STRM Privacy and your organization
In order to start using STRM Privacy in your organization you need to organize the following:
Who decides the shape and content of your event data?
The goal of STRM Privacy is to bring clarity into your event data processing, in both the shape and rules that govern the events, as well as who uses what data.
Your organization needs to decide who is responsible for deciding over schemas (the shape of the events) as well as who is responsible for their content (the data contract). This does not have to be organization wide of course, but it’s advisable that there is clear ownership for each event stream.
The schema determines
what attributes exist on a certain type of event; think
The data contract determines the rules that govern these attributes:
- what content makes an attribute valid or invalid?
- which attribute indicates that events belong to a same entity?
- which attributes contain personal data, and what consent needs to be given to use the attribute.
Each event must conform to a certain schema, extra fields or missing mandatory fields will not be accepted by STRM Privacy. We believe that it’s generally a good idea to have data scientists or data analysts define these schemas, and not solely the teams that are responsible for sending the events. Often, it's a collaboration between producing and consuming parties, with a Data Privacy Officer (or similar) reviewing the contract.
Note that STRM Privacy has predefined public schemas that can be used by every STRM Privacy customer, but it’s also very easy to define your own event schemas.
STRM Privacy schemas must contain a
strmMeta section that defines
the consent-level(s) given by the data-owner for the processing of this event (
a field that allows retrieval of the encryption key for personal data attributes (
Determine the consent levels for handling personal data in your company
Event contents are governed by data contracts. These define among other things which attributes of an event contain personal data.
Your organization has to determine which attributes of an event schema contain personal data, and how these attributes map to the consent levels that have been chosen by your organization. These decisions are of a non-technical nature, and often correspond closely to the rules around cookie consent.
Example 1. Example consent levels
The data owner does not allow any processing of personal data. STRM Privacy removes the personal aspect of personal data attributes by encryption, and in this case, the encryption key will not be used for decryption, and will be discarded as specified by the privacy algorithm. This means that the event data can still be used for some aggregated information (like a customer journey) but it is impossible to relate these events to an individual person.
Customer allows recommendations based on an average over all customers
Customer allows personalized recommendations
Customer allows personalized email marketing
Customer allows contact by phone
This is just an example; STRM Privacy allows for very fine-grained consent configurations.
Collect the data owners consent level(s)
Every event in STRM Privacy has consent level(s) embedded, that define what consent was given by the data subject for this event. Typically, these will be the same for a whole sequence of events, but every event is handled individually, which means that if a data subject changes consent during a sequence of events, this will be taken into account.
Your organization has to set up the mechanism that will include data subject consent in the events that are sent to STRM Privacy. For events that originate in a web-browser this can generally be done from the consent cookie, but for events that originate somewhere in a back-end system, another mechanism has to be created.
Create a stream and associated credentials
Once you’ve determined all of the above, you are ready to start sending events to STRM Privacy. You need
software that collects events and creates a STRM Privacy compatible event
a console account
We provide various drivers to send data to STRM Privacy. None of these drivers are mandatory, it is possible to write your own (see here). In case a language is missing, feel free to create your own driver or contact us for assistance. All the software for interacting with STRM Privacy is open-source, there’s no magic and no vendor lock-in.
For further use of the events in your organization you have two options:
Periodically (for instance once a minute) export events to blob storage. Fully encrypted streams will be fine to use for everyone in your organization, as they no longer contain personal data.
If you have more real-time requirements, you can create a Kafka export, to allow using a standard Kafka consumer to consume events in real-time. Typical end-to-end latency is configurable, but can easily be brought under 1 second.
Assume a part of your organization requires personal data to operate. In that case one needs to
create a decrypted stream with the required consent levels
create (batch)exporters for these streams
provide those that have a need for these data with necessary credentials