This is the GDPR statement of the UK e-Science CA. It clarifies the existing statement of data protection description in Section C of the CP in terms of the GDPR principles. The data processing itself should not change with the introduction of the GDPR.
The CA processes user identity data to enable the user to obtain a certificate compliant with the IGTF CEDAR profile.
Fair and Lawful processing of data
The UK e-Science CA processes data for, and only for, the purpose of providing end users with IGTF-compliant certificates. Some organisations use the same data for other purposes which falls outside the scope of the UK e-Science CA. The RA operators must pass a training course test before they can be allowed to process data. The CA goes through regular checks (with its PMA) of compliance.
Use for Purpose for which it was Collected
The data protection statement in the CP describes the purposes and permitted use of the data. The summary is that data is used (a) to validate user’s identity against that requested in a DN, (b) to maintain a traceable link from the DN to the user’s real-life identity throughout the lifetime of the certificate and for a period thereafter, (c) to prevent the issuance of a certificate with a given DN to a person who is not the first person to whom it was assigned.
Adequate and relevant
Historically, the IGTF requirements has been “reliable photo id and/or official documents,” presented an authorised approver - the RA - in a face-to-face meeting to . In order to comply with IGTF requirements, the RA will usually keep a photo copy of this document. In order to minise the data exposure, the preferred id is an organisational photo id.
Accurate and Up to Date
The data is kept up to date by reissuing the certificate once a year; the reissuance process should include a data check in the approval process.
Not kept for longer than necessary
The IGTF CEDAR profile states that the data should be held for two years after the expiry (or revocation) of the last certificate to which it applies.
All connections between the user and the CA, and between the RA operator and the issuing authority, are done using secure protocols. RA operators are instructed to keep their records securely.