Re: EU's GDPR - is anyone worrying/doing anything?

["Conlee, Keith" <conlee () COD EDU>]

Great Topic.

I pulled some language from the blog pertaining to the scope of GDPR (indented below).  Even though it says that the 
"language is quite broad and will conceivably cover almost any website on the Internet" offering goods or services and 
collecting PII on the "data subjects."  I cannot believe that it would apply to every local mom-and-pop retailer, or 
even national US-only retailer who do not "actively" offer goods or services to EU residents.  Or anything about EU 
residents actions while physically not in the EU.  But since GDPR is not effective until May 2018, no courts have 
interpreted GDPR yet.  If a local institution/company is not actively advertising in the EU (e.g. spending advertising 
$$$ in the EU), my non-expert opinion is that they should not be "in-scope" of the GDPR just because someone in the EU 
can find their website and order goods/services to be shipped (name and address are PII), or take an online class.  
Said another way, just because you can find a US-only website to purchase goods/services should not put website owner 
in scope of GDPR.   Yes we go through great pains to protect all of our student data, but right now it may not be GDPR 
compliant.  But I will definitely pass this on to our general counsel to research further and for a more expert 
analysis.

Maybe you can disclaim being Non-GDPR compliant if you only “actively” advertise (versus “passively” advertise just by 
virtue of having a website on the internet) in the US (or smaller region).  The disclaimer could warn EU residents 
about an institution/company maybe not being GDPR compliant in the event someone googles a product or service and finds 
it available at a US-only advertising company/institution.   Again, IMHO.  Again, I will pass to our general counsel.  
And it will be for the courts to decide.  Who wants to be the first guinea pig ☺ (some humor).


      The GDPR applies to any organization established outside of the EU that processes any personally identifiable 
data (called "personal data" in the GDPR) about residents of the EU (called "data subjects" in the GDPR) when that 
processing is related to either:

            a) "the offering of goods or services, irrespective of whether a payment of the data subject is required, 
to such data subjects in the Union; or

            b) the monitoring of their behaviour as far as their behaviour takes place within the Union."

      This language is quite broad and will conceivably cover almost any website on the Internet that is globally 
available, offers goods or services, and collects personal information of any kind.




Keith Conlee, JD, MS/BS, PCIP, CISSP, CISA, CBCP
Chief Security Officer, IT
College of DuPage
425 Fawell Blvd.
Glen Ellyn, IL 60137-6599

Ph. - 630.942.3055
conlee () cod edu


-----Original Message-----
From: The EDUCAUSE Security Constituent Group Listserv [mailto:SECURITY () LISTSERV EDUCAUSE EDU] On Behalf Of SECURITY 
automatic digest system
Sent: Monday, August 21, 2017 11:00 PM
To: SECURITY () LISTSERV EDUCAUSE EDU
Subject: SECURITY Digest - 18 Aug 2017 to 21 Aug 2017 (#2017-143)

There are 4 messages totalling 462 lines in this issue.

Topics of the day:

  1. EU's GDPR - is anyone worrying/doing anything? (4)

----------------------------------------------------------------------

Date:    Mon, 21 Aug 2017 17:56:23 +0000
From:    Joanna Grama <jgrama () EDUCAUSE EDU<mailto:jgrama () EDUCAUSE EDU>>
Subject: Re: EU's GDPR - is anyone worrying/doing anything?

Hello everyone,
I promised to update you all as GDPR materials are published.  Please note that a Security Matters blog on GDPR was 
published last week.  You can find that blog here:  http://er.educause.edu/blogs/2017/8/gdpr-a-data-regulation-to-watch

For those of you attending the EDUCAUSE Annual Conference, you can find information on the GDPR session here: 
https://events.educause.edu/annual-conference/2017/agenda/the-new-eu-general-data-protection-regulations-what-it-specialists-need-to-know
(Session information is in the process of being uploaded; but the date/time information is correct.)

Kind regards,
Joanna


Joanna Grama, JD, CISSP, CRISC, CIPT
Director of Cybersecurity and IT GRC Programs

EDUCAUSE
Uncommon Thinking for the Common Good
282 Century Place, Suite 5000, Louisville, CO 80027
direct: 720.406.6769 | cell: 720.507.5983 | jgrama () educause edu<mailto:jgrama () educause edu>


-----Original Message-----
From: The EDUCAUSE Security Constituent Group Listserv [mailto:SECURITY () LISTSERV EDUCAUSE EDU] On Behalf Of Joanna 
Grama
Sent: Tuesday, June 06, 2017 8:31 AM
To: SECURITY () LISTSERV EDUCAUSE EDU<mailto:SECURITY () LISTSERV EDUCAUSE EDU>
Subject: Re: [SECURITY] EU's GDPR - is anyone worrying/doing anything?

Hi Everyone,
EDUCAUSE is working to marshal some GDPR resources for IT professionals.  The National Association of College and 
University Attorneys (NACUA) will be presenting a panel presentation on GDPR at the EDUCAUSE Annual Conference this 
fall. In addition, our policy director, Jarret Cummings, is working with another organization to source some blogs and 
other online content about GDPR.  As materials are published, I will be sure to send an alert to this list.

Kind regards,
Joanna


Joanna Grama, JD, CISSP, CRISC, CIPT
Director of Cybersecurity and IT GRC Programs

EDUCAUSE
Uncommon Thinking for the Common Good
282 Century Place, Suite 5000, Louisville, CO 80027
direct: 720.406.6769 | cell: 720.507.5983 | jgrama () educause edu<mailto:jgrama () educause edu>






-----Original Message-----
From: The EDUCAUSE Security Constituent Group Listserv [mailto:SECURITY () LISTSERV EDUCAUSE EDU] On Behalf Of Jim 
Dillon
Sent: Monday, June 5, 2017 1:12 PM
To: SECURITY () LISTSERV EDUCAUSE EDU<mailto:SECURITY () LISTSERV EDUCAUSE EDU>
Subject: Re: [SECURITY] EU's GDPR - is anyone worrying/doing anything?

Laura,

No plans (solid/documented/complete) I'm aware of yet, but our compliance audit manager is fairly concerned about its 
potential impact and we are gathering opinions and researching the topic.  Her sense is we will need to take steps to 
comply.  Not being a legal expert myself I'm always in jurisdictional quandaries about regulations from other nations 
and in other states (remember California's privacy rules?) and how those could have tangible impact, but so far people 
closer to this issue than I believe it to be real.  Since CU is very heavily reaching out to international students we 
may have this problem to a greater degree than others.

Sorry nothing specific to report other than it does pay to pay attention here.  I suggest taking this to compliance and 
legal folks for interpretation as they will (or should) have a more sound understanding of the implications.  My 
impression is that if we advertise and register students in GDPR nations we are definitely accountable for any actions 
there, and that given the typical Internet jurisdictional concerns, we probably are here as well.  I don't have a 
handle on what that means from an operational standpoint yet but it looks a bit onerous to me at the moment.  Yet 
another set of demands to add to your favorite cross-walk.

Might be a good question for the privacy/policy forums if you don't mind cross-posting a bit.

Best regards,

Jim Dillon

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Jim Dillon Director of IT Audit Services, CU Internal Audit
303-735-7028

-----Original Message-----
From: The EDUCAUSE Security Constituent Group Listserv [mailto:SECURITY () LISTSERV EDUCAUSE EDU] On Behalf Of Laura 
Raderman
Sent: Monday, June 05, 2017 10:48 AM
To: SECURITY () LISTSERV EDUCAUSE EDU<mailto:SECURITY () LISTSERV EDUCAUSE EDU>
Subject: [SECURITY] EU's GDPR - is anyone worrying/doing anything?

Is there any institution that’s worried about or otherwise doing anything about the GDPR and getting ready for the May 
2018 “deadline”?  If so, would you be willing to give me a quick overview of what you’re including in your plans?

Thanks,
Laura

Laura Raderman
ISO Policy & Compliance Coordinator
Carnegie Mellon University
lraderman () cmu edu<mailto:lraderman () cmu edu>

------------------------------

Date:    Mon, 21 Aug 2017 14:08:35 -0500
From:    Ken Connelly <ken.connelly () UNI EDU<mailto:ken.connelly () UNI EDU>>
Subject: Re: EU's GDPR - is anyone worrying/doing anything?

Joanna -

Seems as though this would be a worthwhile topic for Security Professionals Conference as well, although next April is 
clearly too late to begin planning for this.

- ken

On 8/21/17 12:56 PM, Joanna Grama wrote:
> Hello everyone,
> I promised to update you all as GDPR materials are published.  Please
> note that a Security Matters blog on GDPR was published last week.
> You can find that blog here:
> http://er.educause.edu/blogs/2017/8/gdpr-a-data-regulation-to-watch
>
> For those of you attending the EDUCAUSE Annual Conference, you can
> find information on the GDPR session here:
> https://events.educause.edu/annual-conference/2017/agenda/the-new-eu-g
> eneral-data-protection-regulations-what-it-specialists-need-to-know
> (Session information is in the process of being uploaded; but the
> date/time information is correct.)
>
> Kind regards,
> Joanna
>
>
> Joanna Grama, JD, CISSP, CRISC, CIPT
> Director of Cybersecurity and IT GRC Programs
>
> EDUCAUSE
> Uncommon Thinking for the Common Good
> 282 Century Place, Suite 5000, Louisville, CO 80027
> direct: 720.406.6769 | cell: 720.507.5983 | jgrama () educause edu<mailto:jgrama () educause edu>
>
>
> -----Original Message-----
> From: The EDUCAUSE Security Constituent Group Listserv
> [mailto:SECURITY () LISTSERV EDUCAUSE EDU] On Behalf Of Joanna Grama
> Sent: Tuesday, June 06, 2017 8:31 AM
> To: SECURITY () LISTSERV EDUCAUSE EDU<mailto:SECURITY () LISTSERV EDUCAUSE EDU>
> Subject: Re: [SECURITY] EU's GDPR - is anyone worrying/doing anything?
>
> Hi Everyone,
> EDUCAUSE is working to marshal some GDPR resources for IT professionals.  The National Association of College and 
> University Attorneys (NACUA) will be presenting a panel presentation on GDPR at the EDUCAUSE Annual Conference this 
> fall. In addition, our policy director, Jarret Cummings, is working with another organization to source some blogs 
> and other online content about GDPR.  As materials are published, I will be sure to send an alert to this list.
>
> Kind regards,
> Joanna
>
>
> Joanna Grama, JD, CISSP, CRISC, CIPT
> Director of Cybersecurity and IT GRC Programs
>
> EDUCAUSE
> Uncommon Thinking for the Common Good
> 282 Century Place, Suite 5000, Louisville, CO 80027
> direct: 720.406.6769 | cell: 720.507.5983 | jgrama () educause edu<mailto:jgrama () educause edu>
>
>
>
>
>
>
> -----Original Message-----
> From: The EDUCAUSE Security Constituent Group Listserv
> [mailto:SECURITY () LISTSERV EDUCAUSE EDU] On Behalf Of Jim Dillon
> Sent: Monday, June 5, 2017 1:12 PM
> To: SECURITY () LISTSERV EDUCAUSE EDU<mailto:SECURITY () LISTSERV EDUCAUSE EDU>
> Subject: Re: [SECURITY] EU's GDPR - is anyone worrying/doing anything?
>
> Laura,
>
> No plans (solid/documented/complete) I'm aware of yet, but our compliance audit manager is fairly concerned about its 
> potential impact and we are gathering opinions and researching the topic.  Her sense is we will need to take steps to 
> comply.  Not being a legal expert myself I'm always in jurisdictional quandaries about regulations from other nations 
> and in other states (remember California's privacy rules?) and how those could have tangible impact, but so far 
> people closer to this issue than I believe it to be real.  Since CU is very heavily reaching out to international 
> students we may have this problem to a greater degree than others.
>
> Sorry nothing specific to report other than it does pay to pay attention here.  I suggest taking this to compliance 
> and legal folks for interpretation as they will (or should) have a more sound understanding of the implications.  My 
> impression is that if we advertise and register students in GDPR nations we are definitely accountable for any 
> actions there, and that given the typical Internet jurisdictional concerns, we probably are here as well.  I don't 
> have a handle on what that means from an operational standpoint yet but it looks a bit onerous to me at the moment.  
> Yet another set of demands to add to your favorite cross-walk.
>
> Might be a good question for the privacy/policy forums if you don't mind cross-posting a bit.
>
> Best regards,
>
> Jim Dillon
>
> _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Jim Dillon
> Director of IT Audit Services, CU Internal Audit
> 303-735-7028
>
> -----Original Message-----
> From: The EDUCAUSE Security Constituent Group Listserv
> [mailto:SECURITY () LISTSERV EDUCAUSE EDU] On Behalf Of Laura Raderman
> Sent: Monday, June 05, 2017 10:48 AM
> To: SECURITY () LISTSERV EDUCAUSE EDU<mailto:SECURITY () LISTSERV EDUCAUSE EDU>
> Subject: [SECURITY] EU's GDPR - is anyone worrying/doing anything?
>
> Is there any institution that’s worried about or otherwise doing anything about the GDPR and getting ready for the 
> May 2018 “deadline”?  If so, would you be willing to give me a quick overview of what you’re including in your plans?
>
> Thanks,
> Laura
>
> Laura Raderman
> ISO Policy & Compliance Coordinator
> Carnegie Mellon University
> lraderman () cmu edu<mailto:lraderman () cmu edu>

--
- Ken
=================================================================
Ken Connelly                       Director, Information Security
Information Security Officer          University of Northern Iowa
email: Ken.Connelly () uni edu<mailto:Ken.Connelly () uni edu>   p: (319) 273-5850 f: (319) 273-7373

Any request to divulge your UNI password via e-mail is fraudulent!

------------------------------

Date:    Mon, 21 Aug 2017 20:31:12 +0000
From:    Joanna Grama <jgrama () EDUCAUSE EDU<mailto:jgrama () EDUCAUSE EDU>>
Subject: Re: EU's GDPR - is anyone worrying/doing anything?

Absolutely, Ken.

The call for proposals for the Security Professionals Conference will open in two short weeks.  If your institution has 
been looking into GDPR and has implemented a GDPR plan or process, your colleagues would LOVE it if you would share 
your knowledge at the conference.

Information about how to submit a proposal will be posted to this list when the call for proposals opens.

Thanks,
Joanna


-----Original Message-----
From: The EDUCAUSE Security Constituent Group Listserv [mailto:SECURITY () LISTSERV EDUCAUSE EDU] On Behalf Of Ken 
Connelly
Sent: Monday, August 21, 2017 3:09 PM
To: SECURITY () LISTSERV EDUCAUSE EDU<mailto:SECURITY () LISTSERV EDUCAUSE EDU>
Subject: Re: [SECURITY] EU's GDPR - is anyone worrying/doing anything?

Joanna -

Seems as though this would be a worthwhile topic for Security Professionals Conference as well, although next April is 
clearly too late to begin planning for this.

- ken

On 8/21/17 12:56 PM, Joanna Grama wrote:
> Hello everyone,
> I promised to update you all as GDPR materials are published.  Please
> note that a Security Matters blog on GDPR was published last week.
> You can find that blog here:
> http://er.educause.edu/blogs/2017/8/gdpr-a-data-regulation-to-watch
>
> For those of you attending the EDUCAUSE Annual Conference, you can
> find information on the GDPR session here:
> https://events.educause.edu/annual-conference/2017/agenda/the-new-eu-g
> eneral-data-protection-regulations-what-it-specialists-need-to-know
> (Session information is in the process of being uploaded; but the
> date/time information is correct.)
>
> Kind regards,
> Joanna
>
>
> Joanna Grama, JD, CISSP, CRISC, CIPT
> Director of Cybersecurity and IT GRC Programs
>
> EDUCAUSE
> Uncommon Thinking for the Common Good
> 282 Century Place, Suite 5000, Louisville, CO 80027
> direct: 720.406.6769 | cell: 720.507.5983 | jgrama () educause edu<mailto:jgrama () educause edu>
>
>
> -----Original Message-----
> From: The EDUCAUSE Security Constituent Group Listserv
> [mailto:SECURITY () LISTSERV EDUCAUSE EDU] On Behalf Of Joanna Grama
> Sent: Tuesday, June 06, 2017 8:31 AM
> To: SECURITY () LISTSERV EDUCAUSE EDU<mailto:SECURITY () LISTSERV EDUCAUSE EDU>
> Subject: Re: [SECURITY] EU's GDPR - is anyone worrying/doing anything?
>
> Hi Everyone,
> EDUCAUSE is working to marshal some GDPR resources for IT professionals.  The National Association of College and 
> University Attorneys (NACUA) will be presenting a panel presentation on GDPR at the EDUCAUSE Annual Conference this 
> fall. In addition, our policy director, Jarret Cummings, is working with another organization to source some blogs 
> and other online content about GDPR.  As materials are published, I will be sure to send an alert to this list.
>
> Kind regards,
> Joanna
>
>
> Joanna Grama, JD, CISSP, CRISC, CIPT
> Director of Cybersecurity and IT GRC Programs
>
> EDUCAUSE
> Uncommon Thinking for the Common Good
> 282 Century Place, Suite 5000, Louisville, CO 80027
> direct: 720.406.6769 | cell: 720.507.5983 | jgrama () educause edu<mailto:jgrama () educause edu>
>
>
>
>
>
>
> -----Original Message-----
> From: The EDUCAUSE Security Constituent Group Listserv
> [mailto:SECURITY () LISTSERV EDUCAUSE EDU] On Behalf Of Jim Dillon
> Sent: Monday, June 5, 2017 1:12 PM
> To: SECURITY () LISTSERV EDUCAUSE EDU<mailto:SECURITY () LISTSERV EDUCAUSE EDU>
> Subject: Re: [SECURITY] EU's GDPR - is anyone worrying/doing anything?
>
> Laura,
>
> No plans (solid/documented/complete) I'm aware of yet, but our compliance audit manager is fairly concerned about its 
> potential impact and we are gathering opinions and researching the topic.  Her sense is we will need to take steps to 
> comply.  Not being a legal expert myself I'm always in jurisdictional quandaries about regulations from other nations 
> and in other states (remember California's privacy rules?) and how those could have tangible impact, but so far 
> people closer to this issue than I believe it to be real.  Since CU is very heavily reaching out to international 
> students we may have this problem to a greater degree than others.
>
> Sorry nothing specific to report other than it does pay to pay attention here.  I suggest taking this to compliance 
> and legal folks for interpretation as they will (or should) have a more sound understanding of the implications.  My 
> impression is that if we advertise and register students in GDPR nations we are definitely accountable for any 
> actions there, and that given the typical Internet jurisdictional concerns, we probably are here as well.  I don't 
> have a handle on what that means from an operational standpoint yet but it looks a bit onerous to me at the moment.  
> Yet another set of demands to add to your favorite cross-walk.
>
> Might be a good question for the privacy/policy forums if you don't mind cross-posting a bit.
>
> Best regards,
>
> Jim Dillon
>
> _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Jim Dillon
> Director of IT Audit Services, CU Internal Audit
> 303-735-7028
>
> -----Original Message-----
> From: The EDUCAUSE Security Constituent Group Listserv
> [mailto:SECURITY () LISTSERV EDUCAUSE EDU] On Behalf Of Laura Raderman
> Sent: Monday, June 05, 2017 10:48 AM
> To: SECURITY () LISTSERV EDUCAUSE EDU<mailto:SECURITY () LISTSERV EDUCAUSE EDU>
> Subject: [SECURITY] EU's GDPR - is anyone worrying/doing anything?
>
> Is there any institution that’s worried about or otherwise doing anything about the GDPR and getting ready for the 
> May 2018 “deadline”?  If so, would you be willing to give me a quick overview of what you’re including in your plans?
>
> Thanks,
> Laura
>
> Laura Raderman
> ISO Policy & Compliance Coordinator
> Carnegie Mellon University
> lraderman () cmu edu<mailto:lraderman () cmu edu>

--
- Ken
=================================================================
Ken Connelly                       Director, Information Security
Information Security Officer          University of Northern Iowa
email: Ken.Connelly () uni edu<mailto:Ken.Connelly () uni edu>   p: (319) 273-5850 f: (319) 273-7373

Any request to divulge your UNI password via e-mail is fraudulent!

------------------------------

Date:    Mon, 21 Aug 2017 15:51:05 -0500
From:    Ken Connelly <ken.connelly () UNI EDU<mailto:ken.connelly () UNI EDU>>
Subject: Re: EU's GDPR - is anyone worrying/doing anything?

Yeah, I'm a consumer on this one, not a provider...

- ken

On 8/21/17 3:31 PM, Joanna Grama wrote:
> Absolutely, Ken.
>
> The call for proposals for the Security Professionals Conference will open in two short weeks.  If your institution 
> has been looking into GDPR and has implemented a GDPR plan or process, your colleagues would LOVE it if you would 
> share your knowledge at the conference.
>
> Information about how to submit a proposal will be posted to this list when the call for proposals opens.
>
> Thanks,
> Joanna
>
>
> -----Original Message-----
> From: The EDUCAUSE Security Constituent Group Listserv
> [mailto:SECURITY () LISTSERV EDUCAUSE EDU] On Behalf Of Ken Connelly
> Sent: Monday, August 21, 2017 3:09 PM
> To: SECURITY () LISTSERV EDUCAUSE EDU<mailto:SECURITY () LISTSERV EDUCAUSE EDU>
> Subject: Re: [SECURITY] EU's GDPR - is anyone worrying/doing anything?
>
> Joanna -
>
> Seems as though this would be a worthwhile topic for Security Professionals Conference as well, although next April 
> is clearly too late to begin planning for this.
>
> - ken
>
> On 8/21/17 12:56 PM, Joanna Grama wrote:
> > Hello everyone,
> > I promised to update you all as GDPR materials are published.  Please
> > note that a Security Matters blog on GDPR was published last week.
> > You can find that blog here:
> > http://er.educause.edu/blogs/2017/8/gdpr-a-data-regulation-to-watch
> >
> > For those of you attending the EDUCAUSE Annual Conference, you can
> > find information on the GDPR session here:
> > https://events.educause.edu/annual-conference/2017/agenda/the-new-eu-
> > g eneral-data-protection-regulations-what-it-specialists-need-to-know
> > (Session information is in the process of being uploaded; but the
> > date/time information is correct.)
> >
> > Kind regards,
> > Joanna
> >
> >
> > Joanna Grama, JD, CISSP, CRISC, CIPT
> > Director of Cybersecurity and IT GRC Programs
> >
> > EDUCAUSE
> > Uncommon Thinking for the Common Good
> > 282 Century Place, Suite 5000, Louisville, CO 80027
> > direct: 720.406.6769 | cell: 720.507.5983 | jgrama () educause edu<mailto:jgrama () educause edu>
> >
> >
> > -----Original Message-----
> > From: The EDUCAUSE Security Constituent Group Listserv
> > [mailto:SECURITY () LISTSERV EDUCAUSE EDU] On Behalf Of Joanna Grama
> > Sent: Tuesday, June 06, 2017 8:31 AM
> > To: SECURITY () LISTSERV EDUCAUSE EDU<mailto:SECURITY () LISTSERV EDUCAUSE EDU>
> > Subject: Re: [SECURITY] EU's GDPR - is anyone worrying/doing anything?
> >
> > Hi Everyone,
> > EDUCAUSE is working to marshal some GDPR resources for IT professionals.  The National Association of College and 
> > University Attorneys (NACUA) will be presenting a panel presentation on GDPR at the EDUCAUSE Annual Conference this 
> > fall. In addition, our policy director, Jarret Cummings, is working with another organization to source some blogs 
> > and other online content about GDPR.  As materials are published, I will be sure to send an alert to this list.
> >
> > Kind regards,
> > Joanna
> >
> >
> > Joanna Grama, JD, CISSP, CRISC, CIPT
> > Director of Cybersecurity and IT GRC Programs
> >
> > EDUCAUSE
> > Uncommon Thinking for the Common Good
> > 282 Century Place, Suite 5000, Louisville, CO 80027
> > direct: 720.406.6769 | cell: 720.507.5983 | jgrama () educause edu<mailto:jgrama () educause edu>
> >
> >
> >
> >
> >
> >
> > -----Original Message-----
> > From: The EDUCAUSE Security Constituent Group Listserv
> > [mailto:SECURITY () LISTSERV EDUCAUSE EDU] On Behalf Of Jim Dillon
> > Sent: Monday, June 5, 2017 1:12 PM
> > To: SECURITY () LISTSERV EDUCAUSE EDU<mailto:SECURITY () LISTSERV EDUCAUSE EDU>
> > Subject: Re: [SECURITY] EU's GDPR - is anyone worrying/doing anything?
> >
> > Laura,
> >
> > No plans (solid/documented/complete) I'm aware of yet, but our compliance audit manager is fairly concerned about 
> > its potential impact and we are gathering opinions and researching the topic.  Her sense is we will need to take 
> > steps to comply.  Not being a legal expert myself I'm always in jurisdictional quandaries about regulations from 
> > other nations and in other states (remember California's privacy rules?) and how those could have tangible impact, 
> > but so far people closer to this issue than I believe it to be real.  Since CU is very heavily reaching out to 
> > international students we may have this problem to a greater degree than others.
> >
> > Sorry nothing specific to report other than it does pay to pay attention here.  I suggest taking this to compliance 
> > and legal folks for interpretation as they will (or should) have a more sound understanding of the implications.  My 
> > impression is that if we advertise and register students in GDPR nations we are definitely accountable for any 
> > actions there, and that given the typical Internet jurisdictional concerns, we probably are here as well.  I don't 
> > have a handle on what that means from an operational standpoint yet but it looks a bit onerous to me at the moment.  
> > Yet another set of demands to add to your favorite cross-walk.
> >
> > Might be a good question for the privacy/policy forums if you don't mind cross-posting a bit.
> >
> > Best regards,
> >
> > Jim Dillon
> >
> > _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Jim Dillon
> > Director of IT Audit Services, CU Internal Audit
> > 303-735-7028
> >
> > -----Original Message-----
> > From: The EDUCAUSE Security Constituent Group Listserv
> > [mailto:SECURITY () LISTSERV EDUCAUSE EDU] On Behalf Of Laura Raderman
> > Sent: Monday, June 05, 2017 10:48 AM
> > To: SECURITY () LISTSERV EDUCAUSE EDU<mailto:SECURITY () LISTSERV EDUCAUSE EDU>
> > Subject: [SECURITY] EU's GDPR - is anyone worrying/doing anything?
> >
> > Is there any institution that’s worried about or otherwise doing anything about the GDPR and getting ready for the 
> > May 2018 “deadline”?  If so, would you be willing to give me a quick overview of what you’re including in your plans?
> >
> > Thanks,
> > Laura
> >
> > Laura Raderman
> > ISO Policy & Compliance Coordinator
> > Carnegie Mellon University
> > lraderman () cmu edu<mailto:lraderman () cmu edu>
> --
> - Ken
> =================================================================
> Ken Connelly                       Director, Information Security
> Information Security Officer          University of Northern Iowa
> email: Ken.Connelly () uni edu<mailto:Ken.Connelly () uni edu>   p: (319) 273-5850 f: (319) 273-7373
>
> Any request to divulge your UNI password via e-mail is fraudulent!

--
- Ken
=================================================================
Ken Connelly                       Director, Information Security
Information Security Officer          University of Northern Iowa
email: Ken.Connelly () uni edu<mailto:Ken.Connelly () uni edu>   p: (319) 273-5850 f: (319) 273-7373

Any request to divulge your UNI password via e-mail is fraudulent!

------------------------------

End of SECURITY Digest - 18 Aug 2017 to 21 Aug 2017 (#2017-143)
***************************************************************