Hello,
On Sun, Jan 31, 2010 at 09:56:41PM +0000, Dee Earley wrote:
One of my customers had an issue with data protection
recently (not
website or IT related) and have had to review everything (a right PITA!).
This covers me as I host the their website with a database of registered
users.
Right.
I understand you have access to my server, both to the
file system, and
root on the server itself with the backup SSH key.
While I trust you and accept that you won't do anything malicious,
Could you give something "official" or update your DPA page covering any
access you have to the VPS and its associated data?
http://www.bitfolk.com/policy/dpa.html
Okay. It depends what you want to see. Let's go through the ways
in which BitFolk staff need to use your data first..
- Your outgoing traffic is automatically sniffed for SSH SYN packets
in order to automatically detect SSH scanning activity. Time,
source IP, source port, destination IP is stored. It isn't
reviewed by a human unless an alert fires, and it's considered the
customer's personal information.
- If there is any sort of abuse report or indication of possible
abusive activity, or a problem with the customer's service or any
other sort of operational need, we sometimes need to be able to
sniff the customer's traffic in order to work out what is going
on. We don't want to have to ask for permission before doing that.
Any data stored is deleted once the problem is worked out, and
it's again considered personal information.
- If your VPS is not responding or is using an abnormal amount of
disk IO then we need to be able to look at the customer's console
output to see if it's properly locked up, if it's in an OOM death
spiral, etc. Again we don't want to have to ask permission.
Now, as regards the actual data on the customer's VPS, we don't
consider it personal data in the same sense as the Data Protection
Act defines personal data. The customer's filesystem data isn't
data that BitFolk has collected about the customer, and we don't
store and process this data for our own purposes. It's whatever the
customer happened to put on a service provided to them.
- Customer data may be automatically accessed for backup purposes,
and moved between hosts as required. If the customer makes use of
the backup service then it will be duplicated one or more times
for that. When the customer's contract ends (or is broken by the
customer) we may decide to keep the data for up to 3 months before
deleting it. If requested it will be deleted as soon as the
contract ends. Backups will be deleted immediately.
- If the customer's service has been or is likely to have been
compromised and abusive behaviour has been detected, the first
step is to prevent the abuse from leaving the virtual machine.
This is usually accomplished by turning off its network or
applying firewalling. Next we expect the customer to work out
what has gone wrong.
If the customer is unable/unwilling to work out what's gone wrong
then we have to make a call between looking ourselves or saying
goodbye to the customer, because it's pointless setting up a new
VPS if we don't know how it got compromised. If we decided to
investigate this for the customer then we would ask for permission
to look through their OS and possibly data.
- We can't explicitly list every possible operational situation that
would require us to access your data, so it is always possible
that something new will happen. In general except where detailed
above we will try to ask permission first.
In terms of what it is POSSIBLE to access, the customer should
consider that all of their data is accessible to anyone with root on
the hardware they are hosted on. The block devices can be directly
read, even encrypted block devices can have their keys read out of
guest memory.
If you're making use of the backup service then you have most likely
given root access by SSH key. You can narrow that down to specific
hosts, and
http://troy.jdmz.net/rsync/ contains a script you can use
to allow access through an SSH key that can only call rsync.
If this is what you were looking for I can tidy it up a bit and add
it to the dpa page.
Cheers,
Andy
--
http://bitfolk.com/ -- No-nonsense VPS hosting
"The electric guitar - like making love - is much improved by a little
feedback, completely ruined by too much." -- The League Against Tedium