GDPR: Protect Personally Identifiable Information
To help your organization protect the personally identifiable information (PII) of resources,
Classic PPMincludes data protection features. The availability of these new features coincides with the May 2018 General Data Protection Regulation (GDPR) in the European Union. GDPR is also included in the United Kingdom Data Protection Act. Compliance is required from any international firm with ties to data in the European Union.
GDPR data protection laws were enacted to provide EU citizens in all member states with greater control over their personal data. Businesses that compromise or misuse personal data are subject to possible fines. To mitigate these risks, including hacking, data breaches, and other cyber threats,
Classic PPMallows administrators to anonymize (randomize or scramble) specific PII data for inactive resources.
CAUTION: This feature permanently protects certain data by scrambling it. Access to original data is irretrievably lost. As an administrator, it is your responsibility to make a secure backup, if permitted by your security policies, before using this feature.
GDPR: Feature Highlights
Installation: Install the new content items for personally identifiable information (PII) from the PMO Accelerator. Installation is handled for SaaS customers. On-premise customers can decide when to install the content, or to decline.
Configuration: To organize the subset of attributes subject to protection, add any new attributes that you create for resource anonymization to this list. By default, the application is configured to anonymize the following attributes for inactive resources that you select: resource ID, resource full name, resource first name, resource last name, resource email address, and username. The complete list of obfuscated data appears further down this page.
New Protected Attributes: You can create a custom attribute on the
Resourceobject in Studio. These optional steps are not new. They are not shown on this page. Click
Objectsand filter the object list to open the
Resourceobject. For example, create an attribute for the last four digits of a personal ID number or a five-digit pin. Then click
PII Attributes. Add your new attribute to the
Personally Identifiable Information (PII) Attribute Listpage.
User Access: Configure the personal attributes on a page where other authorized users can access them. We recommend that you keep them together for easy access. For example, you want resource managers to edit a personal pin number or to set the
Anonymize Personally Identifiable Information (PII)check box. In this example, we add the
Anonymize Personally Identifiable Information (PII)and
PII Last Anonymized Dateto the right-side of the
Generalsection of the
Manage Protection: Authorized users, for example resource managers, can select the
Anonymize Personally Identifiable Information (PII)check box to flag this resource for protection. The next time an administrator runs the
Anonymize Personally Identifable Information (PII)job, the
Resource Settingspage will show the date in the
PII Last Anonymized Datefield. Unless you plan on anonymizing
allresources, to apply protections you must clear the
Activecheck box. Typically, only
inactiveresources are subject to anonymization.
Administration: The lead system administrator configures the availability of the Anonymize Personally Identifiable Information (PII) job. They answer the following important questions:
Who can run this job?
Can those authorized users anonymize only inactive resources who are flagged for protection?
Can those authorized users anonymize all resources?
Do the data protection policies in place at my organization warrant such use?To anonymize all resources, the system administrator clears the read-only constraint on the parameter appropriately named
WARNING! Anonymize ALL Resources. The administrator makes an optional secure backup. Before the job runs, an administrator determines if that instance of the job is going to scramble only the subset of selected inactive resources, or all resources.
Administration: The administrator runs the Anonymize Personally Identifable Information (PII) job with the following check box selected:
Anonymize Only Inactive Resources with Anonymize PII Selected. The job scrambles
onlythe personal attributes of the
inactiveresources that also have their
Anonymize Personally Identifiable Information (PII)check box selected.
Protection: After all these levels of security, the designated resources show a serialized coded value to protect their original data which is now obfuscated forever. In the example above, two resources continue to show their historic resource manager assignment. However, Cheryl Amos now appears throughout the application as
Verify that you have backed up all your resource data before you run the Anonymize Personally Identifiable Information (PII) job. When you run this job, the resource data is permanently obfuscated. You cannot undo this operation. CA Support and Broadcom Service partners cannot help retrieve lost data unless you made a reliable backup. A backup is helpful if you are testing the feature and want to restore data, or you accidentally obfuscated data that you want to restore. However, you might need to encrypt, obfuscate, or purge the backup to comply with your security policies or other regulations.
Install the PII Content Items
The PMO Accelerator add-in is required. The content items for on-premise customers are automatically installed in new environments when you install the PMO Accelerator; however, upgrading customers can choose when to perform these steps.
Follow these steps:
- Log in toClassic PPMas an administrator.
- ClickAdministration,Studio,Content Add-ins.
- Open theAccelerator - Program Management Officeadd-in and click theItemstab.
- In theContent Item Namefilter field, enter*pii*The following content items appear:Anonymize PII - JobPII Attribute - LookupPII Attribute Filter View - ViewPII Attribute List View - ViewPII Attribute Object - ObjectPII Attribute Property Views - ViewPII Attributes - Menu
- Select all seven items and clickInstall.The items show aStatusofInstalled.
Create Custom Attributes for Personally Identifiable Information
You can create a custom attribute on the Resource object in Studio.
- Filter the object list to open theResourceobject.
- Click theAttributestab.
- Create an attribute. For example, create an attribute for the last four digits of a personal ID number or a five-digit pin. Anonymization supports the following custom attribute types: string, large string, number, date, and URL. Custom object attachments are not included. See theStudiodocumentation in theReferencesection of the English edition of the documentation.
- ClickHome,Custom Attributes,PII Attributes. Add your new attribute to the Personally Identifiable Information (PII) Attribute List page.
You can also use the XOG to import custom attributes in bulk.
After you anonymize a resource, you do not have to continue to mark them for repeated scrambling. Anonymized resources are automatically re-anonymized when you add a new custom attribute to the list of protected data. The logical explanation is that the resource has already been flagged for protection of all personal data.
Add Personally Identifiable Information Fields to a Page Layout
You can organize the personal information in one convenient place.
- Filter the object list and open theResourceobject.
- Click theViewstab.
- Click[Layout-Edit]setup for theResource Laborview.
- ChooseSettings,Generalpage or, for stronger security, use a secure subpage.We recommend that you add the personal data attributes to a subpage and set access rights to protect the subpage.
- Click theProperties and Layouticon.
- Add theAnonymize Personally Identifiable Information (PII)andPII Last Anonymized Datefields.
- ClickSave and Return.
Select the Protected Resources
Advise resource managers and other users with access rights that they can now flag one or more resources for protection.
- ClickHome,Resource Management,Resources.
- Open a labor resource. You can anonymize only resources of typelabor.
- The resource manager can select theAnonymize Personally Identifiable Information (PII)check box to flag this resource for protection.
- ThePII Last Anonymized Dateshows1/1/1900by default.After you run the Anonymize Personally Identifable Information (PII) job, thePII Last Anonymized Datefield displays the date. TheAnonymize Personally Identifiable Information (PII)check box is cleared.
- In the future, you can select the check box again. For example, you add a new attribute with personal data and would like to anonymize it for the selected resource.
Seeded admin resources are not anonymized. The system does not allow you to anonymize the admin and csk.admin (PMO Accelerator) users.
Run the Job to Scramble the Data
As a prerequisite, set up DBLINK. The job fails without DBLINK.
Verify that you have backed up all your resource data before you run the Anonymize Personally Identifiable Information (PII) job. When you run this job, the designated personal resource data is permanently obfuscated. You cannot undo this operation. CA Support and Broadcom Service partners cannot help you retrieve lost data unless you made a reliable secure backup.
- ClickHome,Reports and Jobs, and click theJobstab.
- Run or schedule the Anonymize Personally Identifable Information (PII) job.TheResource Settingspage shows the updatedPII Last Anonymized Date.
- To anonymize the same data in the data warehouse, run the Load Data Warehouse job in full mode. An incremental load is not sufficient for pushing out the changes in resource data.
Attachments for Anonymized Resources
The feature handles any attachments on the resource object. However, attachment custom attributes for the resource object or subobjects are not available for selection in the PII Attribute object lookup.
Instead of scrambling data in attachments, they are deleted. Attachments include any files that the user uploaded, even their personal avatar image.
- The Anonymize Personally Identifable Information (PII) job flags resource custom attributes defined as attachments to be purged.
- The Purge Documents job purges these documents for all anonymized resources. The job purges the attachments of all protected resources whenever it runs. The job parameters you select for projects or other criteria do not limit this behavior.
- Exception: Any attachments in custom attributes for resource subobjects are not flagged or purged.
Database and Data WareHouse Fields With Personal Data
The following schema tables and fields are subject to obfuscation. In other words, these attributes can be protected by replacing the original data with an encoded serialized number.
Disclaimer: CA is not responsible for protected data that you anonymize and later decide you want to retrieve.