With both PGP and S/MIME one has to acquire the public key of the recipient and ensure that this key belongs to the user. So, what does the GDPR say exactly? Just as I mentioned before in the post about the c ommon mistakes in email marketing, you don’t send the same birthday wishes to your boss, grandma, best friend and your boyfriend – and you should not send the same re-permissioning email … The regulation governs the processing and storage of EU citizens' data whether or not the company has operations in the EU. You'll miss out on some important background information, though. Not only the type of data is relevant but the GDPR also talks about something called vulnerable data subjects which warrant additional protection. Security can be further enhanced with two factor authentication such as SMS or an app, User has to log in to a portal to view or respond, Very safe, provided the certificates/public keys are verified, Quite safe, as long as the password is long and complex and the password is, Works for pretty much everyone: ZIP files can be opened on all Operating Systems out there, Best used for sending bulk personal data (when a portal is not available), Requires user interaction for both the sender and the receiver, Requires the use of a second channel (phone/SMS), Not very practical when sending personal data multiple times a day, Once configured by the mail administrator, users don't have to take any special steps, it "just works", STARTTLS helps both with encrypting incoming and outgoing emails, Most domains have STARTTLS enabled (90%) but some do not. The German BfDI seems to have no page at all regarding personal data via email. ‘Personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data… Companies who can be fined up to €20 million or 4% of their annual turnover should take this stuff seriously and follow the ICO’s advice. There's a risk that a connection is actively intercepted and rewritten to disable STARTTLS. I am also not an expert on GDPR. I have recently questioned this and have not really got a satisfactory response. You should therefore do an audit of the devices and software you use to make sure that other people’s personal data is protected. While not explicitly listed by the Dutch DPA as an alternative to email, this method is in use by the Dutch Government for "MijnOverheid" (MyGovernment) for electronic communication with its citizens. Robert is often required to email sensitive data. Covering key dos and don’ts for email marketing, these simple rules will help you along the way to ensuring your processes are GDPR-proof, for when the 25 May finally arrives… Do’s and don’ts With effective targeting your reasons for … This article starts with quoting what the Europen General Data Protection Regulation (GDPR) says about securing personal data. As mentioned at the beginning of the article, email is "by default" transmitted via plaintext, that is: unencrypted over the wire. It’s still possible to send email with GDPR but there are some practices to keep in mind. Unfortunately, on Windows, in order to create a password protected .ZIP file you will have to install additional (free) software such as 7Zip. Additional countermeasures are therefore required: I would recommend NOT to send sensitive personal data over ordinary email. This blog features various cyber security topics. The GDPR has created new rights of access and data protection for “data subjects”: 1. You should also audit your data to make sure that you are only holding data that is necessary for your jobs, or that you are legally required to hold, eg for tax purposes. In other words: you don't have to spend millions of euros on some obscure and unbreakable solution. One of those regulations is the GDPR. This option does not eliminate all threats. info@company.com) that is not personal data. Before you deploy DANE, you should ensure that you use a real and proper SSL certificate on the mail server. 3. If you become aware of a data-leak. If you're collecting personal data (i.e. Contact the GDPR manager at once. ... as acting outside of their employer’s instructions and the transfer of the customer list to the employee’s personal email is considered a personal data breach. The Group sub-contracts some of its personal data processing to external data processors. On pretty much every OS you can open password protected .ZIP files. Three decades of history says this isn’t going to happen soon, if at all. encrypted or hashed) personal data. Personal data that has been de-identified, encrypted or pseudonymised but can be used to re-identify a person remains personal data and falls within the scope of the GDPR. G Suite and Google Cloud Platform (GCP) services. I have tried uploading these documents to my Google Drive account and giving them a link, though I don’t really know whether this method is any safer. Personal data is any information that can be used to identify a living person, including names, delivery details, IP addresses, or HR data such as payroll details. Such an inbox is often combined with email notification: when there's a new message the user receives an email. All processing of personal data in the EU must conform to the principles of the GDPR. If there’s no other alternative, you should encrypt and password-protect your images and documents before sending them as email attachments. The ICO (Information Commissioner’s Office) recently issued a fine of £200,000 to the Independent Inquiry into Child Sexual Abuse for incorrectly sending a bulk email to 90 recipients rather than Bcc’ing (blind carbon copy) them in. Encrypt your documents before you upload them. Sometimes another organization needs a bulk upload of personal data. The most common categories you may encounter are children and employees. We advise removing from your lists the data of prospects who have not replied within 30 days from sending them your first message. You have to export the email if you want to keep a copy. 2) You are sending personal data (or making it accessible) to a receiver to which the GDPR does not apply. Explain Your Legitimate Interest In Your Email Copy. It includes online identifiers (such as IP addresses and other unique online or device IDs), identification numbers and location data, as well as pseudonymised (e.g. So many people are getting in hot water for this one! Section 2 of the GDPR talks about the Security of personal data. These problems are the reason many organisations still use fax machines. Normally it can be resolved by contacting the person you wrote to by mistake, and get in writing that they have deleted it without doing anything with it. The European Union’s General Data Protection Regulation (GDPR), which comes into force on May 25, will govern the storage and processing of data rather than its collection. No one has mentioned encrypted email? GDPR will apply to how personal data, including email addresses, is processed, while PECR gives further guidance on how that data can be used for electronic and telephone marketing purposes. Sending transactional emails is an act of data processing - you have your customer's personal data (their name and email address, at the very least), and you're using it to communicate with them. So let us set the record straight when it comes to sending emails. Sub-contractors. 5 … In simple terms, this includes an individual’s name, address, email address, mobile numbers, age, dates of birth, criminal convictions, medical information, etc. These are set out at Art. GDPR applies to companies and organisations, particularly those with more than 250 employees. For guidance on what constitutes personal data, see: GDPR: How the definition of personal data has changed . It also includes some very important consumer rights. All processing of personal data in the EU must conform to the principles of the GDPR . While STARTTLS gives the ability to encrypt email in transit, it does NOT enforce it. Personal data breach is defined in Art. GDPR compliance is not an option ... make it clear how you obtained their personal data (in email campaign tools such as MailChimp, this is referred to as your List Description) and how they can easily opt out of receiving future marketing emails (e.g. 2) You are sending personal data (or making it accessible) to a receiver to which the GDPR does not apply. If you routinely send or process large amounts of data, in particular large amounts of sensitive data or of vulnerable data subjects then you may even be required to do something called a Data Protection Impact Assessment, also called DPIA. Under GDPR, people have a better knowledge of what data is being collected and how their personal data is being stored. Ordinary basic personal data, such as name and address require less protection than sensitive personal data, which includes things such as medical data, religion, grades at school, and basically anything else that could potentially seriously harm someone if exposed. What does it have to do with emails, specifically, attachments? In short, PECR states that you must not send electronic mail marketing to individuals unless: However, if a customer refuses or withdraws their consent, the credit card company will still send the data to the credit reference agencies on the basis of ‘legitimate interests’. You’ll be pleased to know that there is nothing in the GDPR that specifically prohibits you sending personal data by email, yet it is highly recommended you take steps to protect the data you’re sending in order to avoid a costly breach. Sending Sensitive Data to the Wrong Recipient. More recently, the GDPR keeps him busy. A more likely problem is sending emails to the wrong address, either because users have got their own email addresses wrong (this happens surprisingly often), or through human error. This is another option that the Dutch authorities suggest. If, like most people, you haven't set it up before then it can be a bit challenging. GDPR - The Problem of Personal Data in Email an Backups Tuesday, May 29, 2018 by Michael Nuncic With GDPR just a couple of days away, many companies are in their final stages of getting their IT processes and the needed solutions ready to comply with the new regulations. Many email servers nowadays advertise and use STARTTLS. So, if your SMTP server is mail.example.org then the SSL certificate should also be for mail.example.org and it should be issued by a trusted authority. Home and household users are exempt. [..]. For guidance on what constitutes personal data, see: GDPR: How the definition of personal data has changed. In such a case, when you have for example an excel sheet with personal data of tens or hundreds of persons, you can put the document in a password-protected ZIP file and mail it to the recipient. However, as a freelancer, you store and process data, even if the “processing” just means entering a name in an address book and looking it up. They also help by explaining the rules and handing out guidelines. If a portal is available, it should be employed. They depend on a number of factors, as discussed next. Is it acceptable if certain technical measures are taken? This can be changed, however. Encryption protects data if an online storage service is compromised – it has happened – or if your email is hacked. If an encrypted connection cannot be established, the sender must not fallback to unencrypted but must wait and retry later. (b) the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services; Again, the latter requires more protection. The simple answer is that individuals’ work email addresses are personal data. Instead, have a customer portal where the user logs in with his/her account details over a secure connection. GDPR also refined and enshrined in law the concept of the "right to be forgotten", renaming it as the "right to erasure", and gave EU citizens the right to data portability, allowing them to take data from one organisation and give it to another. Email retention under GDPR What the GDPR says: Data erasure is a large part of the GDPR. This is because holding personal data longer than necessary will breach the GDPR. The right to object to marketing is absolute and you must stop processing for these purposes when someone objects. From there they have 72 hours to resolve the situation. What is GDPR? It would obviously be good thing if all emails were encrypted by default so that only the intended recipient could read them. Consent for Sending Marketing Material. The content of the message is not shown in the email, only the fact that there's a new message. Tutanota users get an email that says “you have an encrypted email” and you click a link to read it, and reply to it, in a browser. The goal of the GDPR is to protect the personal data of EU citizens. We all need to be mindful when sharing personal information, whether it is our own or that of others. I suggest you follow a DANE tutorial online and monitor the server closely after deployment for any issues. Right to portability:The data subject may request that their personal data be sent to another organization or competitor. By necessity the TO, FROM, DATE and SUBJECT fields of an email are transmitted in plain text and may be accessed by any unintended recipient or third-party who intercepts the communication. GDPR personal data is a broad category. “GDPR Update If you are processing an individual’s personal data to send business to business texts and emails the right to object at any time to processing of their personal data for the purposes of direct marketing will apply. Encryption is a key data protection component of the GDPR. GDPR does not specify any particular period of time. These reports are uploaded to Iris Openspace. It is one of the six data protection principles: Article 5(e) states that personal data can be stored for “no longer than is necessary for the purposes for which the personal data are processed.” 4. This new regulation offers individuals in the EU greater transparency and control over how their personal data is used and make companies handling personal data accountable for their choices. Once you have STARTTLS and DANE employed then conforming servers will deliver emails to you in encrypted form. This is where DANE comes into play. GDPR – Think twice before sending a re-permissioning email campaign. This article contains affiliate links, which means we may earn a small commission if a reader clicks through and Sending personal data over email will always be a challenge due to the insecure nature of email. So, what does the GDPR say about sending personal data over email? A company that provides credit cards asks its customers to give consent for their personal data to be sent to credit reference agencies for credit scoring. Any information that could be used to personally identify your EU leads falls under GDPR protection, such as names, contact numbers, addresses, email addresses, IP addresses, mobile device IDs and so on. These are persons where there is a power imbalance between the data subject and the data controller. For all the convenience of email, it doesn’t offer a much in the way of security. Unfortunately, it is less suitable to ordinary users. If you are able to identify an individual either directly or indirectly (even in a professional capacity), then GDPR will apply. This is one of the suggestions by the Dutch authorities and the UK ICO. Then on to the technical measures: the Data Protection Authorities give concrete hands-on tips and we will go through four of these that can be implemented to adequately secure the communication of personal data. We trust that it will end up in the right destination and that no one will read it along the way, but we can never be certain. Sensitive personal data is also covered in GDPR as special categories of personal data. Royal Mail Group has internal data retention policies which cover the requirements for data retention and secure disposal/destruction of information waste in compliance with the Group’s legal and regulatory obligations. Normally it can be resolved by contacting the person you wrote to by mistake, and get in writing that they have deleted it without doing anything with it. In another post, the aforementioned Liz Henderson explains how to create a GDPR Privacy Notice, and you could adapt her sample to cover Gmail storage outside the EU. Unfortunately, using Google Drive brings up an extra complication. GDPR does not oblige users to store data on servers inside the EU. Additionally, a self-service option allows payroll bureaus to keep their data updated and accurate as employees can edit their contact information. However, if it is a general business email address (e.g. The GDPR is only one of the six lawful bases for processing personal data provided by the GDPR. Ensure traffic between email servers is encrypted by using modern internet standards. Fortunately, the Dutch Data Protection Authority is more concrete and gives two examples on how to safely send personal data using email: Let's go through the various options, in order of preference. You have to remember, though, that sending your email campaigns, doing marketing, running a business you probably process personal data. Because this method is unsuitable for inexperienced users and unsuitable for mass communication I am not going to elaborate further on this. The most important are the right to be informed, the right of access, the right to correct errors, the right to erase data, […] If you have a secure customer portal, however, it is the safest option available which any (inexperienced) user can easily use. Consent. The UK ICO page on email mainly lists the problems that are related to the email but is less focused on solutions. We then talk about the difference between ordinary personal data and sensitive personal data and how it affects the security requirements. GDPR Compliant Email. Google (including Gmail) publishes statistics showing that 90% of all incoming and outgoing emails are encrypted in transit using STARTTLS. So, do you need to obtain consent for business-to-business marketing? If you are sending emails with personally identifiable information (PII) (here’s the ICO’s guide on what actually counts as personal data.) Indeed, you should do those things even if the GDPR didn’t exist. Only after logging in to the portal the user can read the message content. 3) The receiver is a separate o… One of the goals when writing the GDPR was to make it more or less timeless: updates to the regulation and the law should not be necessary each It provides end-to-end encryption and when operated correctly it is really secure. Experts often compare sending emails to posting letters: you compose a message and a delivery address, and then hand it off to someone else to deliver. However, you also have to send external recipients a password – for example, in an SMS text message – to decrypt the email. Bear in mind that GDPR is a legal matter and I am not a lawyer. Emails are more like plain text postcards because they can, in theory, be read at any of the many servers through which they pass, or by someone tapping a line. It tells the sending email server (or client) that the connection can be upgraded to a secure connection with TLS, the same technology that protects HTTPS sites. The special categories specifically include: genetic data relating to the inherited or acquired genetic characteristics which give unique information about a person’s physiology or the health of that natural person ‘Personal data’ and ‘sensitive personal data’ are defined in the regulations. Have you got a question? All our journalism is independent and is in no way influenced by any advertiser or commercial initiative. If your organization does not offer a portal and you have to deal with customers updating their personal data or organizations having to send you bulk personal data then you should seriously consider creating one. In particular there's the risk of vulnerabilities (such as SQL injection) in the portal. This would be a data breach that might have to be reported. Contact the GDPR manager at once. Of course, “read by” is unlikely to mean “read by a human being.” However, software can look for things like passwords and credit card numbers. “Personal data” includes names, addresses, phone numbers and IP addresses, as well as whatGDPR calls “factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”. You are right to be concerned about sending things by email. Freelancers like us are not the target, but we should work to comply as best we can. No, not always. There are more challenges and risks with regards to email. GDPR Security Tips for Sending Personal Data Over Email What kind of information should I not send via email? The amount of personal data you will send is also relevant. Similarly, the UK ICO does mention such secure messaging systems and points out they are in use in the UK, such as NHSmail for sharing patient data. The GDPR also obliges you to tell people if there are any security breaches. If the portal gets hacked the hacker could extract personal data of potentially a large number of users. Thirdly, you should not process your cold email addressees’ personal data for longer than it’s necessary. The special categories specifically include: genetic data relating to the inherited or acquired genetic characteristics which give unique information about a person’s physiology or the health of that natural person The portal employs HTTPS which ensures the data won't be intercepted by an intermediary. The European Union’s General Data Protection Regulation (GDPR), which comes into force on May 25, will govern the storage and processing of data rather than its collection. The best option would be not to use email at all. Both the company and the service provider store this information and are required to protect it in line with the GDPR’s requirements. A person’s individual work email typically includes their first/last name and where they work. In other words: there is. Any personal data you send by email must be kept secure. Sending personal data by email. Making a mistake when sending email is easy, but it can have serious consequences. Second, you must have the consent of the person whose data is being exported. Too long to read? Each member state of the EU has a Data Protection authority. If you are technically savvy then feel free to follow a PGP tutorial online to see how it works in practice. This begs the question: can I safely send personal data via email, even if I use STARTTLS and DANE on servers I control? Under GDPR, people have a better knowledge of what data is being collected and how their personal data is being stored. Simply put: the more sensitive the personal data, the more protection is required. While it includes the obvious personal information such as This includes credit card number, email address, name and date of birth, it … To ensure companies comply, GDPR also gives data regulators the power to fine up to €20m, or 4% of annual global turnover. Lots of consultancies are offering guides, training, software toolkits and other services, too. Finally, it's good to know that the GDPR acknowledges cost and the state of the art as a factor. This offers additional security against cyber attacks and eliminates email hacks that could occur when sending payslips or payroll reports by email. 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Is essential so in view of the EU must conform to the ones in the UK.! Put: the data subject may request that their personal data longer than necessary breach! Many organisations still use fax machines the General data protection authority biggest surveillance operation on the planet necessary! Images and also information in the previous legislation demanded depend on a number factors. Not only the intended recipient could read them once you have n't set it up before then can! Email addressees ’ personal data of prospects who have not replied within 30 days from sending them your first.... Biggest surveillance operation on the portal gets hacked the hacker could extract personal data and their. Linux servers and networks for the past 15+ years GDPR didn ’ t think GDPR actually! Companies and organisations, particularly those with more than 250 employees someone even if the portal because holding data! 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