Privacy and Its Relation To Cloud Based Information Systems
Privacy and Its Relation To Cloud Based Information Systems
information systems:
Customer information may be "user data" or "personal data." User data is information collected from a
customer, including:
Any data that is collected directly from a customer; e.g., entered by the customer via an
application's user interface
Any data about a customer that is gathered indirectly; e.g., metadata in documents
Any data about a customer's usage behavior; e.g., logs or history
Any data relating to a customer's system; e.g., system configuration, IP address
Personal data, sometimes also called PII, is any piece of data that can potentially be used to uniquely
identify, contact, or locate a single person or can be used with other sources to uniquely identify a single
individual. Not all customer/user data collected by a company is personal data. Examples of personal
data include:
The Federal Trade Commission is educating consumers and businesses about the importance of
personal information privacy, including the security of personal information. Under the FTC Act, the
Commission guards against unfairness and deception by enforcing companies' privacy promises about
how they collect, use, and secure consumers' personal information.
The FTC publishes a guide that is a great educational tool for consumers and businesses alike, titled
"Protecting Personal Information: A Guide for Business." In general, the basics for protecting data privacy
are as follows, whether in a virtualized environment, the cloud, or on a static machine:
Collection: You should have a valid business purpose for developing applications and
implementing systems that collect, use or transmit personal data.
Notice: There should be a clear statement to the data owner of a company's or provider's
intended collection, use, retention, disclosure, transfer, and protection of personal data.
Choice and consent: The data owner must provide clear and unambiguous consent to the
collection, use, retention, disclosure, and protection of personal data.
Use: Once it is collected, personal data must only be used, including transfers to third parties, in
accordance with the valid business purpose and as stated in the Notice.
Security: Appropriate security measures must be in place; e.g., encryption, to ensure the
confidentiality, integrity, and authentication of personal data during transfer, storage, and use.
Access: Personal data must be available to the owner for review and update. Access to personal
data must be restricted to relevant and authorized personnel.
Retention: A process must be in place to ensure that personal data is only retained for the period
necessary to accomplish the intended business purpose or that which is required by law.
Disposal: The personal data must be disposed of in a secure and appropriate manner; i.e., using
encryption disk erasure or paper shredders.