GDPR = RESPECT

Introduction

The General Data Protections Regulation (GDPR) is a ruling intended to protect the data of citizens within the European Union. The GDPR is a move by the European institutions to provide citizens with a greater level of control over their personal data.
The GDPR came into force on May 25th, 2018, replacing national privacy laws and giving people more control over how their data is used by organizations.
More on GDPR: https://en.wikipedia.org/wiki/General_Data_Protection_Regulation

ALLOcloud and the GDPR

End 2017, ALLOcloud appointed an external GDPR consultancy firm to ensure compliance before the due date. This has led to a series of audits and associated actions on our infrastructure, processes, HR, IT tools etc. But things will not stop on May 25th as we plan to work on data privacy and integrity on an on-going basis. Notably, a series of additional actions will probably be required when the ePrivacy regulation will be in application.
More on ePrivacy: https://ec.europa.eu/digital-single-market/en/proposal-eprivacy-regulation

Our Commitment

ALLOcloud is committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place, however we recognize our obligations in updating and expanding this program to meet the demands of the GDPR.
Our preparation and objectives for GDPR compliance have been summarized in this statement and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.

How we prepared for the GDPR

ALLOcloud already had a consistent level of data protection and security across our organization, however it was our aim to be fully compliant with the GDPR. Our preparation included:

• Information Audit: in Q1 and Q2 2018, we carried out several sessions of company-wide information audit to identify and assess what personal information we hold, where it comes from, how and why it is processed and if and to whom it is disclosed.
   
• Policies & Procedures: follow these, we revised and implemented new data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including:

  • Data Protection: our main procedures for data protection has been overhauled to meet the standards and requirements of the GDPR. Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence our obligations and responsibilities; with a dedicated focus on privacy by design and the rights of individuals.

  • Data Retention & Erasure: we have updated our retention procedures to ensure that we meet the ‘data minimization’ and ‘storage limitation’ principles and that personal information is stored, archived and destroyed compliantly and ethically. We have dedicated erasure procedures in place to meet the new ‘Right to Erasure’ obligation and are aware of when this and other data subject’s rights apply.

  • Data Breaches: our breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate and report any personal data breach at the earliest possible time. Our procedures are robust and have been disseminated to all employees, making them aware of the reporting lines and steps to follow.

• Legal Basis for Processing: we reviewed all processing activities to identify the legal basis for processing and ensuring that each basis is appropriate for the activity it relates to. Where applicable, we also maintain records of our processing activities, ensuring that our obligations under Article 30 of the GDPR and Schedule 1 of the Data Protection Bill are met.

• Privacy Policy: we revised our Privacy Policy to comply with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.

• Obtaining Consent: we revised our consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information. We have developed stringent processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records; and an easy to see and access way to withdraw consent at any time.

• Direct Marketing: we revised the wording and processes for direct marketing, including clear opt-in mechanisms for new marketing subscriptions; a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials.

• Processor Agreements: where we use any third-party to process personal information on our behalf (in our case mainly hosting and telecom services), we have asked them to demonstrate their GDPR compliance.

  • Hosting: ALLOcloud infrastructure is hosted on Private (dedicated to ALLOcloud) Infrastructures in external datacenters. ALLOcloud anticipated the GDPR constraints since a while and selected European providers that are part of the CISPE alliance: https://cispe.cloud. This alliance guarantees the GDPR compliance of its members.
    We also use Google Public Cloud infrastructure in Europe but only as disaster recovery hosting (temporarily, should there be a major issue on our Private Cloud infrastructure). Google Cloud European Services are also GDPR compliant: https://cloud.google.com/security/gdpr

  • Telecom providers: ALLOcloud mainly works with Colt Telecom which is GDPR-compliant: https://www.colt.net/data-privacy-statement

Data Subject Rights

In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy to access information via our service portal of an individual’s right to access any personal information that ALLOcloud processes about them.

Our data collection, retention policy and user rights can be found here.

It describes:

• What personal data we hold
• The purposes of the processing
• The recipients to whom the personal data has/will be disclosed
• How long we intend to store your personal data for

Information Security & Technical and Organizational Measures

ALLOcloud takes the privacy and security of individuals and their personal information very seriously and take every reasonable measure and precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorized access, alteration, disclosure or destruction and have several layers of security measures, including: 

• Our datacenters are physically secured and only authorized personnel can access them (even ALLOcloud staff can’t access)
• All our Internet-based resources (website, service platforms, Extranet etc.) use SSL encryption (https://)
• The service platforms enforce strong user passwords
• Device passwords are sent automatically to devices without human intervention. However, we leave the possibility to an administrator to visualize and modify these passwords. In that case, the responsibility becomes hers/his
• Etc.

Further to this, the ALLOcloud staff itself has been given very secure tools and processes:

• ALLOcloud offices are physically secured
• Employee's PCs are encrypted
• Passwords management has been migrated to a highly encrypted password management platform
• Logins (when possible) require 2-step authentication mechanisms
• ALLOcloud employees have been given USB security keys as physical device for 2-step authentication
• Low-level Sysadmin activities are logged and reported
• Platforms are monitored to detect possible intrusion
• Technical staff is on duty 24x7x365
• Efficient escalation processes have been defined (incl SMS alerts)
• Etc.

GDPR Roles and Employees

ALLOcloud designated a Data Protection Officer (DPO) and appointed a data privacy consultant to work on an ongoing basis on data protection. These people are responsible for promoting awareness of the GDPR across the organization, assessing our GDPR compliance, identifying any gap areas and implementing the new policies, procedures and measures.

ALLOcloud understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR and have involved our employees in our preparation plans.

If you have any questions about how we handle GDPR, please contact the Data Protection Officer (DPO). Every ALLOcloud Customer has access to the ALLOcloud ticketing system and should therefore use this mechanism to communicate with the DPO. Customers purchasing through Partners need to communicate through their Partner.