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Cisco Spaces is an indoor location services cloud platform that provides wireless customers with rich location-based services, including location analytics, business insight, customer experience management, asset tracking, Bluetooth Low Energy (BLE) management, and API.
It provides a single point of entry for all location technology and intelligence through a single dashboard interface. Cisco Spaces delivers the industry’s most scalable location-based marketing platform, all while being compatible across existing Cisco Catalyst or Meraki infrastructure.
Following are key stakeholders who develop, support, host, and consume the functionalities of the Cisco Spaces solution:
● Individual (also referred as “data subject”) – The data subject is an identifiable natural person to whom the data relates. The data subject is the final consumer of the Cisco Spaces features and functionality.
● Customer (also referred as “data controller”) – The data controller can be a person, organization, or an entity that owns and exercises control over the personal data that is collected. A data controller can determine how the data is collected and the manner in which the data will be processed. For the Cisco Spaces solution, the customer is the data controller.
● Cisco (also referred as “data processor”) – The data processor is an entity or an organization that processes the collected data on behalf of the data controller. For the Cisco Spaces solution, Cisco is the data processor, which processes the da-ta on behalf of the customer. At Cisco, the DevOps and the engineering teams are involved in the data processing and operational activities.
◦ DevOps – The primary responsibility of the DevOps team is to manage and monitor the cloud infrastructure and the platform hosted in the Amazon Web Services (AWS) cloud.
◦ Engineering – The engineering team is responsible for creating the solution architecture, technical design and implementation, testing, and deployment of the Cisco Spaces solution. The team currently follows the Cisco Secure Development Lifecycle (CSDL) process, which is designed to increase the resiliency and trustworthiness of Cisco offerings, while developing new applications or making enhancements to the existing applications. The Quality Assurance (QA) team, which is part of the engineering team is responsible for testing the product functionality and performing security testing of the Cisco Spaces solution.
Personal data records and its use, collection, and retention
Personal data is any information relating to an identified or identifiable natural person (end user). Information can include a name, location data, or one or more factors specific to the physical, genetic, mental, economic, cultural, or social identity of that natural person.
What data does Cisco Spaces collect?
Personal data collection and its purpose is solely determined by the customer (data controller), who provides the data to Cisco (data processor) for processing. Cisco collects and processes the non-sensitive personal data on behalf of customer. The Cisco Spaces solution:
● Does not collect any special category of personal data, such as race, ethnic background, political opinions, genetic data, biometric data, health data, etc.
● Does not intentionally collect any personal data from minors, as minors are disallowed from using the Cisco Spaces solution.
● Collects only the non-sensitive personal data through the network (MAC address). This data collection is optional and in certain cases, the customer may decide to collect additional data from users.
What does Cisco Spaces do with the collected data?
The non-sensitive personal data collected via the Cisco Spaces platform is essential for implementing the customer solution, such as report generation, trend and data analytics, etc. The underlying restrictions on the purposes of the collected data are applied as per the agreements with the data controller. Restrictions are bound by the commitments provided to the customer (data controller) with respect to the use and retention of the non-sensitive personal data. The data retention activity is based on the agreements with the customer, and as governed by local laws and compliance with prevailing regulations.
Privacy compliance by Cisco Spaces
● Cisco Spaces customers expect and rely upon Cisco to protect their data and privacy. Hence, it is mandatory to provide data protection and implement privacy controls on the collected data.
● The Cisco Spaces solution has adopted the Cisco Secure Development Lifecycle (CSDL) process, which helps to ensure the Cisco Spaces cloud solution adheres to predefined Cisco security requirements and standards.
● The Cisco Spaces solution has achieved Cloud Approval To Operate (CATO) compliance as per the process outlined in the Cloud Security Progression Plan.
● One of the keys to maintaining CATO compliance is to ensure that the data protection and secure operations of the Cisco Spaces solution adheres to industry standards and certifications, such as ISO 27001, GDPR compliance, etc.
● CATO makes sure all the secure operations of the Cisco Spaces solution follow:
◦ Adherence to industry standards and best practices
◦ Include cyber security controls such as privacy impact assessments
◦ Implement privileged access control mechanisms
◦ Implement authentication and authorization mechanisms
◦ Manage security incident responses
◦ Adopt cryptography controls and encryption mechanisms
◦ Implement secure development process
◦ Monitor logging and auditing control mechanisms
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