Data security -- 13 -- data security lifecycle management

One 、 Introduction

Data security Lifecycle Management , It starts with the safe collection or generation of data , Secure use of overlay data 、 Secure transport 、 Secure storage 、 Safety disclosure 、 Safe circulation and tracking , The whole process safety guarantee mechanism until safe destruction .

For the privacy lifecycle of data , It is generally divided into the following stages ：

● Inform the data subject （ Privacy statement or notice ）
● Data subject selection and consent
● Data collection or generation
● The data transfer
● Data storage and retention period management
● Data usage
● Data circulation and exit
● Data disclosure
● Data destruction

Two 、 Inform the data subject

For informing data subjects , Start with data collection , The purpose of the collected data should be clarified 、 Business and product range used 、 Protective measures, etc , Avoid collecting unnecessary user data . In order to protect the right to know of the data subject , And comply with the transparency requirements of laws and regulations , We need to inform the data subject of our privacy policy .

Take the most common website online services as an example , Usually, you need to place a named Privacy policy Hyperlinks for .

3、 ... and 、 Data subject selection and consent

Processing personal data , At least one of the six legal bases is required , These six bases are The user agrees to 、 Contractual obligations 、 Legal obligations 、 The core interests of data subjects or others 、 public interest 、 The legitimate interests of data controllers and third parties .

Among the six legal bases ：

● Contractual obligations 、 Legal obligations 、 The core interests of data subjects or others 、 public interest These four bases use very limited scenarios , Not universal .
● Legitimate interests The most controversial 、 Most complaints , It needs to be avoided as much as possible .

therefore , Most commonly used in practice 、 The most important legal basis is The user agrees to .

When it may have a great impact on the data subject , In particular, it is necessary to obtain the effective consent or express consent of the data subject . The so-called effective consent , That is, by default, you cannot check "agree" for users , Users are required to actively check the consent option .

in addition , Different types of businesses should use different privacy policies , Instead of using a blanket privacy policy . Some activities mentioned in the privacy policy that may affect the interests of data subjects , For example, personalized advertising push , Switch options should be set , And it cannot be opened by default .

In order to effectively manage the consent of data subjects , The background needs to record the consent record of each data subject to each privacy policy version , When the privacy policy version is updated , The data subject needs to agree again .

Four 、 Secure collection or generation of data

After the user agrees , Should be informed in accordance with the privacy policy , Minimize collection . For the received data , Its data classification and classification should be determined . Data classification and classification determine what measures should be taken to protect it .

To prevent personal information disclosure , Appropriate pretreatment should be taken after data collection , Or measures to reduce privacy sensitivity , Upload to the server , There is no need to transmit original sensitive information .

5、 ... and 、 Secure transmission of data

The transmission of information should use HTTPS Or other encrypted channels . Transmit on the Internet , The preferred HTTPS Encrypted transmission mechanism , It is recommended to use a unified access gateway , Unified management of certificate private key , Enable uniformly HTTPS. Transmit on Intranet , Consider RPC The encrypted 、HTTPS Equal mechanism , Encrypted transmission of sensitive data .

6、 ... and 、 Safe storage and retention period management of data

Generally, encrypted storage measures are taken for the following data ：

● password 、 secret key , Include database 、 Passwords and keys in the configuration file .
● Sensitive personal privacy data .
● alive UGC data （ User generated content ）.

As for business data , You need to weigh , Especially involving retrieval 、 Sort 、 Sum calculation and other scenarios .

In terms of retention period , It mainly involves two types of data .

● The first is the identity data of the data subject , It is usually collected once , If there is no need to correct , Then it will be stored for a long time , Until the product goes offline or the user cancels the account , Delete the corresponding data .
● The second type is generated during the activity after registration , Such as pay / Records of consumption 、 Sports records, etc , According to the set retention period , Automatically delete or delete the corresponding encryption key when it expires .

7、 ... and 、 Safe use of data

In data usage 、 Retain 、 In the process of storage , Necessary safety control measures need to be taken , To ensure the security of personal data , This part usually includes ：

● Access to data requires authorization based on identity 、 Access control 、 Audit mechanism .
● to grant authorization , For example, in addition to the users themselves , Authorize their friends to view their circle of friends information .
● Access control , For example, prevent the database from being directly opened to the public or have weak passwords .
● Retention period management , For payment / Records of consumption 、 Sports records, etc , According to the set retention period , Automatically delete or delete the corresponding encryption key when it expires .
● Data display , Some data cannot be displayed , Like passwords 、 Biometrics for identity authentication , Some data need desensitization , Such as name 、 Phone number 、 Address 、 Bank card number, etc .
● Data disclosure , Data before disclosure , Strict desensitization should be taken 、 To mark words and other measures 、 Due diligence and signing should be carried out before disclosure to data processors DPA.

8、 ... and 、 Data circulation and exit

For the safe flow of data , It is recommended not to provide raw data , It is encapsulated as a data service , Insert a tracking field that can be uniquely located to a specific business , Provide desensitization data query interface , Establish corresponding accounts for other businesses and authorize them 、 Limit the query frequency 、 Record the query log . If you have to provide raw data , Consider inserting some fake data that can uniquely locate the other party's business , It is used to locate the party responsible for the leakage of data in batches .

Provide data to other businesses through data interface , Other business demanders need to promise or sign confidentiality agreements , Disable caching 、 It is forbidden to delete tracking fields , And check the implementation when the other party's business goes online .

If the data is collected or generated domestically , By default, it should be stored in China . If you want to transfer abroad , It needs to be strictly evaluated , And consult the legal department of the enterprise .

If it's a cell phone APP And other scenes directly involving personal data exit , At least get the express consent of the user . Express consent is included in the privacy statement to actively and clearly inform 、 The user actively checks agree .

Nine 、 Data destruction

In practice , It is still quite difficult to truly destroy or make it unusable in the sense of security , In general , When the user requests deletion , You can delete the key of the corresponding record , Make the original encrypted data in the backup no longer available .

For retired hard disks , Generally, low-level formatting is required 、 Degaussing 、 Physical bending destruction and other means for destruction .