Be aware of the risks that are intrinsically linked to most IoT systems
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It is necessary to take account key aspects of the IoT application when defining its functionality and the potential impact on data protection, such as:

  • Generally, there is a part for data collection or to provide information for the IoT application or services, so the security of the data collected must be managed.
  • The processing or analysis of these data usually takes place in very remote locations in the cloud and, to be able to reach them, it is necessary to use shared networks, public networks, etc. This aspect has an impact on the protection of the data stored and in motion managed in person by the development team or by a third party.
  • It is becoming increasingly common for IoT applications to be hyper connected with other ones, from either the same manufacturer or developers or a different one, creating large networks of IoT devices. It is thus necessary to consider the security of data shared or accessible by third parties.
  • The integration with third parties ensures compatibility with other products and grants the application greater versatility and functionality, but on the other hand it makes necessary to define a procedure to assess the security of components provided by external suppliers.
  • The interaction between the human “user” and the “product machine” is present and special attention must be paid to ensure a satisfactory user experience while not compromising security.
  • The security assessment of the IoT application should include technical tests such as code review and penetration testing. Penetration testing helps to check the security level of the system, early detection and, in case of failures, to fix possible errors that may affect data security during implementation in order to mitigate or minimize risks before moving to production. Penetration testing is a very efficient test during the evaluation phase because it subjects solutions to the same threats, they might face during the normal operation of an IoT application. As part of so-called ethical hacking, these tests aim to uncover weaknesses in the system that could be exploited in the future by a hacker.
Box 11:

An IoT application that makes it possible to control lightbulbs remotely from a mobile device, supported by wireless communications by means of the protocol or specification Zigbee, and that at the same time uses a gateway to connect to the Internet, can be a useful example of the key aspects for consideration for the functionality mentioned above.

Checklist: data subjects’ rights

☐ The controllers have introduced the necessary procedures to ensure that the data subject rights are adequately satisfied, no matter if they are the end-users or third parties.

☐ The controllers have introduced the necessary procedures to ensure that the data subject rights are satisfied in time (maximum one month after request).

☐ The controllers have introduced efficient tools to ensure that data subjects are able to exercise their rights in a practical manner, for instance by introducing data interoperability standards.

☐ Data subjects are in a position to have access to all their personal data, including the raw data that are registered by IoT devices

☐ The IoT developers have implemented tools to locally read, edit and modify the data before they are transferred to any data controller. Furthermore, personal data processed by a device is stored in a format allowing data portability

☐ The controllers have introduced tools able to communicate rectified data to each recipient to whom the personal data has been disclosed, unless this proves impossible or involves disproportionate effort.

☐ The controllers have introduced tools able to ensure that all data are efficiently deleted at the data subjects’ request if there are no lawful reasons to oppose to that request.

☐ The controllers have ensured that withdrawal schemes should be fine grained and should cover:

(1) any data collected by a specific thing;

(2) a specific type of data collected by anything;

(3) a specific data processing.

☐ Data subjects are offered the option to disable the “connected” feature of the thing and allow it to work as the original, unconnected item (i.e. disable the smart watch or glasses connected functionality).

☐ IoT developers have introduced user-friendly interface for users who want to obtain both aggregated data and/or raw data that they still store. These tools enable data subjects to easily export their data in a structured and commonly used format.

☐ The controllers have documented all the information regarding these issues.


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