1. Personal Data Usage Monitor
Ivo Mehide
Degeetia OÜ

2. Personal Data Usage Monitor – why?
From the Estonian Personal Data Protection Act, §19 subsection 1:
At the request of a data subject, a processor of personal data shall communicate the following to the data subject:
...
5) third persons to whom the personal data of the data subject have been transferred
From the Estonian Personal Data Protection Act, §25 subsection 2:
3) prevent unauthorised recording, alteration and deleting of personal data and to ensure that it be subsequently possible to determine when, by whom and which personal data were recorded, altered or deleted or when, by whom and which data were accessed in the data processing system;
Solution: Registrate this kind of information and share this through common flexible software.
Procurements from Information System Authority, financed by European Regional Development Fund:
Analysis and Design of Personal Data Monitor
Development of Personal Data Monitor Standard Solution

3. Conceptual diagram

4. Components
Extractor – examines X-road messages for personal data and send general information about the messages (service code, receiving party, personal codes etc) to the Data Recorder.
Logger – stores information about the X-road messages in database and shares this to the Eesti.ee portal.
Service in eesti.ee portal – user interface for data subjects.

5. Extractor
Works as transparent proxy between infosystem and X-road security server
Contains rules of determining if transferred X-road message contains personal data.
Contains rules about how to extract general message information (receiver, timestamp, service name, etc) and personal code(s) from the message body.
Extraction rules are going to apply for all the messages that are catched by the filter. Extracted information is going to transferred to the Logger component.

6. Logger
Separate component for storing and retrieving personal data usage information.
Provides REST services for storing and retrieving.
Provides X-road service for eesti.ee portal in order to search and retrieve logged information.
Provides simple web-based UI for internal use.

7. Eesti.ee portal
Data subjects can use eesti.ee portal in order to get information from which database, when and to what third party their personal data was transferred.
Currently there are agreed to present such information from:
Elering Data Warehouse (electricity consumption points)
Population Register
Health Insurance Register
Social Services Register
Unemployment Insurance Registry

8. Different configuration options
Personal Data Usage Monitor components can be used also separately. The possible configurations are as follows:
Both Extractor and Logger components are in use.
Only Logger component is in use. Infosystem writes personal data information directly to Logger
Only Extractor component is in use. Extractor writes log information to infosystem and infosystem implements needed X-road service.
There are no Extractor and Logger components in use. Infosystem implements internally both personal data logging and corresponding X-road service.

9. Additional information
Documentation, full source code and binary packages are available on GitHub: