Data protection measures

In addition to purely technical security measures we implement additional measures to provide a safe environment for your and your customers’ data based on the following standards and regulations:

Data protection officer

The appointed data protection officer is:

Nick Lindovsky
DITAC GmbH
OT Weißlandt-Gölzau · Raffineriestr. 09 · 06369 Südliches Anhalt

General

This document is structured based on the BDSG’s first appendix which summarizes the law’s requirements as a few “golden rules”. For the translation of German official terms to English we made use of the EU’s InterActive Terminology for Europe.

As some of the requirements of the law depend on the specific (contractual) situation, we’d like to first outline the general situation that hosting in the Flying Circus puts you in:

Commissioned data processing

applies within the framework of the GDPR. We will implement a contract for commissioned data protection suitable to the GDPR with you.

Duty to give information

People who are affected by processing of data have right to request information about what data about them is being stored as well as about the processes how this data is being kept secure.

Periodical check for compliance to regulations:

The client has the responsibility to routinely check that applicable regulations are being conformed to by their contractor. Yearly checks appear to be sufficient even for highly sensitive data (e.g. medical records). The result needs to be documented in written form. The audit usually needs to be performed by a third party.

Admission control

Measures for admission control ensure that unauthorized persons cannot physically access the data processing equipment.

The physical assets (servers, switches, hard drives, …) are located in EU data centers operated by third parties. The ownership of the physical equipment is with the Flying Circus, or, in special cases by our customers 1.

For each data center used by us we require the following measures:

  • video surveillance (outside facilities, in-doors and rack corridors)

  • two-factor security for granting access (e.g. personal password and transponder card) with logging

  • physical access must be documented

  • 24 hour guard services with linked alarm system

  • separate physical security zones for general areas, data center infrastructure and customer-accessible areas

  • separately locked racks with the possibility to use custom locks and keys.

We maintain a separate List of data centers.

Physical access to data processing equipment may be performed only by the Flying Circus’ administrators. Administrators may delegate physical access to other persons (e.g., data center staff).

Entry control

Measures for entry control ensure that unauthorized third parties can not make use of the data processing systems.

Machines managed within the Flying Circus can be accessed by a variety of ways for management purposes: SSH, web interfaces, and others. For those we employ a homogenous scheme to identify and authorize users within the Flying Circus. Management access to systems must use encrypted communication channels.

Identification and authorization of customer applications not managed by the Flying Circus infrastructure are not covered by our security responsibility. Our customers are required to ensure the security of their applications themselves.

User identification must be performed using personal credentials, so that actions can be traced back to an individual originator. Thus, sharing one’s credentials with another person is prohibited. Credentials can be either a username and a cryptographic measure (e.g. a private/public key scheme) or a password, depending on the applicability.

Users with a Flying Circus account are required to manage their password securely: unauthorized physical or logical access to objects that can potentially store passwords may not result in a compromised passwords. Examples are: Home directory on a laptop, keychain or password manager software, backups, USB sticks, smartphones. Strongly encrypted storage of passwords is permissible.

All machines have emergency root logins which may only be used by Flying Circus administrators if regular user authentication is not working correctly. Such uses must be documented.

All privileged actions need to be securely logged. 2 SSH logins must be performed using SSH keys. Successful SSH logins to machines are logged—unsuccessful SSH login attempts are not. 3

Access control

Measures for access control protect against access by unauthorized personnel.

Flying Circus implements a permission-based concept to separate application maintenance tasks from privileged administrative tasks: for example, customer software updates or database access versus OS updates or OS configuration.

Privileged administrative access is generally not granted to customers. In cases where another person who is not an administrator is needed to solve a problem, a shared session between an administrator and the other person must be established (e.g. with screen).

Technically, there are three access variants to perform privileged administrative operations:

  1. Using a user account which has been granted the ‘login’ and ‘wheel’ permissions for a certain project. This requires the user to log into a regular account using his SSH key and additionally provide his password to access privileged operations.

  2. Using a user account which is member of the global group of administrators (see List of administrators) which grants access to all machines within the Flying Circus infrastructure.

  3. Emergency root logins (see above in Entry control).

Authorized and unauthorized access to privileged operations is logged. 5

Flying Circus maintains a set of permissions which enable users to perform application maintenance and other semi-privileged tasks, e.g. access to service user accounts or database administration rights. Permissions are granted to individual users upon customer request.

All permission assignments are traceable and explicitly documented: their effects are documented in the configuration code and their assignments are documented in the configuration database. A comprehensive list of users and their permissions may be produced automatically on request. 4

Group accounts are generally not allowed to perform privileged administrative operations to ensure traceability of actions.

Passwords for physical machines granting access to root accounts and IPMI controllers are stored as copies in a strongly encrypted password manager.

Transfer control

Measures for transfer control ensure that data that is being saved or transferred is protected against unauthorized reading, copying, modification, or deletion. It also requires that the points for intentional transfer are documented.

All private data transferred past the boundary of a machine must use an authenticated and encrypted communication channel (exceptions see below). Data paths where sensitive information may be transferred include:

  • Application data (e.g., database contents) is transferred from or to the customer using the standard SCP/SFTP protocol.

  • Persistent data is saved on storage servers. Storage traffic is not encrypted due to performance reasons, but storage servers are connected to application servers using a private network. Machines on which administrative privileges are granted to customers are not allowed to connect directly to the storage network (see also Network security).

  • Backups are transferred to backup servers at the same site using an encrypted communication channel or the private storage network. Backup data may also be transferred to off-site backup servers to improve disaster recovery abilities.

  • In addition to application data, a system can generate data at runtime that contains sensitive information, for example log files. Log files usually do not leave the machine on which they were generated, but may be transferred to a central log server via an encrypted channel. Only Flying Circus administrators have access to the central log server.

Input control

Measures for input control ensure that input, change, and deletion of data are documented showing at least who worked when on what data.

The security of data entry, change and deletion is generally part of the customer’s application. Customers must ensure that data entry, deletion and removal are handled appropriately according to their applicable data protection laws.

However, within the performance of maintenance work it may be necessary that administrators need to enter, change, or delete data records on a low technical level to ensure the continued operation of the overall system. This will only happen after having informed the affected customers and having documented this in our issue tracking system.

Managed log files are rotated by the Flying Circus infrastructure automatically with sensible retention times.

Changes in the Flying Circus user directory (e.g., SSH keys) can be performed by the customer themselves or through our support. If the change happens through our support hen it must be documented beforehand and confirmed by the customer after the change has been performed.

Order control

Measures for order control ensure that data is only processed according to the orders of the client.

The Flying Circus ensures that all actions taken by system administrators are covered by a contract or order with the customers affected by the action. This can be due to broad maintenance contracts or due to specific support requests.

Individual change requests must have an associated ticket in the Flying Circus request tracking system.

Specific actions performed will be reported to the customer if required.

Availability

Measures for availability ensure that data is not accidentally destroyed or lost.

The availability of resources depending on the data center facilities is delegated to the operator of the data center. The Flying Circus facilitates service level agreements to make expectations about availability explicit.

The selection of hardware is performed by the Flying Circus using professional equipment and vendors. The Flying Circus facilitates standard procedures for increased availability of single components (e.g., RAID storages, redundant power supplies, spare components).

Customer data is regularly backed up according to the Flying Circus’ backup schedule. Restoration of past states may be performed by administrators on request. Additionally, a disaster recovery plan details failure scenarios, our preventative and recovery measures.

Separation

Measures for separation ensure that data that is collected for separate purposes must be processed separately.

To separate data from different customers the Flying Circus facilitates virtualization: both virtual machines (to separate execution context) and SAN (to separate storage) ensure that customers can only access data belonging to them. Within a single machine access to different files and processes is available using standard UNIX permissions.

Machines (both virtual and physical) live in a specific access ring (short: ring):

  • Ring 0 machines perform infrastructure tasks. Thus, they need to process data belonging to several customers. Only administrator access is allowed on such machines. Examples include VM hosts and storage servers.

  • Ring 1 machines process data for a specific customer and are accessible to users associated to that customer. Examples include customer VMs.

All resources that belong logically together (e.g., VMs, storage volumes) are bundled into projects. projects share that same set of user accounts and permissions.

Footnotes

1

If a customer owns equipment managed within the Flying Circus we require that this customer uses a separate rack with separate access control.

2

This requirement was added recently and has not been implemented yet.

3

We consider not logging unsuccessful logins acceptable, as SSH logins are only valid using cryptographic private/public key authentication. Password logins are always rejected. Potential attack vectors are thus limited to stolen or cracked private keys or vulnerabilities in the SSH server software. Cracked keys are practically impossible using current technology. Known broken key formats are revoked/rejected regularly. Stolen keys or errors in the server software will not be traceable using unsuccessful login records either. On the opposite: the amount of password login tries performed nowadays (due to bot nets etc.) would cause spamming of the logging infrastructure which in turn can be a vector for DOS attacks.

4

Revoking administrator privileges is currently not a standardized process but will be added to the list of business processes soon.

5

Individual actions performed with administrative privileges are only partially logged.

6

An exception to this rule are restricted machines, which are used in exceptional cases only and operate in a separated network evironment.