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Personally identifiable information (PII) storage service built to comply with GDPR and CCPA
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README.md

Paranoid Guy Data Bunker

Data Bunker is a Personally Identifiable Information (PII) Data Storage Service built to Comply with GDPR and CCPA Privacy Requirements.

Slack

Project demo is available at: https://demo.paranoidguy.com/ . Please add a star if you like our project.

We live in a world where our privacy of information is nonexistent, the EU has been working to remediate this fallacy with GDPR, and the US (California) follows with a first sparrow called CCPA.

Data Bunker Project is intended to ease the acceptance of GDPR and CCPA regulations while giving organizations an easy to implement API's, platform and secure Database. This will give all of us, the real data owners, control of our data, and allow us to know who is using our data, what is he doing with it and have the freedom to decide if we agree to that or not.

This project, when deployed correctly, replaces all the customer's personal records (PII) scattered in the organization's different internal databases and log files with a single, randomly generated token managed by the Data Bunker service.

By deploying this project and moving all personal information to one place, you will comply with the following GDPR statement: Personal data should be processed in a manner that ensures appropriate security and confidentiality of the personal data, including for preventing unauthorized access to or use of personal data and the equipment used for the processing.

Diagram of old-style solution.

picture

Diagram of Solution with Paranoid Guy Data Bunker

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Other documents: API LIST, INSTALLATION

Demo

Project demo is available at: https://demo.paranoidguy.com/

You can see management for Natural person (data subject) account access:

Phone: 4444
Code: 4444
Email: test@paranoidguy.com
Code: 4444

This project resolves most** of the GDPR requirements for you including:

NOTE: Implementing this project does not make you fully compliant with GDPR requirements and you still need to consult with an attorney specializing in privacy.

NOTE: When we use the term "Customer" we mean the data of the end-user that his information is being stored, shared and deleted.

Right of access

Data Bunker will to extract customer email and customer phone out of the customers' personal records granting passwordless access for the customer into their Data bunker' personal account. This is done by generating a random access key that Data Bunker sends to your customer by email or by SMS. Your customer login and can view all information collected and saved by Data Bunker in connection to his profile.

login form login with email verify login with code

Right to restrict processing / Right to object / Consent withdrawal

Data Bunker manages all the customer's consents. A customer can Withdraw/restrict/object to a specific consent in his personal account at Data Bunker, for example, to restrict or block email. Your backend can work with Data Bunker using our API to add, or cancel consents and a callback operation will be fired when a customer's action takes place.

Consent management Consent withdrawal

NOTE: Data bunker can call your backend script on a consent withdrawal (callback). You will have to handle these requests and remove the customer records from other 3rd party processing companies. For example: web recording services, email gateways and etc...

Privacy by design

This product, from the architecture level and down was built to comply with strict privacy laws such as GDPR and CCPA. Deploying this project can make your architecture privacy by design compliant.

Transparency and Accountability principle

Any system or customer connecting to Data Bunker must provide an access token to authorize any operation, otherwise the operation will be aborted. An end customer can login to his profile with a random authorization code sent by email or SMS.

All operations with personal records are saved in the audit log.

Any customer can log in to his account at Data Bunker and view the full audit of activities performed on his profile.

Forget me

Right to be forgotten / Right to erasure

When your customer requests to exercise his right to be forgotten, his private records will be wiped out of the Data Bunker database, giving you the possibility to leave all internal databases intact while not impacting any of your other systems.

Upon customer removal request, Data bunker can call your backend script (callback) with the customer details. You will have to handle these requests and remove other customer records from 3rd party processing companies. For example from web recording services, email gateways and etc...

Forget me

NOTE: You will need to make sure that you do not have any customer identifiable information (PII) in your other databases, logs, files and etc.

Right to rectification/ Data Accuracy

Your customer can log in to his personal account at Data Bunker and change his records, for example change his Name. Data Bunker can fire a callback operation with a customer details, when a customer action takes place.

Change profile

Right to data portability

Your customer can log in to his personal account at Data Bunker and view and extract all his records stored at Data Bunker.

NOTE: You will need to provide your customers with a way to extract data from other internal databases.

Data minimization and GDPR Scope reduction

When you clean up your databases from personal records (PII) and use the Data Bunker token instead, you are minimizing the scope of personal information stored in other systems. In addition, whensharing your customers' data with 3rd parties, Data Bunker provides you with the purposefully built, time-bound "shareable identity".

Integrity and confidentiality

All personal data is encrypted. An audit log is written for all operations with personal records. All-access to Data Bunker API is done using an HTTPS SSL certificate. Enterprise version supports Shamir's Secret Sharing algorithm to split the master key to a number of keys. A number of keys (that can be saved in different hands in the organization) are required to bring up the system.

NOTE

Implementing this project does not make you fully compliant with GDPR requirements and you still need to consult with an attorney specializing in privacy.


Data Bunker use cases

Personal information tokenization and storage

Customer information, or PII, received in HTML POST key/value format of or JSON format is serialized, encrypted with a 32 byte key and saved in database. You will get a customer token to use in internal databases. Afterwords, you can query the Data Bunker service to receive personal information, saving audit trail.

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Application data separation

When creating application, I suppose you do not want to mix your customer data with data from other applications. In addition to personal information record, Data Bunker provides you a way to store your app customer information in a specific type of record for that. So, you can retrieve only your app' customer personal information. For example you can store customer shipping information in an additional app table.

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Audit of all operations with personal records

Data Bunker saves audit events on all API operation. For example, new personal record added or changed; personal information record retrieved, etc...

By providing Audit of events, in relation to personal data, provides response to GDRP Article 15 requirement: Right of access by the data subject.

Special features:

  • Personal information in audit event is encrypted.
  • Customer can view only his own records.

Each audit record consists of:

  • Date and time
  • Operation title
  • Operation status
  • Operation description
  • Change before and after if applicable

GDPR compliant logging : Web and mobile app session data storage

Web or mobile application session data is very similar. They contain customer IP address, browser information, web server headers, logged-in customer info, etc... Many systems, including popular webservers, like Nginx, Apache simply store this information in logs. This information, according to GDPR is considered personal identifiable information and must be secured and controlled.

So, you can not save customer ip or browser information in logs now. Insead, Data Bunker will generate you a special token to save in logs. Data Bunker provides you an API to retrieve this info out of Data Bunker without additional password for a limited time as in GDPR. For example one month.

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Shareable customer/app/session identity for 3rd parties

When sharing data with 3rd party services like web analytics, logging, intelligence, etc... sometimes we need to share customer id, for example, customer original IP address or email address. All these pieces of information are considred customer identifiable information and must be minimized when sending to 3rd paty systems.

Do not share your customer user name, IP, emails, etc... because they look nice in reports!

According to GDPR: The personal data should be adequate, relevant and limited to what is necessary for the purposes for which they are processed.

Our system can generate you time-limited, temporary, shareable identity token that you can share with 3rd parties as a record identity. This identity, can link back to the customer personal record or customer app record or to specific customer session.

Optionally, Data Bunker can incorporate partner name in identity so, you track this identity usage.

Your partner can retrieve this information and only specific fields during this specific timeframe. Afterward, access will be blocked.

Consent management, i.e. withdawal

According to GDPR, if you want to send your customer SMS using 3rd party gateway, you must show to your customer a detailed notification message that you will send his phone number to a specific SMS gateway company and the customer needs to confirm this operation.

You need to store these confirmations and Data Bunker can do it for you.

Consent must be freely given, specific, informed and unambiguous. From GDPR, Article 7, item 3:

  • The data subject shall have the right to withdraw his or her consent at any time.
  • It shall be as easy to withdraw as to give consent.

In Data Bunker:

  • Your customers can log in to his Data Bunker account and view all consents he gave.
  • Customer can also discharge consents and we will send you a notification message.
  • Removing consent for a customer is as easy as granting it in the first place.

Custom application signup and sign-in

When implementing signup and sign-in in your customer-facing applications, we recommend you to store all signup records in the Data Bunker database. We support 3 types of indexes, index by login name, index by email address and index by phone number. So you can easily implement login logic into your solution with our service.

Index by email and index by phone allow us to give your customers passwordless access to their personal profile at Data Bunker. We send your customer a one-time login code by SMS or email to give them access to thier account at Data Bunker.


Questions

How do I search for all orders from a guy named John?

Data bunker supports customer record lookup by login name or email address or phone number or token value. So, if you have one of these values, you can do the customer record lookup (using Data Bunker API) and get customer token. After that you can find customer' orders from the orders table.

How to backup Data Bunker database?

We have a special API call for that. You can run the following command to dump database in SQL format:

curl -s http://localhost:3000/v1/sys/backup -H "X-Bunker-Token: $TOKEN" -o backup.sql

What about replication?

Replication is supported in Data Bunker Enterprise version using the backend MongoDB database. Open source version is using local sqlite3 database that does not supports replication. You can easily backup it using API call and restore. We decided to use sqlite3 as as it provides zero effort from customer to start using our product.

Can my DBA tune database performance characteristics?

Almost all Data Bunker requests are using database level indexes when performing API calls. We would love your DBA to check product database schema for improvements. If we are missing something let us know. We are using sqlite3 in open source version and MongoDB in enterprive version. You can easily backup sqlite3 database and view it's structure.

What is the difference between tokenization solution XXX and Data Bunker?

Most of commercial tokenization solutions are used to tokenize one specific record, for example customer name or customer email, etc... These distinct records are not linked to one customer record. In our solution, we tokenize the whole customer record with all the details, that gives us many additional capabilities. So, in our system, the end customer (Natural person or data subject) can "login" into his profile, change record or manage his consents, or ask for forget me. In addition we provide many APIs to help with GDPR requirements.

Why Open Source?

We are a big fan of the open-source movement. After a lot of thoughts and consultations, the main Data Bunker product will be open source.

We are doing this to boost the adoption of a privacy enabled world.

Enterprise version will be closed source.

What is considered PII or what information is recomended to store in Data Bunker?

Following is a partial list.

PII PII
* Name * RFID
* Address * Contacts
* IP address * Genetic info
* Cookie data * Passport data
* Banking info * Driving license
* Financial data * Mobile device ID
* Browsing history * Personal ID number
* Political opinion * Ethnic information
* Sexual orientation * Health / medical data
* Social Security Number * Etc...

Technology stack?

We use golang/go to build the whole project. Open source version comes with internal database (sqlite3) and Web UI as one executable file to make the project easy to deploy.

Encryption in motion and encryption in storage

All access to Data Bunker API is done using HTTPS SSL certificate. All records that have customer personal information are encrypted or securely hashed in the databases. All customer records are encrypted with a 32 byte key comprizing of System Master key (24 bytes, stored in memory, not on disk) and customer record key (8 bytes, stored on disk). The System Master key is kept in RAM and is never stored to disk. Enterprise version supports Master key split.

Data Bunker internal tables

Information inside Data Bunker is saved in multiple tables in encrypted format. Here is a diagram of tables.

Detailed use case for each table is covered bellow.

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Enterprise features (not an open source version)

Support for Mongo backend

The Databunker open source works with a local database, while enterprise version works with MongoDB database. With MongoDB you can spin a number of database replicas using MongoDB Atlas services and Databunker enterprise version will connect with this database cluster.

Master key split

Upon initial start, the Enterprise version generates a secret master key and 5 keys out of it. These 5 keys are generated using Shamir's Secret Sharing algorithm. Combining 3 of any of the keys, ejects original master key and that can be used to decrypt all records.

The Master key is kept in RAM and is never stored to disk. You will need to provide 3 kits to unlock the application. It is possible to save these keys in the AWS secret store and other vault services.

Advanced role management, ACL

By default, all access to Data Bunker is done with one root token or with Time-limited access tokens that allow to read data from specific customer record only.

For more granular control, Data Bunker supports the notion of custom roles. For example, you can create a role to view all records or another role to add and change any customer records; view sessions, view all audit events, etc...

After you define a role, the system allow you to generate access token for this role (you will need to have root token for all these operations).

Data Bunker have an API for all these operations.

Support Hashicorp Vault

Hashicorp Vault, is a great piece of new generation of security product, has a notion of session accounts/passwords. Hashicorp Vault can store root access token to Paranoid Guy Data Bunker, and when your application wants to open session and access Data Bunker, it will talk with Bunker to issue a temp token with specified role. When your application session is closed with Data Bunker, Hashicorp Vault will connect to Data Bunker and revoke access token.

This architecture is done to minimize the chance that if the attacker breakes into your application server, he will not get a full controll over the Data Bunker service as root token will not be saved in your application server.

This is all done with the help of custom plugin we build for Hashicorp Vault.

Contact us

For technical questions or for product demo you can talk with Yuli Stremovsky at stremovsky@gmail.com

For business inquiries, partnership requests you can talk with Boaz Shunami at boaz@komodosec.com


Other documents: API LIST, INSTALLATION

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