Where's My Data? Managing the Data Residency Challenge

Claude Baudoin & Geoff Rayner
27 February 2018
Where’s My Data?
Managing the Data
Residency Challenge
2/27/2018 Copyright © 2018 OMG. All rights reserved. 1

Speakers
Tracie Berardi Director of Program Management, OMG
Program Manager, Cloud Standards Customer Council
Moderator
tracie@omg.org
Claude Baudoin Principal, cébé IT & Knowledge Management
Steering Committee member, Cloud Standards Customer Council
cbaudoin@cebe-itkm.com
Geoff Rayner CEO, Data Advantage Group
grayner@dag.com

• Data Residency definition
• History of OMG’s work on data residency
• Types of information that pose risks
• Nature of the risks – examples
• Laws and regulations around the world
• Potential applicable standards
• OMG Discussion Paper
• OMG Data Residency Maturity Model (DRMM)
• How to contribute
Topics Covered in this Webinar
New

“Data residency is the set of issues and practices related to the
location of data and metadata, the movement of (meta)data
across geographies and jurisdictions, and the protection of that
(meta)data against unintended access and other location-related
risks.”
• Scope
• Not just about the protection of personally identifiable information (PII)
• Also concerns the right to move “sovereign” data, such as oil reserves data;
international licensing of genomics data; distribution of biometrics data for
security purposes; etc.
Data Residency: Definition

• March 2015: initial request from an OMG member
• June 2015: first OMG Data Residency WG meeting (Berlin)
• Q4 2015: Prepared and issued an RFI
• Q2 2016: Processed RFI results, decided to create a discussion paper as first
deliverable
• Q4 2016: Drafted discussion paper, agreed to collaborate with CSCC and
issue two separate but almost identical papers
• Q1 2017: Collected contributions, edited paper, agreement to release
• Q2 2017: Create CSCC companion white paper, press releases, webinar
• June-Dec. 2017: Successive tutorials, created and released a maturity
model, discussed standards roadmap
OMG’s Work on Data Residency

• Multiple laws and regulations restrict what an organization can do
with certain types of data, or potentially prevent its protection:
• Personally identifiable information (PII)
• Patient health information (PHI)
• Proprietary corporate information
• Communications (e-mail, etc.)
• Government information (incl. military)
• Information subject to trade controls and embargoes
• Information on natural resources
• Banking records
• Other regulated data, e.g., “sovereign” data
Sources of Risk

• Owners of such data may:
• Relocate this data intentionally, for convenience or cost reduction
• Data center consolidation and managed hosting
• Centralized employee or customer database
• Business process outsourcing
• Helpdesk outsourcing
• Be unaware of its location
• Cloud service optimization by the provider
• IoT data collection
• Acquisitions and expansion to new countries change the risk
• The Internet of Things exacerbates the challenge
Sources of Risk (cont.)

• Difficulty of providing IT services across borders from few locations
• Higher cost for customers (less competition for local services)
• Inability to consolidate operations
• Inability to provide shared employee services
• Need for multiple local IT operations teams (skills and cost issues)
• Limitations in backup locations
• Restrictions against strong data encryption
• Legal exposure
• Conflict with authorities
• Public mistrust
Nature of the Risks

• Multiple, inconsistent, overlapping, and still evolving laws and
regulations around the world
• Range from non-existent to severe
• Sometimes (but not always) apply to government data / public
records, not to private companies’ data
• The European Union’s General Data Protection Regulation (GDPR), in
effect from 25 May 2018, is among the most comprehensive
• Multiple motivations behind the laws:
• Protecting the privacy of citizens
• Enabling police and tax authorities to inspect data
• Protectionism – force companies to create domestic facilities
• Monetize the flow of data
Data Residency Laws and Regulations

A Proliferation of Laws

• There is currently no standard that deals specifically with data
residency
• Data residency is related to the security and privacy aspects of
• Several NIST publications (800-144, 500-299, 1500)
• Several ISO/IEC standards (27001, 27017, 27018)
• NIST Big Data Standard, http://fedscoop.com/nist-big-data-framework
• The work of the CSA’s International Standardization Council (ISC)
• Work being considered in ISO/IEC JTC 1/SC 38
• The “Voluntary Data Protection Code” of CISPE (Cloud Infrastructure Service
Providers in Europe)
Potential Useful Standards

• Two very close versions (OMG and CSCC)
OMG’s First Discussion Paper

• Issued by OMG in
December 2017 as
a second
“discussion paper”
• Structured in a
similar manner to
the SEI CMM for
software
engineering
(1990)
• 5 levels and 20
“key process
areas” that need
to be put in place
to “climb” to
higher levels of
maturity
Copyright © 2018 OMG. All rights reserved.
13
The Data Residency Maturity Model (DRMM)
Level
SEI CMM
Name
Definition (under
construction)
Key Process Areas
5 Optimizing
There is continuous
monitoring and
improvement of data
residency policies,
procedures and
implementation
● Active monitoring and auditing of data location, transfer, and remote
access
● Regular review of changes in business, data content, technology, laws
and regulations
● Formal process to evolve policies, procedures, practices and
technology
● Formal process to review all incidents and take corrective action
4 Managed
Active management takes
place at all levels of the
organization
● Executive accountability
● Governance (e.g., steering committee)
● Assign roles and responsibilities for DR policy and implementation
● Formal policies
● Data storage location assignment is part of information modeling
● Logging / audit trail of data creation, movement, access right changes
● Formal program of employee training
3 Defined
Policies, procedures,
practices are documented
and institutionalized, and
data location impact is
formally documented
● Active executive involvement
● Formally documented processes
● Taxonomy of sensitive data
● Informal training resources
● People are formally assigned to data owner/steward/custodian roles
2 Repeatable
The organization
performs on the basis of
human knowledge,
informally shared
● Executive awareness (e.g., evidenced by a letter from each C-level
stakeholder stating their belief in the importance of the issue)
● Informal practices and guidelines to identify and locate data
● Employees know who to go to in order to arbitrate a d.r. question
● People act informally in roles of data owners/steward/custodians
1 Initial
None of above practices
exist

• Participate in OMG’s Data Residency Working Group
• Review the existing discussion papers and provide comments
• http://www.omg.org/cgi-bin/doc?mars/17-03-22.pdf (“Challenges and Opportunities” paper)
• http://www.omg.org/cgi-bin/doc?mars/17-12-18.pdf (DRMM)
• Consider adopting the DRMM
• OMG is interested in partnering with organizations that would want to “adopt
and adapt” the DRMM and give it broader recognition
• Suggest applicable standards – and if you work in standards group on
security and privacy, give them input about data residency issues
• Our current intent
• Coordinate with other OMG groups working on Data Provenance & Pedigree
and on Data Tagging & Labeling – seek a unified “data governance” approach
• Develop a standard to represent the various data residency laws and
regulations in a uniform formal manner
How to Contribute

• Thanks for your attention
• Please ask questions using the BrightTalk interface
• Ask to be added to our mailing list
• Send an e-mail to request@omg.org and ask to be added to the
“dataresidency” list
• Participate in our next meetings
• Reston, Va., March 20, 2018
• Boston, Mass., week of June 18-22
• Ottawa, Ont., Canada, week of Sept. 24-28 (2-day event on various
information governance and security topics for the Canadian government)
• Contact Tracie Berardi, tracie@omg.org, for additional questions or
comments
Discussion

Where's My Data? Managing the Data Residency Challenge

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