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The Exciting and Wonderful World of The Exciting and Wonderful World of . Data Protection Important Information for Anyone Working with Personal Data at Munich International School 1 A Super Short History of Data Protection in Germany • 1977 – First Federal Data Protection Act in Germany • 1983 – Judgment in a case involving the 1980 Census: Right to informational self-determination. • 2018 –The EU General Data Protection regulation (GDPR) directly applicable in all EU Member States. 2 Why Should We Care About Data Protection? • Strict Laws • Serious Attitude About Personal Data • Consequences • Individual Responsibility 3 Advantages of efficient Data Protection • Competitive advantages The organization will win the confidence of staff members, students, parents and business partners through the responsible handling of their data. • Protection from significant financial risks Disruption in business continuity cost money! e.g. data-loss, sabotage, unauthorized access. • Avoid Remedies and sanctions The remedies and sanctions available to DPAs under the GDPR are significantly greater. In particular, the GDPR allows DPAs to issue fines for serious infringements up to a maximum of the greater of €20 million or four percent of worldwide turnover. 4 Where do the laws and guidelines come from? 1.) The EU General Data Protection regulation (GDPR) The GDPR will be directly applicable in all EU Member States from May 25, 2018. Although a key aim of the GDPR is to harmonise data protection law across the EU, there are a number of areas in which the GDPR leaves it to Member States to adopt their own national rules. 3.) German Federal Government On 25 May 2018 not only the EU General Data Protection Regulation (GDPR), but also the new German Privacy Act (BDSG-new) apply. The BDSG-new complements, specifies and modifies the GDPR. It provides rules for specific topics, e.g. for data processing in the context of employment, the designation of a data protection officer (DPO), scoring and credit checks as well as profiling. 5 Future laws ? The ePrivacy Regulation The European Commission has made a proposal for a new ePrivacy law, this proposal will not take effect in 2018. It is expected to be adopted in the later part of 2019. The purpose is to regulate how to handle the processing of electronic communications data as well as the use of cookies and other similar technologies. This proposal is not just about cookies as it covers all technologies used in the processing of data, whether personal or not. Also – at this stage – this is a proposal and one that has to go through the Brussels legislative process and until then we won’t know exactly what it will state. 6 Personal data Personal data is any information that relates to an identified or identifiable living individual. Different pieces of information, which collected together can lead to the identification of a particular person, also constitute personal data. Examples of personal data a name and surname; a home address; an email address; a cookie ID;… The GDPR applies to both electronic records and structured hard copy records. Data about organizations and corporations is not covered. Anonymised Data are not considered personal data. 7 Sensitive Personal Data Sensitive Personal Data are special categories of personal data that are subject to additional protections. In general, organizations require stronger grounds to process Sensitive Personal Data than they require to process "regular" personal data Examples of Sensitive Personal Data Sensitive Personal Data" are personal data, revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership; data concerning health or sex life and sexual orientation; genetic data or biometric data. While it has not yet been fully established by law, students’ academic performance and special learning needs may well qualify as “sensitive personal data”. 8 Some definition: Third party and processors “third party” means: a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data; “processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller; 9 Anonymous versus Pseudonymous Data Anonymous data Some sets of data can be amended in such a way that no individuals can be identified from those data (whether directly or indirectly) by any means or by any person. Ensuring that there is no way in which individuals can be identified is a technically complex task. Pseudonymous data Some sets of data can be amended in such a way that no individuals can be identified from those data (whether directly or indirectly) without a "key" that allows the data to be re-identified. A good example of pseudonymous data is coded data sets used in clinical trials. 10 The 7 GDPR personal data processing principles view source: Serve IT it. 11 EU 7 Basic Principles of Data Protection #1. Fair, lawful and transparent processing (art. 5(1)(a)) Personal data must be processed lawfully, fairly and in a transparent manner in relation to the data subject. The requirement to process personal data fairly and lawfully is extensive. Lawfulness needs to be interpreted strictly: there must be a law allowing the processing. 12 EU 7 Basic Principles of Data Protection #2. The purpose limitation principle (art. 5(1)(b) Personal data may be collected only for specified, explicit and legitimate purposes and must not be further processed in a manner that is incompatible with those purposes. In summary, the purpose limitation principle states that personal data collected for one purpose should not be used for a new, incompatible, purpose than those mentioned to the data subject at the time of collection. A specified, explicit and legitimate purpose doesn’t just mean that there must be a purpose, it also literally means that the purpose needs to be limited. 13 EU 7 Basic Principles of Data Protection #3. Data minimisation (art. 5(1)(c)) Personal data must be adequate, relevant and limited to what is necessary in relation to the purposes for which those data are processed. The principle of data minimization is essentially the idea that, subject to limited exceptions, an organization should process only the personal data that it actually needs to process in order to achieve its defined purposes. 14 EU 7 Basic Principles of Data Protection #4. Accuracy (art. 5(1)(d)) Personal data must be accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that are inaccurate are either erased or rectified without delay. 15 EU 7 Basic Principles of Data Protection #5. Data retention periods (art. 5(1)(e)) Personal data must be kept in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed. In general the rule is: data that is no longer essential for achieving the original purpose for which the data was collected must be deleted. 16 EU 7 Basic Principles of Data Protection #6. Data security (integrity and confidentiality) (art. 5(1)(f)) Personal data must be processed in a manner that ensures appropriate security of those data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures. Controllers are responsible for ensuring that personal data are kept secure, both against external threats (e.g., malicious hackers) and internal threats (e.g., poorly trained employees). 17 EU 7 Basic Principles of Data Protection #7. Accountability (art. 5(2)) In order to be able to demonstrate compliance with this Regulation, the DPO should implement technical and organisational measures, at the earliest stages of the design of the processing operations, in such a way that safeguards privacy and data protection principles right from the start (‘data protection by design’). By default, companies/organisations should ensure that personal data is processed with the highest privacy protection (for example, only the data necessary should be processed, short storage period, limited accessibility) so that by default personal data isn’t made accessible to an indefinite number of persons (‘data protection by default’). 18 Guaranteeing the rights of the data subject • Transparent information and communication • Information obligations: Data subjects have the right to be provided with information on the identity of the controller, the reasons for processing their personal data and other relevant information. • Rights of access: In order to allow data subjects to enforce their data protection rights, EU data protection law obliges controllers to provide data subjects with access to their personal data. • Rectification and erasure ("Right to be forgotten") free of charge • Right to restriction of processing • Notification obligation vis-à-vis third parties regarding rectification, erasure or restriction. The data subject is also entitled to request information about the identities of those third parties. • Right to data portability (e.g., to move account details from one online platform to another). • Right to object, where the lawful basis is either "public interest" or "legitimate interests", data subjects may have a right to object to such processing. 19 GDPR Lawfulness processing. Source : https://www.i-scoop.eu/gdpr/consent-gdpr/ 20 Consent is one of the six legal grounds for lawful processing Consent of the data subject means: "any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her“ To the extent that MIS relies on consent as the lawful basis for any of its processing activities, MIS should ensure that data subjects are provided with a clear explanation of the processing to which they are consenting.
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