CNIL Issues Data Protection Kit For Developers

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  1. The French Data protection authority, CNIL, has issued a “Developer Kit” setting forth best practices for data protection.

Key takeaways:

  • Before using a development tool, especially for personal data, read the conditions of use.
  • If the data requires a maximum level of confidentiality, use tools with a local instance, rather than the cloud.
  • Conduct a data protection impact assessment (DPIA) at the outset, even if not required by GDPR.
  • Start from a simple, correctly designed and secure system. Increase the complexity gradually while continuing to secure new additions.
  • If you use agile methods for your development, consider integrating security into the heart of your process.
  • Implement “defense in depth.”
  • If using cloud-based code management, ensure your code repository visibility setting is set to “private.”
  • Never use real personal data in the dev environment.
  • Change the default configuration of your third-party libraries and SDKs.
  • When using third-party components, only enable the features you need.
  • Develop a clean code and check it.
  • Document your architecture.
  • Version the documentation with the code.

[View source.]

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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