I’ve had a request to copy production data into a test environment to resolve an issue today. Since we’ve had problems with this before, and perhaps it hasn’t always been clearly communicated, I’m writing this mail to explain AMOS Thailand’s policy on this issue.
It’s very simple – production data containing private customer information cannot be copied directly into test or development environments under any circumstances.
This is a legal issue, and we can create big problems for ourselves if we do this. In many countries, data privacy laws explicitly prohibit this practice. Even despite the legal issues, we can create issues for ourselves by allowing unauthorised access to private information.
We had an incident earlier this year where an internal client requested production data be copied into test in order to resolve an issue. This was approved by the client and went ahead without the knowledge of our management team. As a result, emails were accidently sent out to Allianz customers from the test system. Infrastructure people had to work the entire weekend to solve this issue. Then we had to create an incident report that was sent to Munich explaining what had gone wrong. The company narrowly avoided having to report the incident to the European government.
I understand in many cases, it is difficult to resolve production issues without having access to production data. In this situation, what has to be done is to write a script to mask the personal data. So, for example, you might turn paul.knapp@allianz.com into xxxxxx.yyyyy@allianz.com. This script can then be run by the infrastructure team with access to the production data against a copy of it before putting it into a test environment. If you are using this approach, please be careful to make sure all personal data is masked.
You should also only copy the sub-set of the data you need to solve the particular issue, instead of copying across the whole database.
I know this might be a pain and cause short-term delays in resolving issues. But we can’t take risks with this kind of thing. Data privacy is becoming a big issue around the world, and it’s important we take it seriously. Our clients in Allianz should have this explained to them if they make requests for production data copies, as they will also be at risk if we have an incident.
Thanks and please feel free to ask any questions.