Recently, I have been talking about GDPR in the context of SharePoint project sites for a construction company building houses. What practical design choices should we make for the new SharePoint template we are developing, combined with instructions to our users? Let us take a look at five of them.
In a previous post we talked about the Office 365 security and compliance GDPR dashboard, that can help us detect and manage sensitive information after it has been stored in our Office 365 tenant. But it is better to think beforehand and aim for privacy by design. We should only store and process personal data if we have a clear purpose for it. And only for the people who do need these data, for as long as they need it.
1.Don’t use personal data if you can keep it abstract
In their building projects, the houses are bought by real people, who have real personal data. In the project site, information has to be shared about the construction of the individual houses: which kitchen options should be included, what work remains to be done for that house, et cetera. However, there is no need to refer to these houses by the names of the buyers.
So we don’t list a house as the one bought by Mr and Mrs Smith, but at the house with building number 32. And we explain to all users that we avoid using personal data unless it is absolutely necessary to get the job done and we can justify sharing these personal data.
2.Put documents with personal data in a clearly marked, separate, secured library
We do have some cases where some project team members do need to see personal data in order to do their jobs, like commercial team members who need to talk to the house owners and renovation architects who need to see photos of the original rooms the may display personal belongings.
So we have a separate document library for the house owner documents, which is clearly marked as such. That library is listed in the site menu under the heading ‘Sensitive’. And only the project team members who need to use these data have permission to enter the library. We explain to our users where they have to store and find these documents, and that if they don’t see the library, they do not have permission to open it.
3.Only share the personal details that are needed, nothing else
We have a secured list of the contact details of the owners of the houses that are being built, so that project members who need to get in touch with these people know how to reach them. In the past, that list also included fields to share information about the spouses, children, hobbies, et cetera. Somebody got inspired by customer relationship management and got carried away… That information is quite irrelevant for the construction job.
So we trimmed down the list in our site template, to contain only the fields relevant for the job. This way, our users understand that they should not include other personal data.
4.Only allow individuals to access personal data. Not AD-groups
In parts of their project sites, all employees in the business unit or even all employees in the company can see the information. For example, the basic project information is visible to all, for transparency in the organization. For these “high visibility” lists and libraries, access is managed by way of AD-groups that include everyone in that unit. However, you cannot easily see who is part of that “everyone group”.
So in lists and libraries that contain personal data, we do not allow security by way of AD groups. We tell the site owners that they have to add individual users to the SharePoint permission groups, to explicitly and purposefully give those people access.
5.Delete personal data no longer needed after the project
After the building project is finished, some personal data may be needed by the aftercare people. But we should not keep personal data just in case somebody may be interested in them someday…
So we remove the permissions on the personal data for the users who are no longer involved in the finished. And we delete the personal data that do not have to be kept for a clear purpose. For example, we need to keep the data of the companies involved as subcontractors, but we do not need the phone numbers of the individual people. So we keep a companies list for the project relations, but not the people contacts lists.
All in all, we are baking some privacy measures into our SharePoint template for construction projects. We are giving the site owners and end users specific instructions. And we are creating awareness, that we need to be careful with personal data.
