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Based on this assessment, following action points can be attributed to eduGAIN central operations, REFEDS, Identity Federation Operators, Service Providers and Identity Providers.
| AP | Who | Description | How | Status |
|---|---|---|---|---|
| Publishing contacts in metadata | eduGAIN | Operational contact information for individual administrators IdPs, SPs, AAs and Identity Federations is collected in the metadata published by Identity Federation Operators. The information is held and published in the eduGAIN database and in the eduGAIN metadata. | Published contacts in metadata should not be personal but rather to functions. Advise identity federation operators. If personal information is unavoidable, Article 15 on the Rights of Access by the data subject applies. | |
| Identity Federations | Operational contact information for individual administrators of IdPs, SPs and AAs is collected in their metadata. | Published contacts in metadata should not be personal but rather to functions Recommend their IdPs, SPs and AAs to use non-personal contact information in the metadata. If personal information is unavoidable, Article 15 on the Rights of Access by the data subject applies. | ||
| SG members contacts | eduGAIN | Contact information for the eduGAIN Steering Group delegate and deputy of all member federations are collected and published on the technical website. | Inform member federations that information about their SG delegate and deputy is published on the technical website. Processes in eduGAIN should ensure that the individuals mentioned have the appropriate ability to ensure this information is accurate and to understand how it is used (as described in Article 15 Rights of access by the data subject). | |
| Data Processor Agreements - DPA | IdPs, SPs | GDPR regulates the release of personal information from an IdP/AA to SP. Scalable minimal Attribute Assertions should be addressed with use of entity categories. However, where scalable models do not apply, the contracting parties cam make bilateral DPA agreements. | Can make bilateral DPAs where scalable models do not apply. | |
| Identity Federations | Support the IdPs and SPs, and help them identify where scalable models dont apply. | |||
| eduGAIN /REFEDS | Consider to develop a sample bilateral Data Processor Agreement in the BCP package, with the caveat that implementation must be at the risk of the contracting parties | |||
| GÉANT Data Protection Code of Conduct - CoCo | eduGAIN |
The work on a new version of GÉANT CoCo commenced in the GN4-2 project and is being carried out by a small team of identity federation specialists with support from data protection legal specialists at the global law firm DLA Piper. The draft GDPR version has been substantially completed and has been sent out to consultation within the international identity federation community. The new version of GÉANT CoCo is more detailed than version 1 as the new legislation is more prescriptive and takes into consideration the areas of Increased Territorial Scope, Penalties, Consent, Breach Notification, Right to Access, Right to be Forgotten, Data Portability, Privacy by Design and Data Protection Officers. The interim working draft was published in June 2017 on the REFEDS Wiki [GÉANT CoCo-v2]. An explanatory memorandum is being prepared in parallel.
The small working group shall complete the work on the new GDPR version of the GÉANT Data Protection Code of Conduct, including aspects such as jurisdiction and arbitration clauses for international organisations. After completion, the new version| The current version of the CoCo describes an approach to meet the requirements of the EU DPD. It defines behavioural rules for SPs that want to receive attributes from IdPs/AAs about the user that logs in to the service. | Update GÉANT CoCo to reflect the changes between the new GDPR and the old DPD. After completion, new CoCo v2.0 must be submitted to the EU GDPR competent supervisory authority of approved codes of conduct as described in GDPR Article 40. After the submission of |
CoCo v2.0. GÉANT shall work together with the competent supervisory authority to get |
CoCo v2.0 approved as an official GDPR Code of Conduct, effective after 25 May 2018. In parallel with the approval process, adoption and use of |
CoCo v2.0 within eduGAIN will be formalised as Best Practice for both |
SPs and IdPs. | The work on a new version of CoCo commenced by a small team of identity federation specialists with support from DLA Piper. The draft version has been substantially completed and has been sent out to consultation within the international identity federation community.The interim working draft was published in June 2017 and an explanatory memorandum is being prepared in parallel. |
| Identity Federations | Prepare the tooling and processes to enable adoption of GÉANT CoCo v2 by |
| IdPs and |
| SPs | ||||
| REFEDS Research and Scholarship Entity Category -REFEDS R&S | REFEDS | REFEDS R&S is designed to allow data to flow to research and scholarship interaction SPs, that have a legitimate interest in the data.The attributes supported in REFEDS R&S are chosen to represent a privacy baseline such that further minimisation achieves no particular benefit. The impact of the GDPR is low due to the fact that REFEDS R&S is based on necessary use of the service and utilises the minimal Attribute Assertion (shared user identifier, person name, email address and the optional organisational affiliation). | Should perform an assessment of the GDPR on REFEDS R&S: use of consent, use outside EU/EEA and the applicability as certification mechanism. Explore the potential of certifying the REFEDS R&S as Certification bodies emerge. | |
| eduGAIN | Incorporate REFEDS R&S as BCP | |||
| Identity Federations | Implement a lightweight audit for before applying the REFEDS R&S tag to ensure that the data in the attribute bundle is legitimately required by SP. This is supported by a risk management toolkit to help organisations make effective decisions when supporting REFEDS R&S. |
- IdFeds, eduGAIN, REFEDS: need to review their best practices regarding Attribute Assertions
2. IdFeds: should continue to work on scalable minimal Attribute Assertions and adapt them to GDPR
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| IdPs | As REFEDS R&S is based on necessary use by legitimate interest, the IdPs can remove the consent question. Transparent privacy notice in which the IdP explains to the end user which attributes are released and why can be used instead. | |||
13. eduGAIN: To address requirements regarding data breaches place SIRTFI as recommended practice and support data breaches by central function.
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