NUITEQ Snowflake Transfer Impact Assessment

Version Date: August 1, 2021

Background

When a lesson is uploaded to the NUITEQ Snowflake Community a copy of the Lesson is internationally transferred from the Users Profile located in Amazon Web Services (AWS) Stockholm to the NUITEQ Snowflake Community located in AWS US West.  

This transfer is subject to the Amazon Data Processing Agreement (DPA), a Transfer Impact Assessment (TIA) is shown in the Appendix 

APPENDIX 

EXPLANATORY NOTE:

It must be possible to clearly distinguish the information applicable to each transfer or category of transfers and, in this regard, to determine the respective role(s) of the Parties as data exporter(s) and/or data importer(s). This does not necessarily require completing and signing separate appendices for each transfer/category of transfers and/or contractual relationship, where this transparency can achieved through one appendix. However, where necessary to ensure sufficient clarity, separate appendices should be used.

ANNEX I

  1.   LIST OF PARTIES

MODULE ONE: Transfer controller to controller

  • NUITEQ serves as both Transfer Controller and Data Controller

MODULE TWO: Transfer controller to processor

  • NUITEQ serves as Transfer controller and Amazon AWS US West Serves as Data Processor

MODULE THREE: Transfer processor to processor

  • Amazon Stockholm serves as Transfer Processor to Amazon US West as Processor

MODULE FOUR: Transfer processor to controller

  • Amazon Stockholm serves as Transfer Processor to NUITEQ as Data Controller.

Data exporter(s): [Identity and contact details of the data exporter(s) and, where applicable, of its/their data protection officer and/or representative in the European Union]

  • Name: NUITEQ
  • Address: 11 Laboratorgrand, Skelleftea, Sweden, 93177
  • Contact person’s name, position and contact details: Edward Tse, Privacy Officer, et@nuiteq.com
  • Activities relevant to the data transferred under these Clauses: Technical Privacy Implementation
  • Signature and date: Edward Tse, July 9, 2021
  • Role (controller/processor): Data Controller

Data importer(s): [Identity and contact details of the data importer(s), including any contact person with responsibility for data protection]

  • Name: NUITEQ
  • Address: 11 Laboratorgrand, Skelleftea, Sweden, 93177
  • Contact person’s name, position and contact details: Edward Tse, Privacy Officer, et@nuiteq.com
  • Activities relevant to the data transferred under these Clauses: Technical Privacy Implementation
  • Signature and date: Edward Tse, July 9, 2021
  • Role (controller/processor): Data Controller
  1.   DESCRIPTION OF TRANSFER

MODULE ONE: Transfer controller to controller

  • NUITEQ Snowflake receives a request to upload a specific lesson activity to the Snowflake Community, a copy of the lesson is made in memory in AWS Stockholm.

MODULE TWO: Transfer controller to processor

  • AWS Stockholm transfers encrypted data from memory to the processor AWS US West.

MODULE THREE: Transfer processor to processor

  • AWS Stockholm completes the encrypted transfer from memory to AWS US West

MODULE FOUR: Transfer processor to controller

  • AWS US West updates the Snowflake Community Index so the Snowflake lesson activity is searchable. Data Control returns to NUITEQ.

Categories of data subjects whose personal data is transferred

  • Snowflake Users

Categories of personal data transferred

  • User Name, 
  • User Profile Image
  • User Identity Link (links to their profile page)

Sensitive data transferred (if applicable) and applied restrictions or safeguards that fully take into consideration the nature of the data and the risks involved, such as for instance strict purpose limitation, access restrictions (including access only for staff having followed specialised training), keeping a record of access to the data, restrictions for onward transfers or additional security measures.

  • User Data is transferred between two servers that NUITEQ Controls.

The frequency of the transfer (e.g. whether the data is transferred on a one-off or continuous basis).

  • Transfer is a one-off for the specific lesson the user chooses to upload to the Snowflake Community with awareness and consent that this data will be transferred to the US.

Nature of the processing

  • Indexing for search in the NUITEQ Snowflake Community

Purpose(s) of the data transfer and further processing

  • Indexing for search in the NUITEQ Snowflake Community

The period for which the personal data will be retained, or, if that is not possible, the criteria used to determine that period

  • Data is retained indefinitely until the user deletes the lesson from the NUITEQ Snowflake Community or makes a content change/transfer/deletion request by filling out the form at https://www.nuiteq.com/contentchange/ 

For transfers to (sub-) processors, also specify subject matter, nature and duration of the processing

  • A copy of the NUITEQ Lesson Activity is shared with Amazon AWS US West.
  1.   COMPETENT SUPERVISORY AUTHORITY

MODULE ONE: Transfer controller to controller

  • NUITEQ Data Controller initiates via a user request a NUITEQ Snowflake Community Transfer. NUITEQ serves as Transfer Controller.

MODULE TWO: Transfer controller to processor

  • NUITEQ serves as the Transfer Controller and uses Amazon Stockholm as the processor to transfer to Amazon US West that serves as the processor. 

MODULE THREE: Transfer processor to processor

  • Amazon Stockholm finishes processing the transfer and Amazon US West processes the upload by updating the NUITEQ Snowflake Community search index.

Identify the competent supervisory authority/ies in accordance with Clause 13

  • Name: NUITEQ
  • Address: 11 Laboratorgrand, Skelleftea, Sweden, 93177
  • Contact person’s name, position and contact details: Edward Tse, Privacy Officer, et@nuiteq.com
  • Activities relevant to the data transferred under these Clauses: Technical Privacy Implementation
  • Signature and date: Edward Tse, July 9, 2021
  • Role (controller/processor): Data Controller

ANNEX II

TECHNICAL AND ORGANISATIONAL MEASURES INCLUDING TECHNICAL AND ORGANISATIONAL MEASURES TO ENSURE THE SECURITY OF THE DATA

MODULE ONE: Transfer controller to controller

  • NUITEQ Data Controller initiates via a user request a NUITEQ Snowflake Community Transfer. NUITEQ serves as Transfer Controller.

MODULE TWO: Transfer controller to processor

  • NUITEQ serves as the Transfer Controller and uses Amazon Stockholm as the processor to transfer to Amazon US West that serves as the processor. 

MODULE THREE: Transfer processor to processor

  • Amazon Stockholm finishes processing the transfer and Amazon US West processes the upload by updating the NUITEQ Snowflake Community search index.

EXPLANATORY NOTE:

The technical and organisational measures must be described in specific (and not generic) terms. See also the general comment on the first page of the Appendix, in particular on the need to clearly indicate which measures apply to each transfer/set of transfers.

Description of the technical and organisational measures implemented by the data importer(s) (including any relevant certifications) to ensure an appropriate level of security, taking into account the nature, scope, context and purpose of the processing, and the risks for the rights and freedoms of natural persons.

  • Data encrypted at rest using AES-256
  • Data encrypted in transit using SSL
  • Security Officer - Johan Larsson
  • Privacy Officer - Edward Tse
  • Education Framework Privacy Assessment 4.5/5 rating
    • Student Online Privacy Protection Act (SOPPA) HB3606 Compliant 
    • Federal Educational Resource Privacy Act (FERPA) Compliant
    • Meets requirements for Data Minimisation
  • Additional Measures for Student Data
    • Parent/Guardian Consent required before creating account
    • No profile pictures
    • No email required
    • No social profiles, links, or other data
    • No ability to upload to the NUITEQ Snowflake Community
  • Pseudonymisation of non-essential tracking for performance and marketing
  • Regular monitoring for breaches, with automated notifications to senior technical staff
  • Limited access to servers
  • 2 Factor Authentication Company Policy
  • Amazon DPA and Standard Contractual Clauses for data transmission. 
  • Data Breach Notifications for stakeholders at https://www.nuiteq.com/breachnotifications 
  • Content Change form at https://www.nuiteq.com/contentchange/ 
  • More details in this presentation
  • Inventory of Data Sources
  • Data Residency Map  
  • Data Processors listed in our Privacy Policy
  • Tracking Cookies detailed in our Cookie Policy

ANNEX III

LIST OF SUB-PROCESSORS

  • Google Single Sign On (SSO) and Classroom Import
  • YouTube Embedded Video
  • Microsoft SSO and Classroom Import
  • ClassLink SSO and Classroom Import
  • Clever SSO and Classroom Import

MODULE TWO: Transfer controller to processor

  • NUITEQ opens a Single Sign on dialog when the user requests a specific single sign on provider, request is processed by the corresponding sub-processor (e.g. Microsoft SSO)

MODULE THREE: Transfer processor to processor

  • After the sign-on request is complete the sub-processor shares an email and authentication confirmation to Amazon London which begins the login process.

EXPLANATORY NOTE:

This Annex must be completed for Modules Two and Three, in case of the specific authorisation of sub-processors (Clause 9(a), Option 1).

The controller has authorised the use of the following sub-processors:

  • Name: NUITEQ
  • Address: 11 Laboratorgrand, Skelleftea, Sweden, 93177
  • Contact person’s name, position and contact details: Edward Tse, Privacy Officer, et@nuiteq.com
  • Description of processing (including a clear delimitation of responsibilities in case several sub-processors are authorised): User Login, importing student emails to create accounts and add to a NUITEQ Snowflake Classroom list