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SonicWall and GDPR

On May 25, the General Data Protection Regulation (GDPR) will officially go into effect. Like with any major legal reform, questions arise about timing, application, ramifications and more. With the GDPR mandate’s focus on privacy and related data, questions have increased tenfold.

SonicWall is working hard to ensure compliance with GDPR requirements. SonicWall takes information security seriously and has implemented policies and procedures for safeguarding personal data that is stored, processed and/or transferred by SonicWall. 

These policies and procedures include, without limitation, physical and logical access restrictions, data classification, access rights, credentialing programs, record retention, data privacy, information security and the treatment of personal data and sensitive personal data throughout its lifecycle.

To help clarify how SonicWall products and services are impacted by GDPR policies, please review the following.
 

What is the GDPR?


The GDPR is legislation enacted by the European Union (EU) to protect all EU citizens from privacy and data breaches. The GDPR applies to companies and organizations located in the EU, as well as to companies outside the EU that collect, use, transmit or store personal data of EU citizens, regardless of where the activities take place. At a high level, GDPR:
  • Takes effect on May 25, 2018
  • Applies generally to organizations located in the EU, as well as those outside the EU that handle the personal data of EU citizens
  • Applies specifically to data controllers and data processers; with a controller being a company that determines the purposes and means of processing personal data, while a processor is responsible for processing personal data on behalf of a controller
  • Is designed to protect the personal data of EU citizens, which is defined as any information about an identifiable person
  • Requires organizations to give individuals access to and control over their data, and to take reasonable measures to protect it

Does the GDPR apply to SonicWall products?


Yes, but only to a very limited extent. SonicWall products help customers enable security in their networks (and to thus better comply with the GDPR), but SonicWall generally does not have access to, nor does it collect or use, the personal data of individuals.

The GDPR, therefore, does not apply to SonicWall products in most cases. Our customers’ use of our products by itself does not subject SonicWall to GDPR.

However, if SonicWall hosts a solution that is sold to a customer and the hosted solution allows a customer to access or use personal data in that hosted environment, then SonicWall may be subject to certain aspects of the GDPR. In those cases, SonicWall must ensure that adequate security is in place to protect that hosted environment.

In summary:
  • SonicWall typically does not collect, store or transmit the personal data of natural individuals in the EU
  • The GDPR does not apply to SonicWall firewall hardware appliances without a subscription to the SonicWall Capture Advanced Threat Protection sandbox service
  • GDPR may apply to the SonicWall Capture Cloud Platform to the extent it enables end-user designated personnel to access their network data in an environment hosted by SonicWall
  • Where GDPR applies, it requires SonicWall to have adequate network security for its hosted environment
  • SonicWall expects to be compliant with the GDPR by May 25, 2018, to the extent it applies to the company’s range of security solutions and services
  • SonicWall is undertaking a comprehensive third-party audit to confirm the compliance of its products and solutions
 

GDPR and SonicWall hosted solutions


Presently, SonicWall directly maintains a majority of the systems used for our hosted solutions versus outsourcing this activity to a third party. In the limited circumstances that SonicWall leverages third party services, SonicWall works to ensure that it and its third-party provider have the appropriate safeguards in place to protect personal data as required by GDPR. SonicWall uses a number of technological and operational approaches in its physical security program to mitigate security risks to the extent reasonably practicable.

Our team is working to determine that appropriate measures are in place to prevent unauthorized persons from gaining access to systems within which data is processed and continually monitor any changes to the physical infrastructure, business and known threats.

We are also considering best practice measures used by others in the industry while balancing its approach toward security by considering elements of control that include architecture, operations and systems.
SonicWall customers are given the opportunity to choose the location of their primary data center where their information will be hosted. However, limited data may be transferred to other SonicWall locations for the purpose of providing services to our customers.
 

Can SonicWall help companies become GDPR-compliant?


SonicWall acts as a provider of network security and content-based security solutions, and security of data is a key aspect in achieving data privacy principles.

We assist companies to secure their data in a smarter way. In the wake of burgeoning legislation and increased hacker intelligence, it is vital for organizations to encrypt their traffic and files, whether these are stored online or offline.  Using high-performance Deep Packet Inspection, SonicWall can spot malware and other nefarious traffic and behavior from among encrypted files, further safeguarding an organization.

SonicWall provides industry-leading machine learning technology to detect and block zero-day malware. We address advanced cyber threats, “malware cocktails” and related ransomware no matter if they are encrypted or clear, in email, on the web or in file exchange and regardless of the device in use. Our expertise in automated breach prevention means we don’t just spot malware, we prevent attacks from becoming successful.

To learn more about how GDPR applies to SonicWall products and services, please review the official SonicWall Privacy Statement.
 

I need a Data Protection Agreement. What do I need to do?


If SonicWall hosts a SonicWall-branded solution and the hosted solution allows you to access or use personal data in that hosted environment, then SonicWall may be subject to certain aspects of the General Data Protection Regulation (GDPR). In those cases, you may download and sign our Data Protection Agreement (DPA) using our online version found here .
 

Who are your Sub-Processors, what do you use them for, and where are they located?


The sub-processors we use that are relevant to our hosted products depend on the specific SonicWall products and services you use. You may view our sub-processor list by clicking here.
 

Who can I contact if I have additional questions?


You may contact SonicWall directly by sending an email to dataprivacy@sonicwall.com or you may contact your sales representative.


General Disclaimer: The information on the SonicWall website is not an exhaustive review of all elements of the Regulation, nor is it legal advice. Please seek guidance from your own legal consultants.  

 
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