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Oversight body handed Code of Conduct for Cloud Service Providers

On February 15, the Cloud Select Industry Group (C-SIG) hosted its first plenary meeting of the year in Brussels, Belgium. The C-SIG was established in 2013 and is “made up of representatives from European and multinational industry, public administrations and other interested players. Meetings with this group help the Commission gather feedback on major cloud-related issues from a variety of perspectives.”

At the meeting, the European Commission presented its suggestions for the evolution and re-organization of C-SIG, emphasizing the stakeholder engagement and governance structures to ensure a strong and balanced involvement of a broad scope of stakeholders, and to develop a cloud ecosystem by promoting trust, growth, harmonization and competition.

Also, the Data Protection Code of Conduct for Cloud Service Providers was handed over to its General Assembly, SCOPE EUROPE, a new entity specifically established to administer codes of conduct and to foster development on the European level. The Code of Conduct for Cloud Service Providers was drafted by the C-SIG working group in 2012.

Between 2014 and 2015, the draft code was reviewed by the Working Party 29 for feedback and opinions. Since 2015, the drafting team has worked on processing the received feedback. 

The code was created based on alignment with the new General Data Protection Regulation, plus industry best practices. It is the first code of conduct in the market with a governance model and set-up for an independent monitoring in accordance with GDPR.

Its purpose is to provide trust and confidence to cloud customers that their personal data are “processed with an appropriate level of data protection and that an adhering CSP has performed the necessary due diligence related to the processing of personal data according to the current EU Data Protection Directive, its national transpositions and subsequent EU data protection laws, in particular the General Data Protection Regulation and any further European data protection legislation. Specific governance procedures are foreseen to ensure that the Code is revised and amended to remain fully aligned with the obligations of European data protection law over the course of its evolution.”

An important point to highlight is that the scope of the code applies to any type of the CSP (including IaaS, PaaS and SaaS), any CSP that process personal data, and any CSP that is in scope of meeting the requirements of EU data protection laws.

The code contains a clear introduction with terminologies, structure, purpose and scope, as well as the declaration of adherence. For data protection, it spells out the substantive rights and obligations of related parties, such as the data controller and processor defined in the Data Protection Directive and the GDPR once in force. The code lists a minimum set of information-security objectives that must be achieved by a CSP. In addition, it explains in detail the transparency, security and process for declaration of adherence. At last, to help CSP to kick start, the code also provided a checklist – a step by step guidance to adherence.

The model of governance is at multiple levels:

  • the governance of the code and organizational framework of the Code itself and its bodies;
  • the governance of the CSPs that have chosen to adhere to the Code; and,
  • the governance of the code itself, “ensuring that it can be updated to reflect changes in EU data protection law and in particular the enactment and implementation of the General Data Protection Regulation, and ensuring that lessons learned in the interpretation and application of the Code can be appropriately integrated.”

As part of the governance model, the Brussels-based General Assembly, SCOPE EUROPE, was created to meet the requirements of a GDPR-monitoring body (Article. 41). Its German based parent company, SRIW, has nearly six years of experience in administrating and monitoring codes of conduct. SCOPE EUROPE will host the General Assembly of the Cloud Code of Conduct and perform the tasks of the secretariat and monitoring body.

Currently, several companies representing a significant share of the cloud market have already declared to become members of the General Assembly. A broad participation from the cloud industry will help to ensure the code’s governance principles become a pilot model for any future codes under the regime of the GDPR.

The first meeting of the General Assembly will be held within the next four weeks to discuss further work streams to go into operations.  

photo credit: Infomastern The Sky via photopin (license)

Written By

ShanShan Pa, CIPP/US, CIPM

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