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For a number of reasons, including remote accessibility, my company would like to move all of our accounting records, account applications, and marketing materials to Google’s Apps for Work Drive. At first glance, this sounds like a pretty bad idea, but I don't have the firsthand knowledge or reasons to argue a case against it.

The information stored includes banking information, names, and addresses; as well as SSNs, mostly in the form of PDF documents.

Can we legally host our files with Google Drive, who would be responsible for the costs associated with a breach in access, and is the amount of risk worth the increased accessibility?

Documents provided by Google support:

  • 10
    Probably not desirable to make it so breaking into a single google account grants access to all that information, just as an initial thought. – Trotski94 Oct 12 '15 at 14:27
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    here, in Switzerland, it would be illegal to do so due to data protection law and the fact that Dropbox uses US-based data centers. – Stephane Oct 12 '15 at 14:33
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    every PC/Laptop/Smartphone that has access to this Google Drive is a liability. – JOW Oct 12 '15 at 14:33
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    Thank you, these were also my thoughts as well. I also read on an EDU site there was an issue because we cannot guarantee only US employees will have access to the documents. I don't have any hard facts though – epool Oct 12 '15 at 14:36
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    I'm presuming you're in the US due to the use of SSNs. I am betting (though not a lawyer) that there are restrictions on export of data in the US (Certainly is here in the UK). You would have to be able to guarantee the data staying in the US (possibly in the same state, I don't know). In short, you'd need a lawyer to ensure this is compliant. – Chris Murray Oct 12 '15 at 15:53
48

Google Drive is no more or less safe than any other web-based service with a single logon. Your company must decide for itself whether it is willing to put the data online (albeit behind Google's authentication)

At the very least, I'd recommend that

  1. 2-factor authentication is used
  2. Any data travelling outside the organisation is encrypted.

Google Drive is presumably fairly secure, but as we saw with iCloud, people can (and do) sometimes get access to systems they shouldn't be able to access.

One piece of advice a tutor at university gave me was:

Treat anything that isn't behind your firewall as though it was on a USB pen you'd just left on a train

Meaning: assume that it may fall into the wrong hands, and ensure that you've taken sufficient precautions to make it useless to them.

(In fact, I'm a fan of treating things that are behind my firewall the same...)

Edit

To add to the "liability" question:

This is mostly a matter of what is stated in the contracts, agreements (EULA or ToS etc) etc between you and Google, and potentially you and any third parties who the data belongs to. Note that this doesn't just include clients/customers, it also includes your staff, if you are storing their personally identifiable information in the cloud - so this could not only cause financial issues, but also destroy employee trust if there is a breach! Your bank may also refuse to reimburse any money lost if bank details are stored in the cloud, as this could be considered negligence.

In general, though: unless specifically stated, at least some liability will always remain with you. Some liability may or may not fall upon Google for data breaches etc, but this will depend on the agreement. You will still be liable for any third party data, however, in as much as you have chosen to entrust it to a third party.

If there was a data breach, it would then become a (likely very long and drawn out!) legal question, and would revolve around whether either Google or yourself were negligent, the nature of your agreement, and whether you both took any and all reasonable steps to protect that data.

I think the crux of your question is "Will Google take responsibility for the security of data on Google Drive" to which the answer is "No, probably not". But I am not a lawyer, nor do I play one on TV.

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    2-factor authentication is useful for preventing people guessing your password. Although this helps significantly with the main weakness of online services, it does nothing if someone malicious gains access to the storage behind Google Drive (ie they break into Google's system directly). If you have sensitive data, you should still encrypt it. – Jon Story Oct 12 '15 at 14:46
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    It's also worth noting it doesn't protect someone from a compromised device after its been authenticated. E.g. someone who has synced our documents on a computer than later becomes infected or compromised. – epool Oct 12 '15 at 15:04
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    Given current security practices, I'd say that you should treat ANYTHING as about as secure as on a flash drive that you lost on a train. Firewalls don't just magically save you. Look no further than Sony, the NSA, the US Military, Ashley-Madison and countless other major data spills for evidence of that. – Steve Sether Oct 12 '15 at 20:44
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    The same will happen to Google since they don't live in the magic world where probability equal to 0 exists, do they. – daniel Azuelos Oct 13 '15 at 22:30
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    Data stored on Google Drive is, in fact, "data traveling outside the organization." – Craig Oct 14 '15 at 6:19
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This answer may not directly relate to your question who is held liable for data leakage.

I would not store any unencrypted, sensitive data on google drive, even if they just use your data to operate, promote and improve their Services. From Google's Terms of Service:

When you upload, submit, store, send or receive content to or through our Services, you give Google (and those we work with) a worldwide licence to use, host, store, reproduce, modify, create derivative works (such as those resulting from translations, adaptations or other changes that we make so that your content works better with our Services), communicate, publish, publicly perform, publicly display and distribute such content. The rights that you grant in this licence are for the limited purpose of operating, promoting and improving our Services, and to develop new ones.

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    Great find! This is a good argument in itself. Specifically this part bring a large amount of concern; > publicly display and distribute such content – epool Oct 12 '15 at 19:11
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    @edward.pool There are other cloud storage providers that claim to encrypt your data on your PC before they upload it to their cloud, e.g. MEGA. – mucaho Oct 12 '15 at 19:20
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    @mucaho but with MEGA I'd be worried about the authorities taking them down and your data with it. – Chris H Oct 13 '15 at 9:05
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    MEGA is the successor to megaupload, which was taken down by the authorities for hosting copyright infringement. Its founder is still a target for law enforcement from that case. I suggest that despite their use of encryption, they are more vulnerable than the likes of Google and Microsoft to having the whole site taken down at short notice. After all, users leaking encryption keys could easily demonstrate what's being hosted. – Chris H Oct 13 '15 at 11:24
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    Be aware that even Dotcom says not to trust Mega any more. wired.co.uk/news/archive/2015-07/31/kim-dotcom-mega-3 – kirb Oct 13 '15 at 22:42
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Storing sensitive data outside of a private network is always a risk.

It's much more easy for malicious users to get access to the data. Using fishing techniques, or if you log on your account on an infected computer, or even worse if your computer gets infected a malicious user could get access to your credentials and use them to access the data. Since Google servers are available on the web it wouldn't be hard to connect and do some damage.

On the other hand if you keep the sensitive data in a private network it's always harder to access the data even if the malicious users have the credentials, because they would have to enter your network first.

To help avoiding situations like that, a two-factor authentication is allways recommended. Unless the malicious user could have access to your physical device, the two-factor authentication would make it harder to access the data even with the credentials.

Another important aspect is the way you storage the information. I'd recommend to store the information encrypted (you can try Truecrypt) because that way even if somebody could get physical access to device or for some reason could log and see the data it would be unreadable.
And the Google policies for uploaded data allows them to use the data for multiple purposes (like advertising, translations, etc), so you never know.

8

I'm making the assumption they would be responsible for physical breaches ...

I doubt that they will be responsible for this in the way you expect it. Especially I doubt that they would cover all costs caused by the loss or leak of these data. Unless they explicitly cover thus costs it is primarily your problem because you've uploaded the data there.

You might check with you cyber-insurance provider if they would cover thus costs (I hope that you have such an insurance if you deal with such sensitive personal data).

4

Encrypt the data no matter what! Sensitive data should not even be sitting within your own network without being encrypted and access control in place. If it's encrypted in the first place you at least have a lot less to worry about in any circumstance. Don't trust someone else to do the job you should have done in the first place and it's more about protecting yourself. Depending on the data you transmit it could be illegal to transmit and store it un-encrypted. And it should never be outside of the company un-encrypted. If you must do something like transport it on a laptop or flash drive, those devices need to be encrypted. You lose the data for improper practices its your fault.

0

Why not set up your own server in your company? My father in-law worked in an accounting firm and set up their own servers for their data.

-2

It was revealed at this years DefCon that there's a new kind of attack vector being used called MITC, or Man-In-The-Cloud, that has already compromised several G-Drive and DropBox accounts. I would STRONGLY advise against this.

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    Add a reference please. – Matthew Peters Oct 14 '15 at 0:19
  • MITC has been known since before the most recent DefCon. I'm not sure this is a strong enough reason not to store this data in the cloud - there are so many other better reasons. – schroeder Oct 14 '15 at 3:54
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In addition to the above comments, I'd add a small tidbit. The vast majority of the cloud storage providers do not encrypt the data "at rest" on their servers for their "standard" consumer offer. There is a HUGE notable exception to this and this is "Box" (not Dropbox, just "Box"; they are at box.com). They are not as cheap as Google Drive, but there is some value in the fact that the data is in fact encrypted at rest. This could alleviate some of the challenges with encrypting it yourself before you store it in the cloud.

Additionally, their service does have a HIPAA-compliant variant that should more than satisfy concerns about data protection.

See more here: Box Security and Privacy (click the Encryption tab at the top for more specifics)

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    [citation needed] for "vast majority of the cloud storage providers do not encrypt the data "at rest"" – schroeder Oct 14 '15 at 19:17
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    Can you describe how "encryption at rest" in a cloud environment helps in the problem described in the Question? – schroeder Oct 14 '15 at 19:19
  • Dropbox appears to employ "encryption at rest": dropbox.com/business/trust/security/architecture – schroeder Oct 14 '15 at 19:23
  • iCloud and Google Drive also encrypts at rest (AES 128). OneDrive encrypts at rest but only for business customers. – schroeder Oct 14 '15 at 19:26
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    You have a couple problems with your answer: 1) you make a broad statement about cloud providers that appears to be untrue, 2) you also made a comment that your statement in your answer only applied to "ordinary consumer service", a qualification that you did not make in your answer, but your link to Box was for the business-grade service. – schroeder Oct 14 '15 at 20:06

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