cbdc:public:cbdc_omg:04_doc:15_common:50_international:10_residency
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cbdc:public:cbdc_omg:04_doc:15_common:50_international:10_residency [2022/05/16 19:38] terrance |
cbdc:public:cbdc_omg:04_doc:15_common:50_international:10_residency [2022/06/17 18:16] (current) terrance |
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| ====== 4.6.1 Data Residency ====== | ====== 4.6.1 Data Residency ====== | ||
| |< 100% >| | |< 100% >| | ||
| - | | [[cbdc:public:cbdc_omg:04_doc:15_common:48_natsec:start| Return to National Security Considerations]] | <WRAP> | + | | [[cbdc:public:cbdc_omg:04_doc:15_common:50_international:start| International Considerations]] | <WRAP> |
| <html><b> | <html><b> | ||
| - | <a href="mailto:[email protected]?Subject=OMG CBDC Response: | + | <a href="mailto:[email protected]?Subject=OMG's CBDC WG Response: |
| 4.6.1 Data Residency | 4.6.1 Data Residency | ||
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| Large multinational companies wish to consolidate data centers from multiple countries into a smaller set of locations (data center consolidation). | Large multinational companies wish to consolidate data centers from multiple countries into a smaller set of locations (data center consolidation). | ||
| </WRAP>|<WRAP> | </WRAP>|<WRAP> | ||
| - | Although a U.S.-based CBDC is not a multinational company, it is, by nature, a multinational enterprise. A summary of the multinational nature of the CBDC found in OMG [[cbdc:public:cbdc_omg:04_doc:12_summary:start| White Paper Analysis]] follows: | + | Although a U.S.-based CBDC is not a multinational company, it is, by nature, a multinational enterprise. A summary of the multinational nature of the CBDC found in OMG's CBDC WG [[cbdc:public:cbdc_omg:04_doc:12_summary:start| White Paper Analysis]] follows: |
| : 1. **''B0036''** and **''B0042''** set as a "desirement" the preservation the dominance of the U.S. Dollar internationally | : 1. **''B0036''** and **''B0042''** set as a "desirement" the preservation the dominance of the U.S. Dollar internationally | ||
| : 2. **''B0009''**, **''B0024''**, **''B0034''**, **''P0026''** express the "need for speed" | : 2. **''B0009''**, **''B0024''**, **''B0034''**, **''P0026''** express the "need for speed" | ||
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| : 6. **''D0009''** to support foreign demand | : 6. **''D0009''** to support foreign demand | ||
| </WRAP>| | </WRAP>| | ||
| - | ^ DR02 ^ <WRAP>Organizations migrate some of their services to the cloud or to a hosted solution managed by an outsourcing company located in another country. “Services” is a very broad term here, and a risk arises simply if a remote backup solution stores the backup data in another country. | + | ^ DR02 ^ <WRAP>Organizations migrate some of their services to the cloud or to a hosted solution managed by an outsourcing company located in another country. “Services” is a very broad term here, and risk arises simply if a remote backup solution stores the backup data in another country. |
| </WRAP>|<WRAP> | </WRAP>|<WRAP> | ||
| - | For the same reasons given in the explanation for **''DR01''** above, the CBDC has an implied "desirement" for cloud-based data collection and the redundancy it offers. In addition, **''B0051''**, and **''D0011''** both refer to data collection, which can cause Data Residency issues when data is from outside U.S. source. | + | For the same reasons given in the explanation for **''DR01''** above, the CBDC has an implied "desirement" for cloud-based data collection and the redundancy it offers. In addition, **''B0051''**, and **''D0011''** both refer to data collection, which can cause Data Residency issues when data is from outside U.S. sources. |
| </WRAP>| | </WRAP>| | ||
| ^ DR03 ^ <WRAP>A Business Process Outsourcing (BPO) solution, or a managed helpdesk solution, causes agents in a different country to have access to protected information in order to perform the contracted service. | ^ DR03 ^ <WRAP>A Business Process Outsourcing (BPO) solution, or a managed helpdesk solution, causes agents in a different country to have access to protected information in order to perform the contracted service. | ||
| </WRAP>|<WRAP> | </WRAP>|<WRAP> | ||
| - | Figure {{ref>bpoData}} provides a list of the top services to outsource to third Party BPOs. Some of these are relatively benign un terms of the data visibility by BPO employees. Other areas such as //"Information Technology(IT)"// and //"Claims, eligibility, and appeals processing"// might need to be addressed for any CBDC implantation. | + | Figure {{ref>bpoData}} provides a list of the top services to outsource to third Party BPOs. Some of these are relatively benign in terms of data visibility by BPO employees. Other areas such as //"Information Technology(IT)"// and //"Claims, eligibility, and appeals processing"// might need to be addressed for any CBDC implantation. |
| <figure bpoData> | <figure bpoData> | ||
| - | {{ :cbdc:private:cbdc_omg:04_doc:15_common:50_international:screen_shot_2022-04-08_at_2.22.00_pm.png?400 |}} | + | {{ cbdc:04_doc:15_common:50_international:screen_shot_2022-04-08_at_2.22.00_pm.png?400 |}} |
| <caption>Federal Managers report that BPO is used for a wide range of services(( | <caption>Federal Managers report that BPO is used for a wide range of services(( | ||
| Government Business Council, | Government Business Council, | ||
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| - Nature of the being gathered and stored by the CBDC | - Nature of the being gathered and stored by the CBDC | ||
| - | - Severity of the laws and regulations governing data in the jurisdiction where the data resides, passes through or is being manipulated | + | - Severity of the laws and regulations governing data in the jurisdiction where the data resides, passes through, or is being manipulated |
| - Nature of the services the CBDC will offer internationally | - Nature of the services the CBDC will offer internationally | ||
| - Level of awareness (or ignorance) of the issues by international communities | - Level of awareness (or ignorance) of the issues by international communities | ||
| Line 83: | Line 83: | ||
| <figure dataResidencyUseCase> | <figure dataResidencyUseCase> | ||
| - | {{:cbdc:private:cbdc_omg:04_doc:15_common:50_international:screen_shot_2022-04-08_at_12.30.15_pm.png?700|}} | + | {{cbdc:04_doc:15_common:50_international:screen_shot_2022-04-08_at_12.30.15_pm.png?700|}} |
| - | {{:cbdc:private:cbdc_omg:04_doc:15_common:50_international:screen_shot_2022-04-08_at_12.33.24_pm.png?300|}} | + | {{cbdc:04_doc:15_common:50_international:screen_shot_2022-04-08_at_12.33.24_pm.png?300|}} |
| <caption>Data Residency Use Case Matrix from the **Cloud Working Group Data Residency White Paper**.</caption> | <caption>Data Residency Use Case Matrix from the **Cloud Working Group Data Residency White Paper**.</caption> | ||
| </figure> | </figure> | ||
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| </WRAP>| | </WRAP>| | ||
| ^ **In-house** | <WRAP> | ^ **In-house** | <WRAP> | ||
| - | Data is present within the physical premises of the data custodian. Whether this is a single (computer) room, building or campus is not germane. What is germane is whether the storage, servers and network infrastructure are all privately controlled by the data custodian. As a specific case, if two locations are physically separate and connected by an Internet connection, this criterion would be violated. Examples of data sources that are in-country but not in-house are a wellsite sensor on a private owner’s oil lease and an automatic teller machine (ATM) is an International airport, on a ferry, or on a cruise ship. | + | Data is present within the physical premises of the data custodian. Whether this is a single (computer) room, building or campus is not germane. What is germane is whether the storage, servers and network infrastructure are all privately controlled by the data custodian. As a specific case, if two locations are physically separate and connected by an Internet connection, this criterion would be violated. Examples of data sources that are in-country but not in-house are a well-site sensor on a private owner’s oil lease and an automatic teller machine (ATM) is in an International airport, on a ferry, or on a cruise ship. |
| </WRAP>| | </WRAP>| | ||
| ^ **External** | <WRAP> | ^ **External** | <WRAP> | ||
cbdc/public/cbdc_omg/04_doc/15_common/50_international/10_residency.1652744305.txt.gz · Last modified: 2022/05/16 19:38 by terrance
