the Commission today said that it will send the UK a reasoned opinion.

Specifically, the Commission has identified

Three Gaps In the Existing UK Rules

governing the confidentiality of electronic communications, namely:

No Independent National Authority

to supervise interception of communications, although the establishment of such authority is required under the ePrivacy and Data Protection Directives, in particular to hear complaints regarding interception of communications;

No Need To Grant Explicit Consent

The current UK law the Regulation of Investigatory Powers Act 2000 (RIPA) authorises interception of communications not only where the persons concerned have consented to interception but also when the person intercepting the communications has ‘reasonable grounds for believing’ that consent to do so has been given. These UK law provisions do not comply with EU rules defining consent as freely given specific and informed indication of a person’s wishes;

No Sanctions Against Unlawful Interception

The RIPA provisions prohibiting and providing sanctions in case of unlawful interception are limited to ‘intentional’ interception only, whereas the EU law requires Members States to prohibit and to ensure sanctions against any unlawful interception regardless of whether committed intentionally or not.

The UK has two months to reply to this second stage of the infringement proceeding. If the Commission receives no reply, or if the response presented by the UK is not satisfactory, the Commission may refer the case to the European Court of Justice.

To me, this is a clear signal that data protection and privacy are considered highly valuable achievements that need to be  protected within the European dimension.

13 September 2009

New Commission’s communication on enhancing the enforcement of intellectual property rights in the internal market


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The European Commission has published a new communication (COM 2009/467) to the Council, the Parliament and the Economic and Social Committee. In this communication the Commission acknowledges that the Union is the home of some very large and successful businesses in the world, who consider IPR to be amongst their most precious commercial possessions. The Commission further acknowledges that counterfeiting and piracy have a dramatic and damaging effect on business in Europe, wherefore certain measures Enforcement Directive, Customs Regulation) to better combat such counterfeiting and piracy were undertaken in the past.

The Commission

Seeks to Support and Enhance the Enforcement

by complementing the existing regulatory framework with non-legislative measures to make for more collaborative and focused enforcement across the Internal Market, in particular by:

  • supporting enforcement through an EU Counterfeiting and Piracy Observatory;
  • fostering administrative cooperation throughout the Internal Market;
  • facilitating voluntary arrangements between stakeholders.

The Commission suggests that the Observatory serve as the central resource for gathering, monitoring and reporting information and data related to all IPR infringements.

The Commission views s greater administrative cooperation in the field of IPR enforcement in the wider context of a partnership between the Commission and the Member States in implementing a borderless internal market.

Concerning its last point, arrangements between stakeholders, the Commission stresses that such solutions have to be

Compliant with the Existing Legal Framework

and should neither restrict in any way the fundamental rights of EU citizens, such as the freedom of expression and information, the right to privacy and the protection of personal data.

6 May 2009

Consumer Rights: EU Commission wants consumers to surf the web without borders


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The European Commission launched the eYouGuide, a new online tool giving practical advice on the “digital rights” consumers have under EU law.

This guide, which responds to a call from the European Parliament in 2007, addresses consumer issues like the rights towards your broadband provider, shopping on the web, downloading music and protecting your personal data online and on social networking sites.

Even though 48.5% of EU households have a broadband internet connection, a new Eurobarometer survey shows that a lack of confidence still holds many consumers back from online transactions.
Only 12% of EU web users feel safe making transactions on the internet, while 39% of EU internet users have major doubts about safety, and 42% do not dare carry out financial transactions online. 65% of internet users in the EU do not know where to get information and advice about cross-border shopping in the EU.

A third of consumers would consider buying online from another country because it is cheaper or better, but only 7% actually do so. Giving consumers clear information about their rights will increase trust and help unlock the full economic potential of Europe’s single online market, worth EUR 106 billion in revenues.

28 January 2009

So, it happened again…


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What is one supposed to do in case he or she suffers a so called identity theft?
And who is to be deemed responsible therefor? The data controller, the data processor or the data subject (to stay in the definitions of the data protection legislation)?

According to this report the UK’s largest recruitment websites lost (partially sensitive!) data records of more than 4,5 Million of its subscribers.

Data and identity theft, however, seems to have some tradition in Britain and should, in my humble opinion, be questioned on the highest possible level.

This dangerous practice must be countered by appropriate measurements including both legislative and technical improvements. Alternatively we are on the best way to lose what has remained of our anyway reduced privacy.

12 December 2008

Virtual theft – real punishment?


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Virtual theft and virtual fraud appear to be widely spread among the online and gaming community.
Authorities in the Nethderlands and in the USA have thus undertaken proceedings against wrongdoers.

What is the moral of the story?
Owing to the lower threshold required, one is likelier to conduct an offense online. But beware of what you do, because you can get an offline punishment!