For security reasons and to guarantee the continuity of your services it is necessary to have a backup system that allows you to restore a single data or the entire system at a given time identified as stable and not corrupt.
Why make the backup
A data or a file or the entire file system or a service or the entire corporate network could be corrupt or no longer usable for several reasons:
- due to an error by an employee or operator;
- for problems with the software;
- because the file system is corrupt;
- due to hardware problems;
- for a computer virus or for the intrusion of a hacker;
- for a structural disaster or for a natural disaster.
Furthermore, if you have sensitive data based on the GDPR it is necessary to have a backup system:
- safe, better if the data is encrypted with secure algorithms before being saved;
- always active so that all updates are available;
- easy to restore in a short time and therefore necessarily the availability of data even in the event of a physical or technical accident;
- a procedure (better if written and detailed) of how to restore the system. This procedure should be tested regularly;
All this is present in section 2 (Security of personal data) in article 32 of the GDPR:
Security of processing
1. Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, the controller and the processor shall implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate:…
(a) the pseudonymisation and encryption of personal data;
(b) the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
(c) the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;
(d) a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.
2. In assessing the appropriate level of security account shall be taken in particular of the risks that are presented by processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed.
Types of backups
We can implement the backup in different ways based on the customer’s choice such as:
- backup to local disk (but in this way we will be at risk of operator and virus or hardware problems);
- backup on corporate or remote NAS;
- remote backup using software such as NetBackup or similar;
- on a cloud space such as Amazon S3 or Glacier or others.
For each type of backup, if necessary, to comply with point 1a of article 32 of the GDPR we will provide for the “pseudonymisation” (see Article 4 – Definitions of the GDPR for the meaning) of the files and data encryption.
Once the type of backup has been defined, we will set the time policies in which all or part of the data will be copied, that is when to make a complete backup or when to do only the incremental so as to be in good standing even with the GDPR.
Backup recovery tests
At this point the backup is done but we have to test it to see if it is correct.
Therefore, we will restore everything in a parallel environment (possibly on equivalent virtual machines) with both full and incremental backups.
If problems are encountered during recovery due to backup, we fix it until the desired result is achieved.
To comply with Article 32 of the GDPR in point 1c and 1d we would produce a document that describes the functioning of the
backup, its recovery and the estimated time to perform these operations.