September 22, 2017 at 4:04 am
Morning Folks,
What is the meaning of segregation of data. We've been told to be compliant with some European laws that we need to 'segregate' data from various countries. In particular Germany and France. How far does one take this segregation? Is a Partitioned View sufficient, where the data exists in a separate tables? Or should it be a separate database? Or should it be a separate server? Or a separate network?
The rules and policies seem rather vague and theoretical.
Any thoughts or experience?
Cheers
Alex
September 22, 2017 at 5:15 am
I'm assuming that this related to GDPR; which is coming into effect in 2018.
In all honesty, I don't really know at this time. We have a Data Protection Officer (DPO) here who's keeping up to speed, but here in the UK the legislation isn't finalised yet (and it's the same to a degree in the EU); mainly due to "BREXIT"... /sigh (can you tell I'm pro EU? 😉 ). This means that you know you need to segregate the data, but not really told how to (the business needs to decide until real guidelines are put in place, if at all).
From my understanding from the DPO (who's sitting behind be), the important part is the proof that your data is segregated, and thus, the how doesn't matter provided that the method you've chosen is effective and you can prove as such. For example, if you simply choose to use Row Level Security/Partitioned view to enforce access for specific users, that is still a form is segregation. Alternatively, you could go as far as storing the data in a different table, different database, or even a totally different instance/Server and/or (physical) location.
The best person to speak to will be your DPO at your company. They should be the most informed on what the current regulations and laws are that affect your clients, and can give you pointers on what they see your business requirements are. Every company is unique, with different systems and processes in place, so there's going to be no "blanket" answer to a question like this, just recommendations; and normally the right person in the business will be the best person to give those for others to then implement. 🙂
Thom~
Excuse my typos and sometimes awful grammar. My fingers work faster than my brain does.
Larnu.uk
September 22, 2017 at 5:28 am
Hiya Thom, thanks for such a quick reply.
I like what you've said and your reasoning. Our current DPO (who leaves in a couple of week) is very knee jerk reactionary to such things and so far is insisting all our data needs to go on separate servers. Though I am getting a whiff of BS there and don't want us to rush in following his heavy handedness if its all speculation. So, as its a new development it wont hurt to go with Row Level security as a method of segregating the data until there is more definitive guides as to how it should handled.
Cheers Thom. Massive help.
Alex
September 22, 2017 at 5:49 am
alex.sqldba - Friday, September 22, 2017 5:28 AMHiya Thom, thanks for such a quick reply.I like what you've said and your reasoning. Our current DPO (who leaves in a couple of week) is very knee jerk reactionary to such things and so far is insisting all our data needs to go on separate servers. Though I am getting a whiff of BS there and don't want us to rush in following his heavy handedness if its all speculation. So, as its a new development it wont hurt to go with Row Level security as a method of segregating the data until there is more definitive guides as to how it should handled.
Cheers Thom. Massive help.
Alex
I'm not saying do/don't listen to your DPO, but if that's their opinion for your business then they must have a reason why.
It helps that our DPO here used to be our Senior DBA, so he understands SQL server and the abilities. Other DPO's may come from a very different background. It's always worth discussing the options with them and understanding what the needs are for the client/regulation. There are often many answers/routes to a single goal, but not everyone will be aware of them; discussing those routes gives everyone a better view and puts all your cards on the table.
Of course, if the DPO is leaving, then they aren't going to be able to oversee the implementation. Thus, you might be better waiting for your new DPO, who can properly document your processes as you implement them; or you could start the discussions again, letting him know that a solution isn't in place yet, but here are what you can do and his input would be appreciated.
I can't stress enough that the documentation is really important here. That's effectively your proof. If you have a process in place, but no documentation, it could be very hard to prove; thus you might still be liable for fines/reprimands/etc even if your system is as robust and secure as Fort Knox.
Thom~
Excuse my typos and sometimes awful grammar. My fingers work faster than my brain does.
Larnu.uk
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