For PID(s): UT:32AEI
This document is intended to help you in your preparations for GDPR readiness. It provides information about features of WebSphere Configuration Migration Tool for IBM Cloud (WCMT4IC) that you can configure, and aspects of the product’s use, that you should consider to help your organization with GDPR readiness. This information is not an exhaustive list, due to the many ways that clients can choose and configure features, and the large variety of ways that the product can be used in itself and with third-party applications and systems.
Clients are responsible for ensuring their own compliance with various laws and regulations, including the European Union General Data Protection Regulation. Clients are solely responsible for obtaining advice of competent legal counsel as to the identification and interpretation of any relevant laws and regulations that may affect the clients’ business and any actions the clients may need to take to comply with such laws and regulations.
The products, services, and other capabilities described herein are not suitable for all client situations and may have restricted availability. IBM does not provide legal, accounting, or auditing advice or represent or warrant that its services or products will ensure that clients are in compliance with any law or regulation.
Table of Contents
- Product Configuration for GDPR
- Data Life Cycle
- Data Collection
- Data Storage
- Data Access
- Data Processing
- Data Deletion
- Data Monitoring
This is a supplemental document to the WebSphere Configuration Migration Tool for IBM Cloud documentation.
General Data Protection Regulation (GDPR) has been adopted by the European Union and will apply from May 25, 2018.
Why is GDPR important?
GDPR establishes a stronger data protection regulatory framework for processing of personal data of individuals. GDPR brings:
- New and enhanced rights for individuals
- Widened definition of personal data
- New obligations for companies and organisations handling personal data
- Potential for significant financial penalties for non-compliance
- Compulsory data breach notification
Read more about GDPR
Product Configuration – Considerations for GDPR Readiness
The following sections provide considerations for configuring WebSphere Configuration Migration Tool for IBM Cloud to help your organization with GDPR readiness.
Configuration to support data handling requirements
The WebSphere Configuration Migration Tool for IBM Cloud wizard is not configurable in a manner which affects how the tool collects, processes, or transfers the WebSphere Configuration data. The configuration data can contain sensitive information which needs to be protected. The wizard collects and process the WebSphere Configuration data in work directories on the local machine. The customer can be assured that the data collected is handled properly and removed promptly after the data is uploaded to the IBM Cloud’s Object Store. When the data is uploaded to the IBM Cloud it is stored encrypted in a secure location only accessible by the ‘WebSphere Application Server’ service bound to the specific migration request. It will remain in Object Store until the user deletes the ‘WebSphere Application Server’ service or a successful migration occurs when the IBM Cloud virtual machines are provisioned.
As noted above there are no user configurable settings to control the collection, handling and uploading of the WebSphere configuration data.
Data Life Cycle
The data collected and processed by the ‘WebSphere Configuration Migration Tool for IBM Cloud’ is the entire configuration data for a WebSphere Cell, including installed applications. After selecting the WebSphere cell, the tool guides the customer in collecting and uploading the configuration data for each node in the cell. The node’s configuration data is stored encrypted in a temporary location in the IBM Cloud until either the provisioning process completes successfully or the customer cancels the requested service. Contained within the configuration data is user id and password information. To protect this data, the tool automatically deletes any locally collected configuration data once it has been uploaded to the IBM Cloud. In addition, consideration must also be given when the configuration data is collected from a remote machine and processed locally. This is a manual process and the customer is very aware of the creation and transmission of this configuration data from the remote machine to the local machine. For convenience, the tool understands that the configuration data is from a remote machine and will not automatically delete it, but instead will prompt the customer as to whether they would like to delete it.
If WebSphere global security is enabled, the tool requires the WebSphere administrator’s user id and password be supplied. This is to allow the administrative server to be temporarily shut down so that the configuration data can be collected. See the WebSphere WASPreUpgrade command for more details. The administrator’s user id and password also are required by the WASPostUpgrade command which is run as part of provisioning process on the IBM Cloud. The provisioning process sets up the IBM Cloud virtual machines and completes the WebSphere migration process. This administrative user id and password is stored encoded within the zip file that is encrypted and uploaded to the temporary location on the IBM Cloud. The customer will only gain access to these virtual machines if the migration process competes successfully. The customer is in control of deleting this request at which time all configuration data in the IBM cloud for this request is deleted. If the migration completes successfully, all temporary files on the IBM Cloud virtual machine are cleaned up. In the end the customer is left with their old WebSphere environment completely intact and functional, and with their new cloned WebSphere Cell running in the IBM Cloud.
See the Data Life Cycle section above.
See the Data Life Cycle section above.
The WebSphere Configuration Migration Tool for IBM Cloud must be started with a system user id which has access to the WebSphere installations containing the cells to be migrated. In addition, the user will need the WebSphere administrative user id and password if global security is enabled in that cell. These user ids give the tool proper access to collect and upload the data on the local machine. The tool also requires an IBM Cloud Account, otherwise it will not proceed forward to the point where it collects the configuration data. All the data is cleaned up as it is processed and uploaded to the IBM Cloud. Once in the IBM Cloud it is encrypted and stored in a secure location which is only accessible by the IBM Cloud service created by the tool. It is accessed by the provisioning process and is cleaned up when successful. The data is also cleaned up when the IBM Cloud service is deleted or turned back in.
When error situations occur, IBM Support will ask the customer to run the tool with options to preserve the the configuration data in order for it to be analyzed. In those instances the customer may want to protect their WebSphere user id and password information. This is similar to the traditional WebSphere migration process used for on premises to on premises migrations. For issues involving the functionality of the WebSphere Configuration Migration Tool for IBM Cloud wizard itself, it does not involve any sensitive data which needs to be protected.
See the Data Life Cycle section above.
At any time during the on premises to IBM Cloud migration process the configuration data for any node uploaded to the IBM Cloud can be deleted by simply turning in the IBM Cloud WebSphere Application Server service that was created for the migration. If the cell has been successfully provisioned the configuration data was already deleted from the temporary location.
The WebSphere Configuration Migration Tool for IBM Cloud logs events during the on premises to IBM Cloud migration process. The data does not include writing any user ids or passwords to the logs. Log on information the IBM Cloud is also protected and is cleared from memory once access is established.