Welcome!

Microservices Expo Authors: Flint Brenton, AppDynamics Blog, Automic Blog, Sujoy Sen, Liz McMillan

Related Topics: @CloudExpo, Java IoT, Microservices Expo, Linux Containers, Cloud Security, @BigDataExpo

@CloudExpo: Article

Key Data Residency Requirements Global Organizations Need to Understand

…And some advice on how to satisfy them as you move to the cloud

One challenge more and more enterprises are grappling with as they plan to adopt the cloud is data residency & sovereignty. They are finding that if they want to use a cloud service hosted outside of their borders, life can become quite complex. Perhaps it is a result of the often discussed "Snowden Effect," but no one can deny that countries and regions are putting some strict guidelines in place to ensure privacy of sensitive data that is moving outside of their borders. These three examples are indicative of what I foresee we will be seeing much more of:

Australia: The Privacy Amendment Act
The Privacy Amendment Act introduced many changes to the original Privacy Act and just recently went into effect. The Act includes a set of new privacy principles that cover the processing of personal information by government agencies and businesses. The new principles are called jointly called the Australian Privacy Principles (APPs).

In the context of cloud adoption, agencies and businesses that deal with personal information are subject to APP8 (cross-border disclosure of personal information) which regulates the disclosure/transfer of personal information by an agency or business to a different entity (including a parent company) offshore. Before moving this type of data offshore, the Australian agency/business (Australian sender) must take reasonable steps to ensure the overseas recipient will comply with / not breach the APPs. The Australian Sender will remain liable for the overseas recipient's acts associated with any transferred personal information and, where relevant, be in breach of the APPs due to the overseas recipient's acts or omissions. In addition, APP11.1 (security of personal information) requires that an organization must "take reasonable steps to protect the personal information it holds from misuse".

Germany: The Federal Data Protection Act
Germany's Federal Data Protection Act is known as Bundesdatenschutzgesetz or BDSG, and these laws were reformed to cover a range of data protection-related issues. The key principles of the law state that organizations cannot collect any personally identifiable information without express permission from an individual (this includes obvious things like name and date of birth, as well as less obvious things like phone number, address and computer IP address). The permission that an individual grants must specify how, where, how long and for what purposes the data may be used and the individual can revoke the permission at any time.

Organizations must have policies, procedures and controls in place to protect all data types and categories that fall under the BDSG umbrella. Further, Germany does not recognize Safe Harbor regulations in the same way as other EU states (note - other EU states are re-examining this issue). It requires all parties involved in data transfer to assure that Safe Harbor requirements are met in a more formalized and structured manner.

In addition to the Federal Data Protection Act, components of the German criminal code regulate personal data protection, particularly for telecommunications, healthcare, and insurance companies. And all of the 16 German states have their own specific data protection laws pertaining to these areas.

United Kingdom: The UK Data Protection Act
The UK Data Protection Act is the UK's legislation covering the processing of data on people and is the main piece of legislation that governs the protection of personal data in the UK. The Act places clear demands upon those holding personal data in terms of the security that must be applied to protect it and it is necessary to apply a wide range of security measures to meet these standards:

  • Data must be processed fairly and lawfully
  • Data must be processed in accordance with the rights and freedoms of data subjects
  • Data must be protected against unauthorized or unlawful processing and against accidental loss, destruction or damage
  • Data must not be transferred to a country or territory outside the European Economic Area unless that country or territory protects the rights and freedoms of the data subjects.

The Information Commissioner's Office (ICO) is the UK's independent authority set up to uphold information rights in the public interest. They recently provided guidance around the use of cloud computing reiterating that the responsibility for data protection remains with the data controller (the enterprise). And particular consideration should be given to mitigating the security risks relating to personal data since foreign law enforcement agencies may have the power to demand access to personal data stored in a foreign data center. Failing to protect private data can result in ICO-levied fines.

What is an organization to do? Look exclusively at cloud solutions that are based wholly in the country where they operate? Avoid cloud services altogether? Both of these approaches are impractical. Enterprises need to adopt cloud-based solutions, the best ones available irrespective of location, in order to drive their businesses and remain competitive. So what to do? Technology in the form of Cloud Data Control Gateways (CDCGs) using a technique called tokenization can help.

CDCGs are increasingly being used by global organizations to meet data residency requirements. Using tokenization, where clear text data is replaced by a surrogate token (check out a cool infographic describing the technique here), sensitive data can remain physically onsite while only surrogate replacement tokens go to the cloud for processing and storage. This solution enables enterprises to use public cloud applications no matter where they are located because actual data never needs to leave their in-country data center where the tokenization process occurs. It is a simple and straightforward way to adhere to complex data residency/sovereignty requirements. For those concerned about the "Snowden Effect," the reality is that any requests for information through one of their US-based cloud providers cannot result in compromising customer or corporate data without the enterprise being part of the conversation.

Of course, not all tokenization technologies are created equal. This solution only works when it is designed and deployed properly so as to fulfill all data obfuscation goals and objectives. Most important, it needs to be part of a gateway approach that ensures that the functionality of the cloud application is not disrupted for cloud end users. For example, users need to be able to use the cloud as if the gateway was not in the middle of the equation at all (e.g., they need to be able to Search or Sort on data that has been tokenized).

Please check out our website, which offers more insights on data sovereignty and tokenization with specific pages addressing laws in a number of countries as well as sector-based requirements for verticals like Banking and Healthcare. We also provide various reference pieces, including a broader whitepaper, International Privacy Laws.

Read the original blog entry...


Perspecsys Inc. is a leading provider of cloud data tokenization and cloud encryption solutions that enable mission-critical cloud applications to be adopted throughout the enterprise. Cloud security companies like Perspecsys remove the technical, legal and financial risks of placing sensitive company data in the cloud. Perspecsys accomplishes this for many large, heavily regulated companies across the world by never allowing sensitive data to leave a customer's network, while maintaining the functionality of cloud applications. For more information please visit perspecsys.com or follow on Twitter @perspecsys.

More Stories By Gerry Grealish

Gerry Grealish is Vice President, Marketing & Products, at PerspecSys. He is responsible for defining and executing PerspecSys’ marketing vision and driving revenue growth through strategic market expansion and new product development. Previously, he ran Product Marketing for the TNS Payments Division, helping create the marketing and product strategy for its cloud-based payment gateway and tokenization/encryption security solutions. He has held senior marketing and leadership roles for venture-backed startups as well as F500 companies, and his industry experience includes enterprise analytical software, payment processing and security services, and marketing and credit risk decisioning platforms.

Comments (0)

Share your thoughts on this story.

Add your comment
You must be signed in to add a comment. Sign-in | Register

In accordance with our Comment Policy, we encourage comments that are on topic, relevant and to-the-point. We will remove comments that include profanity, personal attacks, racial slurs, threats of violence, or other inappropriate material that violates our Terms and Conditions, and will block users who make repeated violations. We ask all readers to expect diversity of opinion and to treat one another with dignity and respect.


@MicroservicesExpo Stories
As the software delivery industry continues to evolve and mature, the challenge of managing the growing list of the tools and processes becomes more daunting every day. Today, Application Lifecycle Management (ALM) platforms are proving most valuable by providing the governance, management and coordination for every stage of development, deployment and release. Recently, I spoke with Madison Moore at SD Times about the changing market and where ALM is headed.
In a crowded world of popular computer languages, platforms and ecosystems, Node.js is one of the hottest. According to w3techs.com, Node.js usage has gone up 241 percent in the last year alone. Retailers have taken notice and are implementing it on many levels. I am going to share the basics of Node.js, and discuss why retailers are using it to reduce page load times and improve server efficiency. I’ll talk about similar developments such as Docker and microservices, and look at several compani...
From the conception of Docker containers to the unfolding microservices revolution we see today, here is a brief history of what I like to call 'containerology'. In 2013, we were solidly in the monolithic application era. I had noticed that a growing amount of effort was going into deploying and configuring applications. As applications had grown in complexity and interdependency over the years, the effort to install and configure them was becoming significant. But the road did not end with a ...
The goal of any tech business worth its salt is to provide the best product or service to its clients in the most efficient and cost-effective way possible. This is just as true in the development of software products as it is in other product design services. Microservices, an app architecture style that leans mostly on independent, self-contained programs, are quickly becoming the new norm, so to speak. With this change comes a declining reliance on older SOAs like COBRA, a push toward more s...
Small teams are more effective. The general agreement is that anything from 5 to 12 is the 'right' small. But of course small teams will also have 'small' throughput - relatively speaking. So if your demand is X and the throughput of a small team is X/10, you probably need 10 teams to meet that demand. But more teams also mean more effort to coordinate and align their efforts in the same direction. So, the challenge is how to harness the power of small teams and yet orchestrate multiples of them...
Many private cloud projects were built to deliver self-service access to development and test resources. While those clouds delivered faster access to resources, they lacked visibility, control and security needed for production deployments. In their session at 18th Cloud Expo, Steve Anderson, Product Manager at BMC Software, and Rick Lefort, Principal Technical Marketing Consultant at BMC Software, will discuss how a cloud designed for production operations not only helps accelerate developer...
SYS-CON Events announced today that Peak 10, Inc., a national IT infrastructure and cloud services provider, will exhibit at SYS-CON's 18th International Cloud Expo®, which will take place on June 7-9, 2016, at the Javits Center in New York City, NY. Peak 10 provides reliable, tailored data center and network services, cloud and managed services. Its solutions are designed to scale and adapt to customers’ changing business needs, enabling them to lower costs, improve performance and focus inter...
Much of the value of DevOps comes from a (renewed) focus on measurement, sharing, and continuous feedback loops. In increasingly complex DevOps workflows and environments, and especially in larger, regulated, or more crystallized organizations, these core concepts become even more critical. In his session at @DevOpsSummit at 18th Cloud Expo, Andi Mann, Chief Technology Advocate at Splunk, will show how, by focusing on 'metrics that matter,' you can provide objective, transparent, and meaningfu...
In the world of DevOps there are ‘known good practices’ – aka ‘patterns’ – and ‘known bad practices’ – aka ‘anti-patterns.' Many of these patterns and anti-patterns have been developed from real world experience, especially by the early adopters of DevOps theory; but many are more feasible in theory than in practice, especially for more recent entrants to the DevOps scene. In this power panel at @DevOpsSummit at 18th Cloud Expo, moderated by DevOps Conference Chair Andi Mann, panelists will dis...
Wow, if you ever wanted to learn about Rugged DevOps (some call it DevSecOps), sit down for a spell with Shannon Lietz, Ian Allison and Scott Kennedy from Intuit. We discussed a number of important topics including internal war games, culture hacking, gamification of Rugged DevOps and starting as a small team. There are 100 gold nuggets in this conversation for novices and experts alike.
The notion of customer journeys, of course, are central to the digital marketer’s playbook. Clearly, enterprises should focus their digital efforts on such journeys, as they represent customer interactions over time. But making customer journeys the centerpiece of the enterprise architecture, however, leaves more questions than answers. The challenge arises when EAs consider the context of the customer journey in the overall architecture as well as the architectural elements that make up each...
In 2006, Martin Fowler posted his now famous essay on Continuous Integration. Looking back, what seemed revolutionary, radical or just plain crazy is now common, pedestrian and "just what you do." I love it. Back then, building and releasing software was a real pain. Integration was something you did at the end, after code complete, and we didn't know how long it would take. Some people may recall how we, as an industry, spent a massive amount of time integrating code from one team with another...
Admittedly, two years ago I was a bulk contributor to the DevOps noise with conversations rooted in the movement around culture, principles, and goals. And while all of these elements of DevOps environments are important, I’ve found that the biggest challenge now is a lack of understanding as to why DevOps is beneficial. It’s getting the wheels going, or just taking the next step. The best way to start on the road to change is to take a look at the companies that have already made great headway ...
Struggling to keep up with increasing application demand? Learn how Platform as a Service (PaaS) can streamline application development processes and make resource management easy.
If there is anything we have learned by now, is that every business paves their own unique path for releasing software- every pipeline, implementation and practices are a bit different, and DevOps comes in all shapes and sizes. Software delivery practices are often comprised of set of several complementing (or even competing) methodologies – such as leveraging Agile, DevOps and even a mix of ITIL, to create the combination that’s most suitable for your organization and that maximize your busines...
Digital means customer preferences and behavior are driving enterprise technology decisions to be sure, but let’s not forget our employees. After all, when we say customer, we mean customer writ large, including partners, supply chain participants, and yes, those salaried denizens whose daily labor forms the cornerstone of the enterprise. While your customers bask in the warm rays of your digital efforts, are your employees toiling away in the dark recesses of your enterprise, pecking data into...
I have an article in the recently released “DZone Guide to Building and Deploying Applications on the Cloud” entitled “Fullstack Engineering in the Age of Hybrid Cloud”. In this article I discuss the need and skills of a Fullstack Engineer with relation to troubleshooting and repairing complex, distributed hybrid cloud applications. My recent experiences with troubleshooting issues with my Docker WordPress container only reinforce the details I wrote about in this piece. Without my comprehensive...
You deployed your app with the Bluemix PaaS and it's gaining some serious traction, so it's time to make some tweaks. Did you design your application in a way that it can scale in the cloud? Were you even thinking about the cloud when you built the app? If not, chances are your app is going to break. Check out this webcast to learn various techniques for designing applications that will scale successfully in Bluemix, for the confidence you need to take your apps to the next level and beyond.
With DevOps becoming more well-known and established practice in nearly every industry that delivers software, it is important to continually reassess its efficacy. This week’s top 10 includes a discussion on how the quick uptake of DevOps adoption in the enterprise has posed some serious challenges. Additionally, organizations who have taken the DevOps plunge must find ways to find, hire and keep their DevOps talent in order to keep the machine running smoothly.
Much of the discussion around cloud DevOps focuses on the speed with which companies need to get new code into production. This focus is important – because in an increasingly digital marketplace, new code enables new value propositions. New code is also often essential for maintaining competitive parity with market innovators. But new code doesn’t just have to deliver the functionality the business requires. It also has to behave well because the behavior of code in the cloud affects performan...