EU-US Data Privacy Framework 101

This RFP Guide is designed to help organizations create their own RFP for selection of Cloud-native Data Security Platform (DSP) & Data Security Posture Management (DSPM) solutions. The purpose is to identify key essential requirements  that will enable effective discovery, classification, and protection of sensitive data across complex environments, including in public cloud infrastructures and in on-premises environments.

Instructions for Vendors

Each section provides essential and recommended requirements to achieve a best practice capability. These have been accumulated over dozens of customer implementations.  Customers may also wish to include their own unique requirements specific to their industry or data environment.

1. Data Discovery & Classification

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2. Data Access Governance

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3. Posture, Risk Assessment & Threat Monitoring

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4. Incident Response & Remediation

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5. Infrastructure & Deployment

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6. Operations & Support

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7. Pricing & Licensing

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Conclusion

This RFP template is designed to facilitate a structured and efficient evaluation of DSP and DSPM solutions. Vendors are encouraged to provide comprehensive and transparent responses to ensure an accurate assessment of their solution’s capabilities.

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Sentra’s cloud-native design combines powerful Data Discovery and Classification, DSPM, DAG, and DDR capabilities into a complete Data Security Platform (DSP). With this, Sentra customers achieve enterprise-scale data protection and do so very efficiently - without creating undue burdens on the personnel who must manage it.

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To learn more about Sentra’s DSP, request a demo here and choose a time for a meeting with our data security experts. You can also choose to download the RFP as a pdf.

The Importance of Data Labeling and Tagging

In today's fast-paced business environment, data rarely stays in one place. It moves across devices, applications, and services as individuals collaborate with internal teams and external partners. This mobility is essential for productivity but poses a challenge: how can you ensure your data remains secure and compliant with business and regulatory requirements when it's constantly on the move?

Why Labeling and Tagging Data Matters

Data labeling and tagging provide a critical solution to this challenge. By assigning sensitivity labels to your data, you can define its importance and security level within your organization. These labels act as identifiers that abstract the content itself, enabling you to manage and track the data type without directly exposing sensitive information. With the right labeling, organizations can also control access in real-time.

For example, labeling a document containing social security numbers or credit card information as Highly Confidential allows your organization to acknowledge the data's sensitivity and enforce appropriate protections, all without needing to access or expose the actual contents.

Why Sentra’s AI-Based Classification Is a Game-Changer

Sentra’s AI-based classification technology enhances data security by ensuring that the sensitivity labels are applied with exceptional accuracy. Leveraging advanced LLM models, Sentra enhances data classification with context-aware capabilities, such as:

• Detecting the geographic residency of data subjects.
• Differentiating between Customer Data and Employee Data.
• Identifying and treating Synthetic or Mock Data differently from real sensitive data.

This context-based approach eliminates the inefficiencies of manual processes and seamlessly scales to meet the demands of modern, complex data environments. By integrating AI into the classification process, Sentra empowers teams to confidently and consistently protect their data—ensuring sensitive information remains secure, no matter where it resides or how it is accessed.

‍Benefits of Labeling and Tagging in Sentra

Sentra enhances your ability to classify and secure data by automatically applying sensitivity labels to data assets. By automating this process, Sentra removes the manual effort required from each team member—achieving accuracy that’s only possible through a deep understanding of what data is sensitive and its broader context.

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Here are some key benefits of labeling and tagging in Sentra:

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1. Enhanced Security and Loss Prevention: Sentra’s integration with Data Loss Prevention (DLP) solutions prevents the loss of sensitive and critical data by applying the right sensitivity labels. Sentra’s granular, contextual tags help to provide the detail necessary to action remediation automatically so that operations can scale.‍
2. Easily Build Your Tagging Rules: Sentra’s Intuitive Rule Builder allows you to automatically apply sensitivity labels to assets based on your pre-existing tagging rules and or define new ones via the builder UI (see screen below). Sentra imports discovered Microsoft Purview Information Protection (MPIP) labels to speed this process.

3. Labels Move with the Data: Sensitivity labels created in Sentra can be mapped to Microsoft Purview Information Protection (MPIP) labels and applied to various applications like SharePoint, OneDrive, Teams, Amazon S3, and Azure Blob Containers. Once applied, labels are stored as metadata and travel with the file or data wherever it goes, ensuring consistent protection across platforms and services.
4. Automatic Labeling: Sentra allows for the automatic application of sensitivity labels based on the data's content. Auto-tagging rules, configured for each sensitivity label, determine which label should be applied during scans for sensitive information.
5. Support for Structured and Unstructured Data: Sentra enables labeling for files stored in cloud environments such as Amazon S3 or EBS volumes and for database columns in structured data environments like Amazon RDS. By implementing these labeling practices, your organization can track, manage, and protect data with ease while maintaining compliance and safeguarding sensitive information. Whether collaborating across services or storing data in diverse cloud environments, Sentra ensures your labels and protection follow the data wherever it goes.

Applying Sensitivity Labels to Data Assets in Sentra

In today’s rapidly evolving data security landscape, ensuring that your data is properly classified and protected is crucial. One effective way to achieve this is by applying sensitivity labels to your data assets. Sensitivity labels help ensure that data is handled according to its level of sensitivity, reducing the risk of accidental exposure and enabling compliance with data protection regulations.

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Below, we’ll walk you through the necessary steps to automatically apply sensitivity labels to your data assets in Sentra. By following these steps, you can enhance your data governance, improve data security, and maintain clear visibility over your organization's sensitive information.

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The process involves three key actions:

1. Create Sensitivity Labels: The first step in applying sensitivity labels is creating them within Sentra. These labels allow you to categorize data assets according to various rules and classifications. Once set up, these labels will automatically apply to data assets based on predefined criteria, such as the types of classifications detected within the data. Sensitivity labels help ensure that sensitive information is properly identified and protected.
2. Connect Accounts with Data Assets: The next step is to connect your accounts with the relevant data assets. This integration allows Sentra to automatically discover and continuously scan all your data assets, ensuring that no data goes unnoticed. As new data is created or modified, Sentra will promptly detect and categorize it, keeping your data classification up to date and reducing manual efforts.
3. Apply Classification Tags: Whenever a data asset is scanned, Sentra will automatically apply classification tags to it, such as data classes, data contexts, and sensitivity labels. These tags are visible in Sentra’s data catalog, giving you a comprehensive overview of your data’s classification status. By applying these tags consistently across all your data assets, you’ll have a clear, automated way to manage sensitive data, ensuring compliance and security.

By following these steps, you can streamline your data classification process, making it easier to protect your sensitive information, improve your data governance practices, and reduce the risk of data breaches.

Applying MPIP Labels

In order to apply Microsoft Purview Information Protection (MPIP) labels based on Sentra sensitivity labels, you are required to follow a few additional steps:

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1. Set up the Microsoft Purview integration - which will allow Sentra to import and sync MPIP sensitivity labels.
2. Create tagging rules - which will allow you to map Sentra sensitivity labels to MPIP sensitivity labels (for example “Very Confidential” in Sentra would be mapped to “ACME - Highly Confidential” in MPIP), and choose to which services this rule would apply (for example, Microsoft 365 and Amazon S3).

Using Sensitivity Labels in Microsoft DLP

Microsoft Purview DLP (as well as all other industry-leading DLP solutions) supports MPIP labels in its policies so admins can easily control and prevent data loss of sensitive data across multiple services and applications.For instance, a MPIP ‘highly confidential’ label may instruct Microsoft Purview DLP to restrict transfer of sensitive data outside a certain geography. Likewise, another similar label could instruct that confidential intellectual property (IP) is not allowed to be shared within Teams collaborative workspaces. Labels can be used to help control access to sensitive data as well. Organizations can set a rule with read permission only for specific tags. For example, only production IAM roles can access production files. Further, for use cases where data is stored in a single store, organizations can estimate the storage cost for each specific tag.

Build a Stronger Foundation with Accurate Data Classification

Effectively tagging sensitive data unlocks significant benefits for organizations, driving improvements across accuracy, efficiency, scalability, and risk management. With precise classification exceeding 95% accuracy and minimal false positives, organizations can confidently label both structured and unstructured data. Automated tagging rules reduce the reliance on manual effort, saving valuable time and resources. Granular, contextual tags enable confident and automated remediation, ensuring operations can scale seamlessly. Additionally, robust data tagging strengthens DLP and compliance strategies by fully leveraging Microsoft Purview’s capabilities. By streamlining these processes, organizations can consistently label and secure data across their entire estate, freeing resources to focus on strategic priorities and innovation.

What is PII Compliance?

In our contemporary digital landscape, where information flows seamlessly through the vast network of the internet, protecting sensitive data has become crucial. Personally Identifiable Information (PII), encompassing data that can be utilized to identify an individual, lies at the core of this concern. PII compliance stands as the vigilant guardian, the fortification that organizations adopt to ensure the secure handling and safeguarding of this invaluable asset.

In recent years, the frequency and sophistication of cyber threats have surged, making the need for robust protective measures more critical than ever. PII compliance is not merely a legal obligation; it is strategically essential for businesses seeking to instill trust, maintain integrity, and protect their customers and stakeholders from the perils of identity theft and data breaches.

Sensitive vs. Non-Sensitive PII Examples

Before delving into the intricacies of PII compliance, one must navigate the nuanced waters that distinguish sensitive from non-sensitive PII. The former comprises information of profound consequence – Social Security numbers, financial account details, and health records. Mishandling such data could have severe repercussions.

On the other hand, non-sensitive PII includes less critical information like names, addresses, and phone numbers. The ability to discern between these two categories is fundamental to tailoring protective measures effectively.

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This table provides a clear visual distinction between sensitive and non-sensitive PII, illustrating the types of information that fall into each category.

The Need for Robust PII Compliance

The need for PII compliance is propelled by the escalating threats of data breaches and identity theft in the digital realm. Cybercriminals, armed with advanced techniques, continuously evolve their strategies, making it crucial for organizations to fortify their defenses. Implementing PII compliance, including robust Data Security Posture Management (DSPM), not only acts as a shield against potential risks but also serves as a foundation for building trust among customers, stakeholders, and regulatory bodies. DSPM reduces data breaches, providing a proactive approach to safeguarding sensitive information and bolstering the overall security posture of an organization.

PII Compliance Checklist

As we delve into the intricacies of safeguarding sensitive data through PII compliance, it becomes imperative to embrace a proactive and comprehensive approach. The PII Compliance Checklist serves as a navigational guide through the complex landscape of data protection, offering a meticulous roadmap for organizations to fortify their digital defenses.

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From the initial steps of discovering, identifying, classifying, and categorizing PII to the formulation of a compliance-based PII policy and the implementation of cutting-edge data security measures - this checklist encapsulates the essence of responsible data stewardship. Each item on the checklist acts as a strategic layer, collectively forming an impenetrable shield against the evolving threats of data breaches and identity theft.

1. Discover, Identify, Classify, and Categorize PII

The cornerstone of PII compliance lies in a thorough understanding of your data landscape. Conducting a comprehensive audit becomes the backbone of this process. The journey begins with a meticulous effort to discover the exact locations where PII resides within your organization's data repositories.

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Identifying the diverse types of information collected is equally important, as is the subsequent classification of data into sensitive and non-sensitive categories. Categorization, based on varying levels of confidentiality, forms the final layer, establishing a robust foundation for effective PII compliance.

2. Create a Compliance-Based PII Policy

In the intricate tapestry of data protection, the formulation of a compliance-based PII policy emerges as a linchpin. This policy serves as the guiding document, articulating the purpose behind the collection of PII, establishing the legal basis for processing, and delineating the measures implemented to safeguard this information.

The clarity and precision of this policy are paramount, ensuring that every employee is not only aware of its existence but also adheres to its principles. It becomes the ethical compass that steers the organization through the complexities of data governance.

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public class PiiPolicy {
    private String purpose;
    private String legalBasis;
    private String protectionMeasures;

    // Constructor and methods for implementing the PII policy
    // ...

    // Example method to enforce the PII policy
    public boolean enforcePolicy(DataRecord data) {
        // Implementation to enforce the PII policy on a data record
        // ...
        return true;  // Compliance achieved
    }
}

The Java code snippet represents a simplified PII policy class. It includes fields for the purpose of collecting PII, legal basis, and protection measures. The enforcePolicy method could be used to validate data against the policy.

3. Implement Data Security With the Right Tools

Arming your organization with cutting-edge data security tools and technologies is the next critical stride in the journey of PII compliance. Encryption, access controls, and secure transmission protocols form the arsenal against potential threats, safeguarding various types of sensitive data.

The emphasis lies not only on adopting these measures but also on the proactive and regular updating and patching of software to address vulnerabilities, ensuring a dynamic defense against evolving cyber threats.

function implementDataSecurity(data) {
    // Example implementation for data encryption
    let encryptedData = encryptData(data);

    // Example implementation for access controls
    grantAccess(user, encryptedData);

    // Example implementation for secure transmission
    sendSecureData(encryptedData);
}

function encryptData(data) {
    // Implementation for data encryption
    // ...
    return encryptedData;
}

function grantAccess(user, data) {
    // Implementation for access controls
    // ...
}

function sendSecureData(data) {
    // Implementation for secure data transmission
    // ...
}

The JavaScript code snippet provides examples of implementing data security measures, including data encryption, access controls, and secure transmission.

4. Practice IAM

Identity and Access Management (IAM) emerges as the sentinel standing guard over sensitive data. The implementation of IAM practices should be designed not only to restrict unauthorized access but also to regularly review and update user access privileges. The alignment of these privileges with job roles and responsibilities becomes the anchor, ensuring that access is not only secure but also purposeful.

5. Monitor and Respond

In the ever-shifting landscape of digital security, continuous monitoring becomes the heartbeat of effective PII compliance. Simultaneously, it advocates for the establishment of an incident response plan, a blueprint for swift and decisive action in the aftermath of a breach. The timely response becomes the bulwark against the cascading impacts of a data breach.

6. Regularly Assess Your Organization’s PII

The journey towards PII compliance is not a one-time endeavor but an ongoing commitment, making periodic assessments of an organization's PII practices a critical task. Internal audits and risk assessments become the instruments of scrutiny, identifying areas for improvement and addressing emerging threats. It is a proactive stance that ensures the adaptive evolution of PII compliance strategies in tandem with the ever-changing threat landscape.

7. Keep Your Privacy Policy Updated

In the dynamic sphere of technology and regulations, the privacy policy becomes the living document that shapes an organization's commitment to data protection. It is of vital importance to regularly review and update the privacy policy. It is not merely a legal requirement but a demonstration of the organization's responsiveness to the evolving landscape, aligning data protection practices with the latest compliance requirements and technological advancements.

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# Example implementation for reviewing and updating the privacy policy
class PrivacyPolicyUpdater
  def self.update_policy
    # Implementation for reviewing and updating the privacy policy
    # ...
  end
end

# Example usage
PrivacyPolicyUpdater.update_policy

The Ruby script provides an example of a script to review and update a privacy policy.

8. Prepare a Data Breach Response Plan

Anticipation and preparedness are the hallmarks of resilient organizations. Despite the most stringent preventive measures, the possibility of a data breach looms. Beyond the blueprint, it emphasizes the necessity of practicing and regularly updating this plan, transforming it from a theoretical document into a well-oiled machine ready to mitigate the impact of a breach through strategic communication, legal considerations, and effective remediation steps.

Key PII Compliance Standards

Understanding the regulatory landscape is crucial for PII compliance. Different regions have distinct compliance standards and data privacy regulations that organizations must adhere to. Here are some key standards:

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• United States Data Privacy Regulations: In the United States, organizations need to comply with various federal and state regulations. Examples include the Health Insurance Portability and Accountability Act (HIPAA) for healthcare information and the Gramm-Leach-Bliley Act (GLBA) for financial data.

• Europe Data Privacy Regulations: European countries operate under the General Data Protection Regulation (GDPR), a comprehensive framework that sets strict standards for the processing and protection of personal data. GDPR compliance is essential for organizations dealing with European citizens' information.

Conclusion

PII compliance is not just a regulatory requirement; it is a fundamental aspect of responsible and ethical business practices. Protecting sensitive data through a robust compliance framework not only mitigates the risk of data breaches but also fosters trust among customers and stakeholders. By following a comprehensive PII compliance checklist and staying informed about relevant standards, organizations can navigate the complex landscape of data protection successfully. As technology continues to advance, a proactive and adaptive approach to PII compliance is key to securing the future of sensitive data protection.

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If you want to learn more about Sentra's Data Security Platform and how you can use a strong PII compliance framework to protect sensitive data, reduce breach risks, and build trust with customers and stakeholders, request a demo today.