A Large GDPR Victim

Steve Jones, 2019-01-29

During the last two years, Redgate has been preparing for the GDPR to take effect in the European Union. As a company based in the UK, we recognized that there were both challenges and opportunities for our business. We needed to ensure we were compliant with the regulations, which would likely require us to change processes and educate our employees. At the same time, our customers would face similar challenges and there was an opportunity to help them achieve their own compliance with software tools.

The GDPR enforcement began last May, though fairly slowly with few fines and decisions being handed down. Across the EU, it seems to have been a quiet period with few companies told they were non compliant. Most organizations likely think all their preparation has been worth the effort and likely believe that they are prepared for any complaints from customers or investigations from regulatory authorities.That confidence may have been shaken in the last week as Google was assessed a fine over $50 million for violations. In particular, the EU regulators in France found that Google had not obtained the consent needed for using certain data in personalizing ads. They also decreed that Google had not clearly presented information about how users data would be handled and stored, as well as creating a difficult process to opt out.

This fine isn't much for the tech giant, but it's just the start and will likely force Google to change the way they handle data. It may also have implications for other tech companies of all sizes. Google is appealing the decision, and this will be an interesting case to follow for data professionals since we may need to ensure that we can comply with the final ruling. Many of us view the data in our organizations as belonging to our employer, with free reign in how we handle, process, and store it. That may change quickly if the ruling is upheld.

Much of the decisions about how companies will deal with data is made by others, but data professionals often need to ensure that we do comply with whatever rules our organizations decide to use. This means a number of practices that we must consider. At a high level, we need to know what data is affected by the GDPR, or any other privacy regulation. This requires that organizations have a data catalog that allows them to track which data is sensitive and must be handled carefully. Few organizations have a comprehensive data catalog already, so this will be an area in which to focus resources during 2019.

Once we are aware of where our sensitive data is stored, we must take precautions to protect this data throughout our organization. Most companies have implemented security in their production environments, but their data handling practices in test and development areas are often not the same. The GDPR calls for anonymization, randomized data, encryption, and other protections, which data professionals will need to implement in a consistent manner throughout their IT infrastructure.

Finally, accidents and malicious attacks will take place. This means that every organization really needs a process to detect data loss and a plan for disclosing the issues to customers. Auditing of activity, forensic analysis, and communication plans need to be developed, practiced, and distributed to the employees that may be involved in security incidents.

There may be other preparations needed, and the larger the company, the more work that will be required. Tools are critical to ensuring this process can be completed in a timely manner, both to save time in implementing processes and also to show regulators that actions are underway to better protect data. Fine levels aren't mandated, and the more effort put into achieving compliance, the less likely that regulators will assess a fine equivalent to 4% of your annual revenue.

There will be plenty of other GDPR fines in the future, and it is worth following this case with Google to see how stringently the regulations will be enforced. The world of data handling practices is changing and all organizations need to get used to better disclosure of practices, tooling for customers, and protection of the data assets they hold.

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