Tag Archives: Europe

All you need to know about the Digital Services Act

Post Syndicated from Petra Arts http://blog.cloudflare.com/author/petra/ original https://blog.cloudflare.com/digital-services-act


February 17th, 2024 marked the entry into force of a landmark piece of European Union (EU) legislation, affecting European users who create and disseminate online content as well as tech companies who act as “intermediaries” on the Internet. I am talking of course about the EU Digital Services Act, or DSA for short. The DSA was first proposed in December 2020, and is meant to update a 20-year-old law called the EU e-commerce Directive, which provides important safeguards and legal certainty for all businesses operating online. The principles of that legal framework, most notably the introduction of EU-wide rules on intermediary liability, are still of major importance today. The DSA is a landmark piece of European legislation because it also sets out, for the first time, enhanced regulatory requirements for (large) digital platforms, thus affecting the entire Internet ecosystem.

At Cloudflare, we are supportive of the longstanding legal frameworks both in Europe and other parts of the world that protect Internet companies from liability for the content that is uploaded or sent through their networks by their users, subscribers or customers. These frameworks are indispensable for the growth of online services, and have been essential in the growth of online applications, marketplaces and social networks.

What’s the Digital Services Act all about?

The EU Digital Services Act consists of two main parts: First, the DSA maintains the strong liability protections for intermediary services that have existed in Europe for over 20 years, and modernizes them, including by giving explicit recognition of supporting Internet services. Services which perform important roles in the functioning of the Internet, such as CDNs, reverse proxies and technical services at the DNS level were not explicitly mentioned in the EU e-commerce Directive at the time. The DSA, in recital 28, recognises that those services, along with many others, are part of the fundamental fabric of the Internet and deserve protection against liability for any illegal or infringing content. This marks an important clarification milestone in EU law.

Secondly, the DSA establishes varying degrees of due diligence and transparency obligations for intermediary services that offer services in the EU. The DSA follows a ‘staggered’ or ‘cumulative’ approach to those obligations and the different services it applies to. This ranges from a number of detailed obligations for the largest platforms (so-called “Very Large Online Platforms” or VLOPs, such as the Apple App Store, Facebook, TikTok, and YouTube), down to less extensive but still impactful rules for smaller platforms, hosting services and Internet intermediaries. What is really important to note with regard to the different service providers that are impacted is that the DSA clearly distinguishes between (technical) intermediary services, “mere” hosting services, and “online platforms”, with the latter category having a number of additional obligations under the new law. Online platform services are considered as hosting services which store information at the request of the recipients of the service, with the important additional role of also disseminating that information to the public.

This proportionate approach is in line with Cloudflare’s view of the Internet stack and the idea that infrastructure services are distinct from social media and search services that are designed to curate and recommend Internet content. This principle of a targeted, proportionate response to the matter is also embedded in the DSA itself. Recital 27 states that “(…) any requests or orders for [such] involvement should, as a general rule, be directed to the specific provider that has the technical and operational ability to act against specific items of illegal content, so as to prevent and minimise (sic) any possible negative effects on the availability and accessibility of information that is not illegal content”. This is an important provision, as principles of proportionality, freedom of speech, and access to information should be safeguarded at all times when it relates to online content.

What do the new rules mean for Cloudflare?

As a provider of intermediary services, Cloudflare has engaged with European policymakers on the topic of intermediary liability for a number of years. From the start of the legislative process on the proposed DSA in 2020 we have contributed extensively to public consultations, and have shared our views on the proposed DSA with lawmakers in Brussels.

In many ways, the final version of the law reflects our existing practices. We have long taken the position, for example, that our intermediary services should have different rules than our hosting services, as is anticipated under the DSA. We have taken a few additional measures to ensure compliance with DSA requirements. For instance, we’ve announced a new legal representative in the EU and point of contact for the purposes of the DSA.

Cloudflare has strongly believed in transparency reporting for a long time, and we have issued transparency reports twice a year since 2013. We recognize that the DSA includes some new requirements around transparency reporting, some of which match with our current reports and processes, and others that do not. We will be revising our transparency reporting, to reflect the DSA’s requirements, beyond our existing documentation. We have also taken steps to confirm that our limited hosting services comply with DSA requirements.

The EU Digital Services Act, because of its enhanced regulatory requirements for (large) digital platforms, represents a significant change to the Internet ecosystem. Cloudflare feels nonetheless well-prepared to address the different requirements that came into force on February 17, 2024, and we look forward to having positive and constructive conversations with relevant European regulators as they start to work on the enforcement of the new law.

Reflecting on the GDPR to celebrate Privacy Day 2024

Post Syndicated from Emily Hancock http://blog.cloudflare.com/author/emily-hancock/ original https://blog.cloudflare.com/reflecting-on-the-gdpr-to-celebrate-privacy-day-2024


Just in time for Data Privacy Day 2024 on January 28, the EU Commission is calling for evidence to understand how the EU’s General Data Protection Regulation (GDPR) has been functioning now that we’re nearing the 6th anniversary of the regulation coming into force.

We’re so glad they asked, because we have some thoughts. And what better way to celebrate privacy day than by discussing whether the application of the GDPR has actually done anything to improve people’s privacy?

The answer is, mostly yes, but in a couple of significant ways – no.

Overall, the GDPR is rightly seen as the global gold standard for privacy protection. It has served as a model for what data protection practices should look like globally, it enshrines data subject rights that have been copied across jurisdictions, and when it took effect, it created a standard for the kinds of privacy protections people worldwide should be able to expect and demand from the entities that handle their personal data. On balance, the GDPR has definitely moved the needle in the right direction for giving people more control over their personal data and in protecting their privacy.

In a couple of key areas, however, we believe the way the GDPR has been applied to data flowing across the Internet has done nothing for privacy and in fact may even jeopardize the protection of personal data. The first area where we see this is with respect to cross-border data transfers. Location has become a proxy for privacy in the minds of many EU data protection regulators, and we think that is the wrong result. The second area is an overly broad interpretation of what constitutes “personal data” by some regulators with respect to Internet Protocol or “IP” addresses. We contend that IP addresses should not always count as personal data, especially when the entities handling IP addresses have no ability on their own to tie those IP addresses to individuals. This is important because the ability to implement a number of industry-leading cybersecurity measures relies on the ability to do threat intelligence on Internet traffic metadata, including IP addresses.  

Location should not be a proxy for privacy

Fundamentally, good data security and privacy practices should be able to protect personal data regardless of where that processing or storage occurs. Nevertheless, the GDPR is based on the idea that legal protections should attach to personal data based on the location of the data – where it is generated, processed, or stored. Articles 44 to 49 establish the conditions that must be in place in order for data to be transferred to a jurisdiction outside the EU, with the idea that even if the data is in a different location, the privacy protections established by the GDPR should follow the data. No doubt this approach was influenced by political developments around government surveillance practices, such as the revelations in 2013 of secret documents describing the relationship between the US NSA (and its Five Eyes partners) and large Internet companies, and that intelligence agencies were scooping up data from choke points on the Internet. And once the GDPR took effect, many data regulators in the EU were of the view that as a result of the GDPR’s restrictions on cross-border data transfers, European personal data simply could not be processed in the United States in a way that would be consistent with the GDPR.

This issue came to a head in July 2020, when the European Court of Justice (CJEU), in its “Schrems II” decision1, invalidated the EU-US Privacy Shield adequacy standard and questioned the suitability of the EU standard contractual clauses (a mechanism entities can use to ensure that GDPR protections are applied to EU personal data even if it is processed outside the EU). The ruling in some respects left data protection regulators with little room to maneuver on questions of transatlantic data flows. But while some regulators were able to view the Schrems II ruling in a way that would still allow for EU personal data to be processed in the United States, other data protection regulators saw the decision as an opportunity to double down on their view that EU personal data cannot be processed in the US consistent with the GDPR, therefore promoting the misconception that data localization should be a proxy for data protection.

In fact, we would argue that the opposite is the case. From our own experience and according to recent research2, we know that data localization threatens an organization’s ability to achieve integrated management of cybersecurity risk and limits an entity’s ability to employ state-of-the-art cybersecurity measures that rely on cross-border data transfers to make them as effective as possible. For example, Cloudflare’s Bot Management product only increases in accuracy with continued use on the global network: it detects and blocks traffic coming from likely bots before feeding back learnings to the models backing the product. A diversity of signal and scale of data on a global platform is critical to help us continue to evolve our bot detection tools. If the Internet were fragmented – preventing data from one jurisdiction being used in another – more and more signals would be missed. We wouldn’t be able to apply learnings from bot trends in Asia to bot mitigation efforts in Europe, for example. And if the ability to identify bot traffic is hampered, so is the ability to block those harmful bots from services that process personal data.

The need for industry-leading cybersecurity measures is self-evident, and it is not as if data protection authorities don’t realize this. If you look at any enforcement action brought against an entity that suffered a data breach, you see data protection regulators insisting that the impacted entities implement ever more robust cybersecurity measures in line with the obligation GDPR Article 32 places on data controllers and processors to “develop appropriate technical and organizational measures to ensure a level of security appropriate to the risk”, “taking into account the state of the art”. In addition, data localization undermines information sharing within industry and with government agencies for cybersecurity purposes, which is generally recognized as vital to effective cybersecurity.

In this way, while the GDPR itself lays out a solid framework for securing personal data to ensure its privacy, the application of the GDPR’s cross-border data transfer provisions has twisted and contorted the purpose of the GDPR. It’s a classic example of not being able to see the forest for the trees. If the GDPR is applied in such a way as to elevate the priority of data localization over the priority of keeping data private and secure, then the protection of ordinary people’s data suffers.

Applying data transfer rules to IP addresses could lead to balkanization of the Internet

The other key way in which the application of the GDPR has been detrimental to the actual privacy of personal data is related to the way the term “personal data” has been defined in the Internet context – specifically with respect to Internet Protocol or “IP” addresses. A world where IP addresses are always treated as personal data and therefore subject to the GDPR’s data transfer rules is a world that could come perilously close to requiring a walled-off European Internet. And as noted above, this could have serious consequences for data privacy, not to mention that it likely would cut the EU off from any number of global marketplaces, information exchanges, and social media platforms.

This is a bit of a complicated argument, so let’s break it down. As most of us know, IP addresses are the addressing system for the Internet. When you send a request to a website, send an email, or communicate online in any way, IP addresses connect your request to the destination you’re trying to access. These IP addresses are the key to making sure Internet traffic gets delivered to where it needs to go. As the Internet is a global network, this means it’s entirely possible that Internet traffic – which necessarily contains IP addresses – will cross national borders. Indeed, the destination you are trying to access may well be located in a different jurisdiction altogether. That’s just the way the global Internet works. So far, so good.

But if IP addresses are considered personal data, then they are subject to data transfer restrictions under the GDPR. And with the way those provisions have been applied in recent years, some data regulators were getting perilously close to saying that IP addresses cannot transit jurisdictional boundaries if it meant the data might go to the US. The EU’s recent approval of the EU-US Data Privacy Framework established adequacy for US entities that certify to the framework, so these cross-border data transfers are not currently an issue. But if the Data Privacy Framework were to be invalidated as the EU-US Privacy Shield was in the Schrems II decision, then we could find ourselves in a place where the GDPR is applied to mean that IP addresses ostensibly linked to EU residents can’t be processed in the US, or potentially not even leave the EU.

If this were the case, then providers would have to start developing Europe-only networks to ensure IP addresses never cross jurisdictional boundaries. But how would people in the EU and US communicate if EU IP addresses can’t go to the US? Would EU citizens be restricted from accessing content stored in the US? It’s an application of the GDPR that would lead to the absurd result – one surely not intended by its drafters. And yet, in light of the Schrems II case and the way the GDPR has been applied, here we are.

A possible solution would be to consider that IP addresses are not always “personal data” subject to the GDPR. In 2016 – even before the GDPR took effect – the Court of Justice of the European Union (CJEU) established the view in Breyer v. Bundesrepublik Deutschland that even dynamic IP addresses, which change with every new connection to the Internet, constituted personal data if an entity processing the IP address could link the IP addresses to an individual. While the court’s decision did not say that dynamic IP addresses are always personal data under European data protection law, that’s exactly what EU data regulators took from the decision, without considering whether an entity actually has a way to tie the IP address to a real person3.

The question of when an identifier qualifies as “personal data” is again before the CJEU: In April 2023, the lower EU General Court ruled in SRB v EDPS4 that transmitted data can be considered anonymised and therefore not personal data if the data recipient does not have any additional information reasonably likely to allow it to re-identify the data subjects and has no legal means available to access such information. The appellant – the European Data Protection Supervisor (EDPS) – disagrees. The EDPS, who mainly oversees the privacy compliance of EU institutions and bodies, is appealing the decision and arguing that a unique identifier should qualify as personal data if that identifier could ever be linked to an individual, regardless of whether the entity holding the identifier actually had the means to make such a link.

If the lower court’s common-sense ruling holds, one could argue that IP addresses are not personal data when those IP addresses are processed by entities like Cloudflare, which have no means of connecting an IP address to an individual. If IP addresses are then not always personal data, then IP addresses will not always be subject to the GDPR’s rules on cross-border data transfers.

Although it may seem counterintuitive, having a standard whereby an IP address is not necessarily “personal data” would actually be a positive development for privacy. If IP addresses can flow freely across the Internet, then entities in the EU can use non-EU cybersecurity providers to help them secure their personal data. Advanced Machine Learning/predictive AI techniques that look at IP addresses to protect against DDoS attacks, prevent bots, or otherwise guard against personal data breaches will be able to draw on attack patterns and threat intelligence from around the world to the benefit of EU entities and residents. But none of these benefits can be realized in a world where IP addresses are always personal data under the GDPR and where the GDPR’s data transfer rules are interpreted to mean IP addresses linked to EU residents can never flow to the United States.

Keeping privacy in focus

On this Data Privacy Day, we urge EU policy makers to look closely at how the GDPR is working in practice, and to take note of the instances where the GDPR is applied in ways that place privacy protections above all other considerations – even appropriate security measures mandated by the GDPR’s Article 32 that take into account the state of the art of technology. When this happens, it can actually be detrimental to privacy. If taken to the extreme, this formulaic approach would not only negatively impact cybersecurity and data protection, but even put into question the functioning of the global Internet infrastructure as a whole, which depends on cross-border data flows. So what can be done to avert this?

First, we believe EU policymakers could adopt guidelines (if not legal clarification) for regulators that IP addresses should not be considered personal data when they cannot be linked by an entity to a real person. Second, policymakers should clarify that the GDPR’s application should be considered with the cybersecurity benefits of data processing in mind. Building on the GDPR’s existing recital 49, which rightly recognizes cybersecurity as a legitimate interest for processing, personal data that needs to be processed outside the EU for cybersecurity purposes should be exempted from GDPR restrictions to international data transfers. This would avoid some of the worst effects of the mindset that currently views data localization as a proxy for data privacy. Such a shift would be a truly pro-privacy application of the GDPR.

1 Case C-311/18, Data Protection Commissioner v Facebook Ireland and Maximillian Schrems.
2 Swire, Peter and Kennedy-Mayo, DeBrae and Bagley, Andrew and Modak, Avani and Krasser, Sven and Bausewein, Christoph, Risks to Cybersecurity from Data Localization, Organized by Techniques, Tactics, and Procedures (2023).
3 Different decisions by the European data protection authorities, namely the Austrian DSB (December 2021), the French CNIL (February 2022) and the Italian Garante (June 2022), while analyzing the use of Google Analytics, have rejected the relative approach used by the Breyer case and considered that an IP address should always be considered as personal data. Only the decision issued by the Spanish AEPD (December 2022) followed the same interpretation of the Breyer case. In addition, see paragraphs 109 and 136 in Guidelines by Supervisory Authorities for Tele-Media Providers, DSK (2021).
4 Single Resolution Board v EDPS, Court of Justice of the European Union, April 2023.

AWS named as a Leader in 2023 ISG Provider Lens report for Multi Public Cloud Services – Sovereign Cloud Infrastructure Services (EU)

Post Syndicated from Marta Taggart original https://aws.amazon.com/blogs/security/aws-named-as-a-leader-in-2023-isg-provider-lens-report-for-multi-public-cloud-services-sovereign-cloud-infrastructure-services-eu/

Amazon Web Services (AWS) is named as a Leader in the 2023 ISG Provider Lens Quadrant Report for Multi Public Cloud Services – Sovereign Cloud Infrastructure Services (EU), published on January 8, 2024. This first-ever Information Services Group (ISG) report evaluates providers of sovereign cloud infrastructure services in the multi public cloud environment and examines how they address the key challenges that confront enterprise clients in the European Union (EU). ISG defines Leaders as representing innovative strength and competitive stability.

AWS received the highest score among the providers that ISG evaluated on portfolio attractiveness, which was assessed on multiple factors, including:

  • Scope of portfolio – breadth and depth of offering
  • Portfolio quality – technology and skills, customer satisfaction, and security
  • Strategy and vision – product roadmap, thought leadership, and investments
  • Local characteristics – product support and infrastructure

According to ISG, “AWS’ network of data centers across the EU provides sovereign cloud services that are highly scalable. The AWS Nitro System, the foundation of AWS’ cloud services, ensures data residency, privacy, and sovereignty.”

Read the report to:

  • Gain perspective on the factors that ISG believes will influence the sovereign cloud market in the EU.
  • Discover some of the considerations that enterprises in the EU should consider when evaluating sovereign cloud infrastructure services.
  • Learn how the AWS Cloud is sovereign-by-design and how we continue to innovate without compromising on the full power of AWS.

The recognition of AWS as a Leader in this report highlights the work that we have undertaken to help address the complexity that European customers are facing in the evolving sovereignty landscape. AWS continues to deliver on the AWS Digital Sovereignty Pledge by investing in a comprehensive and ambitious roadmap of capabilities of data residency, granular access restriction, encryption, and resilience to provide customers with more choice in meeting their unique needs. Our recent innovations to help customers address their local regulatory requirements and sovereignty needs include AWS Dedicated Local Zones and the announcement of plans to launch the AWS European Sovereign Cloud. Download the full 2023 ISG Provider Lens Quadrant Report for Multi Public Cloud Services – Sovereign Cloud Infrastructure Services (EU) from AWS.

If you have feedback about this post, submit comments in the Comments section below.

Author

Marta Taggart

Marta is a Seattle-native and Principal Product Marketing Manager in AWS Security Product Marketing, where she focuses on data protection services and digital sovereignty. Outside of work, you’ll find her trying to convince Jack, her rescue dog, not to chase squirrels (with limited success).

AWS achieves TISAX certification (Information with Very High Protection Needs (AL3)

Post Syndicated from Janice Leung original https://aws.amazon.com/blogs/security/aws-achieves-tisax-certification-information-with-very-high-protection-needs-al3/

We’re excited to announce the completion of the Trusted Information Security Assessment Exchange (TISAX) certification on June 30, 2022 for 19 AWS Regions. These Regions achieved the Information with Very High Protection Needs (AL3) label for the control domains Information Handling and Data Protection. This alignment with TISAX requirements demonstrates our continued commitment to adhere to the heightened expectations for cloud service providers. AWS automotive customers can run their applications in the AWS Cloud certified Regions in confidence.

The following 19 Regions are currently TISAX certified:

  • US East (Ohio)
  • US East (Northern Virginia)
  • US West (Oregon)
  • Africa (Cape Town)
  • Asia Pacific (Hong Kong)
  • Asia Pacific (Mumbai)
  • Asia Pacific (Osaka)
  • Asia Pacific (Korea)
  • Asia Pacific (Singapore)
  • Asia Pacific (Sydney)
  • Asia Pacific (Tokyo)
  • Canada (Central)
  • Europe (Frankfurt)
  • Europe (Ireland)
  • Europe (London)
  • Europe (Milan)
  • Europe (Paris)
  • Europe (Stockholm)
  • South America (Sao Paulo)

TISAX is a European automotive industry-standard information security assessment (ISA) catalog based on key aspects of information security, such as data protection and connection to third parties.

AWS was evaluated and certified by independent third-party auditors on June 30, 2022. The Certificate of Compliance demonstrating the AWS compliance status is available on the European Network Exchange (ENX) Portal (the scope ID and assessment ID are SM22TH and AYA2D4-1, respectively) and through AWS Artifact. AWS Artifact is a self-service portal for on-demand access to AWS compliance reports. Sign in to AWS Artifact in the AWS Management Console, or learn more at Getting Started with AWS Artifact.

For up-to-date information, including when additional Regions are added, see the AWS Compliance Program, and choose TISAX.

AWS strives to continuously bring services into scope of its compliance programs to help you meet your architectural and regulatory needs. Please reach out to your AWS account team if you have questions or feedback about TISAX compliance.

To learn more about our compliance and security programs, see AWS Compliance Programs. As always, we value your feedback and questions; reach out to the AWS Compliance team through the Contact Us page.

If you have feedback about this post, submit comments in the Comments section below.

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Author

Janice Leung

Janice is a security audit program manager at AWS, based in New York. She leads security audits across Europe and has previously worked in security assurance and technology risk management in the financial industry for 10 years.

Introducing the Customer Metadata Boundary

Post Syndicated from Jon Levine original https://blog.cloudflare.com/introducing-the-customer-metadata-boundary/

Introducing the Customer Metadata Boundary

Introducing the Customer Metadata Boundary

Data localisation has gotten a lot of attention in recent years because a number of countries see it as a way of controlling or protecting their citizens’ data. Countries such as Australia, China, India, Brazil, and South Korea have or are currently considering regulations that assert legal sovereignty over their citizens’ personal data in some fashion — health care data must be stored locally; public institutions may only contract with local service providers, etc.

In the EU, the recent “Schrems II” decision resulted in additional requirements for companies that transfer personal data outside the EU. And a number of highly regulated industries require that specific types of personal data stay within the EU’s borders.

Cloudflare is committed to helping our customers keep personal data in the EU. Last year, we introduced the Data Localisation Suite, which gives customers control over where their data is inspected and stored.

Today, we’re excited to introduce the Customer Metadata Boundary, which expands the Data Localisation Suite to ensure that a customer’s end user traffic metadata stays in the EU.

Metadata: a primer

“Metadata” can be a scary term, but it’s a simple concept — it just means “data about data.” In other words, it’s a description of activity that happened on our network. Every service on the Internet collects metadata in some form, and it’s vital to user safety and network availability.

At Cloudflare, we collect metadata about the usage of our products for several purposes:

  • Serving analytics via our dashboards and APIs
  • Sharing logs with customers
  • Stopping security threats such as bot or DDoS attacks
  • Improving the performance of our network
  • Maintaining the reliability and resiliency of our network

What does that collection look like in practice at Cloudflare? Our network consists of dozens of services: our Firewall, Cache, DNS Resolver, DDoS protection systems, Workers runtime, and more. Each service emits structured log messages, which contain fields like timestamps, URLs, usage of Cloudflare features, and the identifier of the customer’s account and zone.

These messages do not contain the contents of customer traffic, and so they do not contain things like usernames, passwords, personal information, and other private details of customers’ end users. However, these logs may contain end-user IP addresses, which is considered personal data in the EU.

Data Localisation in the EU

The EU’s General Data Protection Regulation, or GDPR, is one of the world’s most comprehensive (and well known) data privacy laws. The GDPR does not, however, insist that personal data must stay in Europe. Instead, it provides a number of legal mechanisms to ensure that GDPR-level protections are available for EU personal data if it is transferred outside the EU to a third country like the United States. Data transfers from the EU to the US were, until recently, permitted under an agreement called the EU-U.S. Privacy Shield Framework.

Shortly after the GDPR went into effect, a privacy activist named Max Schrems filed suit against Facebook for their data collection practices. In July 2020, the Court of Justice of the EU issued the “Schrems II” ruling — which, among other things, invalidated the Privacy Shield framework. However, the court upheld other valid transfer mechanisms that ensure EU personal data won’t be accessed by U.S. government authorities in a way that violates the GDPR.

Since the Schrems II decision, many customers have asked us how we’re protecting EU citizens’ data. Fortunately, Cloudflare has had data protection safeguards in place since well before the Schrems II case, such as our industry-leading commitments on government data requests. In response to Schrems II in particular, we updated our customer Data Processing Addendum (DPA). We incorporated the latest Standard Contractual Clauses, which are legal agreements approved by the EU Commission that enable data transfer. We also added additional safeguards as outlined in the EDPB’s June 2021 Recommendations on Supplementary Measures. Finally, Cloudflare’s services are certified under the ISO 27701 standard, which maps to the GDPR’s requirements.

In light of these measures, we believe that our EU customers can use Cloudflare’s services in a manner consistent with GDPR and the Schrems II decision. Still, we recognize that many of our customers want their EU personal data to stay in the EU. For example, some of our customers in industries like healthcare, law, and finance may have additional requirements.  For that reason, we have developed an optional suite of services to address those requirements. We call this our Data Localisation Suite.

How the Data Localisation Suite helps today

Data Localisation is challenging for customers because of the volume and variety of data they handle. When it comes to their Cloudflare traffic, we’ve found that customers are primarily concerned about three areas:

  1. How do I ensure my encryption keys stay in the EU?
  2. How can I ensure that services like caching and WAF only run in the EU?
  3. How can ensure that metadata is never transferred outside the EU?

To address the first concern, Cloudflare has long offered Keyless SSL and Geo Key Manager, which ensure that private SSL/TLS key material never leaves the EU. Keyless SSL ensures that Cloudflare never has possession of the private key material at all; Geo Key Manager uses Keyless SSL under the hood to ensure the keys never leave the specified region.

Last year we addressed the second concern with Regional Services, which ensures that Cloudflare will only be able to decrypt and inspect the content of HTTP traffic inside the EU. In other words, SSL connections will only be terminated in Europe, and all of our layer 7 security and performance services will only run in our EU data centers.

Today, we’re enabling customers to address the third and final concern, and keep metadata local as well.

How the Metadata Boundary Works

The Customer Metadata Boundary ensures, simply, that end user traffic metadata that can identify a customer stays in the EU. This includes all the logs and analytics that a customer sees.

How are we able to do this? All the metadata that can identify a customer flows through a single service at our edge, before being forwarded to one of our core data centers.

When the Metadata Boundary is enabled for a customer, our edge ensures that any log message that identifies that customer (that is, contains that customer’s Account ID) is not sent outside the EU. It will only be sent to our core data center in the EU, and not our core data center in the US.

Introducing the Customer Metadata Boundary

What’s next

Today our Data Localisation Suite is focused on helping our customers in the EU localise data for their inbound HTTP traffic. This includes our Cache, Firewall, DDoS protection, and Bot Management products.

We’ve heard from customers that they want data localisation for more products and more regions. This means making all of our Data Localisation Products, including Geo Key Manager and Regional Services, work globally. We’re also working on expanding the Metadata Boundary to include our Zero Trust products like Cloudflare for Teams. Stay tuned!

New Standard Contractual Clauses now part of the AWS GDPR Data Processing Addendum for customers

Post Syndicated from Stéphane Ducable original https://aws.amazon.com/blogs/security/new-standard-contractual-clauses-now-part-of-the-aws-gdpr-data-processing-addendum-for-customers/

Today, we’re happy to announce an update to our online AWS GDPR Data Processing Addendum (AWS GDPR DPA) and our online Service Terms to include the new Standard Contractual Clauses (SCCs) that the European Commission (EC) adopted in June 2021. The EC-approved SCCs give our customers the ability to comply with the General Data Protection Regulation (GDPR) when they transfer personal data subject to GDPR to countries outside the European Economic Area (EEA) that haven’t received an EC adequacy decision (third countries). The new SCCs are now better adapted to how our customers operate their applications or run their workloads in the cloud, because they cover different transfer scenarios, and also provide enhanced safeguards for data transfers.

Achieving compliance with GDPR is critical for hundreds of thousands of AWS customers and AWS. The new SCCs allow all AWS customers that are controllers or processors under GDPR to continue to transfer personal data from their AWS accounts in compliance with GDPR. As part of the online Service Terms, the new SCCs will apply automatically whenever an AWS customer uses AWS services to transfer customer data to third countries.

The updated AWS GDPR DPA incorporating the new SCCs supplements our announcement in February 2021 of strengthened commitments to protect customer data, such as challenging law enforcement requests that conflict with EU law. We have also published the blog post How AWS is helping EU customers navigate the new normal for data protection, and the whitepaper Navigating Compliance with EU Data Transfer Requirements to help AWS customers conduct their data transfer assessments and comply with GDPR, the Schrems II ruling, and the recommendations issued by the European Data Protection Board. AWS is constantly working to ensure that our customers can enjoy the benefits of AWS everywhere they operate, and we welcome the new SCCs because they enable our customers to continue using AWS services in compliance with GDPR. If you have questions or need more information, visit our EU Data Protection page and our GDPR Center.

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Author

Stéphane Ducable

Stéphane is Vice President of Public Policy – EMEA at AWS. He is focused on increasing awareness of the benefits of adopting cloud computing technology across the EMEA region.

AWS IQ expansion: Connect with Experts and Consulting Firms based in the UK and France

Post Syndicated from Alex Casalboni original https://aws.amazon.com/blogs/aws/aws-iq-expansion-experts-uk-france/

AWS IQ launched in 2019 and has been helping customers worldwide engage thousands of AWS Certified third-party experts and consulting firms for on-demand project work. Whether you need to learn about AWS, plan your project, setup new services, migrate existing applications, or optimize your spend, AWS IQ connects you with experts and consulting firms who can help. You can share your project objectives with a description, receive responses within the AWS IQ application, approve permissions and budget, and will be charged directly through AWS billing.

Until yesterday, experts had to reside in the United States to offer their hands-on help on AWS IQ. Today, I’m happy to announce that AWS Certified experts and consulting firms based in the UK and France can participate in AWS IQ.

If you are an AWS customer based in the UK or France and need to connect with local AWS experts, now you can reach out to a wider pool of experts and consulting firms during European business hours. When creating a new project, you can now indicate a preferred expert location.

As an AWS Certified expert you can now view the buyer’s preferred expert location to ensure the right fit. AWS IQ simplifies finding relevant opportunities and it helps you access a customer’s AWS environment securely. It also takes care of billing so more time is spent on solving customer problems, instead of administrative tasks. Your payments will be disbursed by AWS Marketplace in USD towards a US bank account. If you don’t already have a US bank account, you may be able to obtain one through third-party services such as Hyperwallet.

AWS IQ User Interface Update
When you create a new project request, you can select a Preferred expert or firm location: Anywhere, France, UK, or US.

Check out Jeff Barr’s launch article to learn more about the full request creation process.

You can also work on the same project with multiple experts from different locations.

When browsing experts and firms, you will find their location under the company name and reviews.

Available Today
AWS IQ is available for customers anywhere in the world (except China) for all sorts of project work, delivered by AWS experts in the United States, the United Kingdom, and France. Get started by creating your project request on iq.aws.amazon.com. Here you can discover featured experts or browse experts for a specific service such as Amazon Elastic Compute Cloud (EC2) or DynamoDB.

If you’re interested in getting started as an expert, check out AWS IQ for Experts. Your profile will showcase your AWS Certifications as well as the ratings and reviews from completed projects.

I’m excited about the expansion of AWS IQ for experts based in the UK and France, and I’m looking forward to further expansions in the future.

Alex

How AWS is helping EU customers navigate the new normal for data protection

Post Syndicated from Stephen Schmidt original https://aws.amazon.com/blogs/security/how-aws-is-helping-eu-customers-navigate-the-new-normal-for-data-protection/

Achieving compliance with the European Union’s data protection regulations is critical for hundreds of thousands of Amazon Web Services (AWS) customers. Many of them are subject to the EU’s General Data Protection Regulation (GDPR), which ensures individuals’ fundamental right to privacy and the protection of personal data. In February, we announced strengthened commitments to protect customer data, such as challenging law enforcement requests for customer data that conflict with EU law.

Today, we’re excited to announce that we’ve launched two new online resources to help customers more easily complete data transfer assessments and comply with the GDPR, taking into account the European Data Protection Board (EDPB) recommendations. These resources will also assist AWS customers in other countries to understand whether their use of AWS services involves a data transfer.

Using AWS’s new “Privacy Features for AWS Services,” customers can determine whether their use of an individual AWS service involves the transfer of customer data (the personal data they’ve uploaded to their AWS account). Knowing this information enables customers to choose the right action for their applications, such as opting out of the data transfer or creating an appropriate disclosure of the transfer for end user transparency.

We’re also providing additional information on the processing activities and locations of the limited number of sub-processors that AWS engages to provide services that involve the processing of customer data. AWS engages three types of sub-processors:

  • Local AWS entities that provide the AWS infrastructure.
  • AWS entities that process customer data for specific AWS services.
  • Third parties that AWS contracts with to provide processing activities for specific AWS services.

The enhanced information available on our updated Sub-processors page enables customers to assess if a sub-processor is relevant to their use of AWS services and AWS Regions.

These new resources make it easier for AWS customers to conduct their data transfer assessments as set out in the EDPB recommendations and, as a result, comply with GDPR. After completing their data transfer assessments, customers will also be able to determine whether they need to implement supplemental measures in line with the EDPB’s recommendations.

These resources support our ongoing commitment to giving customers control over where their data is stored, how it’s stored, and who has access to it.

Since we opened our first region in the EU in 2007, customers have been able to choose to store customer data with AWS in the EU. Today, customers can store their data in our AWS Regions in France, Germany, Ireland, Italy, and Sweden, and we’re adding Spain in 2022. AWS will never transfer data outside a customer’s selected AWS Region without the customer’s agreement.

AWS customers control how their data is stored, and we have a variety of tools at their disposal to enhance security. For example, AWS CloudHSM and AWS Key Management Service (AWS KMS) allow customers to encrypt data in transit and at rest and securely generate and manage encryption keys that they control.

Finally, our customers control who can access their data. We never use customer data for marketing or advertising purposes. We also prohibit, and our systems are designed to prevent, remote access by AWS personnel to customer data for any purpose, including service maintenance, unless requested by a customer, required to prevent fraud and abuse, or to comply with the law.

As previously mentioned, we challenge law enforcement requests for customer data from governmental bodies, whether inside or outside the EU, where the request conflicts with EU law, is overbroad, or we otherwise have any appropriate grounds to do so.

Earning customer trust is the foundation of our business at AWS, and we know protecting customer data is key to achieving this. We also know that helping customers protect their data in a world with constantly changing regulations, technology, and risks takes teamwork. We would never expect our customers to go it alone.

As we continue to enhance the capabilities customers have at their fingertips, they can be confident that choosing AWS will ensure they have the tools necessary to help them meet the most stringent security, privacy, and compliance requirements.

If you have questions or need more information, visit our EU Data Protection page.

Want more AWS Security how-to content, news, and feature announcements? Follow us on Twitter.

Author

Steve Schmidt

Steve is Vice President and Chief Information Security Officer for AWS. His duties include leading product design, management, and engineering development efforts focused on bringing the competitive, economic, and security benefits of cloud computing to business and government customers. Prior to AWS, he had an extensive career at the Federal Bureau of Investigation, where he served as a senior executive and section chief. He currently holds 11 patents in the field of cloud security architecture. Follow Steve on Twitter.

Author

Donna Dodson

Donna is a Senior Principal Scientist at AWS focusing on security and privacy capabilities including cryptography, risk management, standards, and assessments. Before joining AWS, Donna was the Chief Cybersecurity Advisor at the National Institute of Standards and Technology (NIST). She led NIST’s comprehensive cybersecurity research and development to cultivate trust in technology for stakeholders nationally and internationally.

The UEFA EURO 2020 final as seen online by Cloudflare Radar

Post Syndicated from John Graham-Cumming original https://blog.cloudflare.com/the-uefa-euro-2020-final-as-seen-online-by-cloudflare-radar/

The UEFA EURO 2020 final as seen online by Cloudflare Radar

Last night’s Italy-England match was a nail-biter. 1-1 at full time, 1-1 at the end of extra time, and then an amazing penalty shootout with incredible goalkeeping by Pickford and Donnarumma.

Cloudflare has been publishing statistics about all the teams involved in EURO 2020 and traffic to betting websites, sports newspapers, streaming services and sponsors. Here’s a quick look at some specific highlights from England’s and Italy’s EURO 2020.

Two interesting peaks show up in UK visits to sports newspapers: the day after England-Germany and today after England’s defeat. Looks like fans are hungry for analysis and news beyond the goals. You can see all the data on the dedicated England EURO 2020 page on Cloudflare Radar.

The UEFA EURO 2020 final as seen online by Cloudflare Radar

But it was a quiet morning for the websites of the England team’s sponsors.

The UEFA EURO 2020 final as seen online by Cloudflare Radar

Turning to the winners, we can see that Italian readers are even more interested in knowing more about their team’s success.

The UEFA EURO 2020 final as seen online by Cloudflare Radar

And this enthusiasm spills over into visits to the Italian team’s sponsors.

The UEFA EURO 2020 final as seen online by Cloudflare Radar

You can follow along on the dedicated Cloudflare Radar page for Italy in EURO 2020.

Visit Cloudflare Radar for information on global Internet trends, trending domains, attacks and usage statistics.

C5 Type 2 attestation report now available with one new Region and 123 services in scope

Post Syndicated from Mercy Kanengoni original https://aws.amazon.com/blogs/security/c5-type-2-attestation-report-available-one-new-region-123-services-in-scope/

Amazon Web Services (AWS) is pleased to announce the issuance of the 2020 Cloud Computing Compliance Controls Catalogue (C5) Type 2 attestation report. We added one new AWS Region (Europe-Milan) and 21 additional services and service features to the scope of the 2020 report.

Germany’s national cybersecurity authority, Bundesamt für Sicherheit in der Informationstechnik (BSI), established C5 to define a reference standard for German cloud security requirements. Customers in Germany and other European countries can use AWS’s attestation report to help them meet local security requirements of the C5 framework.

The C5 Type 2 report covers the time period October 1, 2019, through September 30, 2020. It was issued by an independent third-party attestation organization and assesses the design and the operational effectiveness of AWS’s controls against C5’s basic and additional criteria. This attestation demonstrates our commitment to meet the security expectations for cloud service providers set by the BSI in Germany.

We continue to add new Regions and services to the C5 compliance scope so that you have more services to choose from that meet regulatory and compliance requirements. AWS has added the Europe (Milan) Region and the following 21 services and service features to this year’s C5 scope:

You can see a current list of the services in scope for C5 on the AWS Services in Scope by Compliance Program page. The C5 report and Continuing Operations Letter is available to AWS customers through AWS Artifact. For more information, see Cloud Computing Compliance Controls Catalogue (C5).

If you have feedback about this post, submit comments in the Comments section below.

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Author

Mercy Kanengoni

Mercy is a Security Audit Program Manager at AWS. She leads security audits across Europe, and she has previously worked in security assurance and technology risk management.