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Platform Strategy

Trimble Identity “Forget Me” Flow

Author(s): David Kohler and Jared Bloch

Peer Reviewers: Thad Hoskins, Trimble Director of Privacy

Charlie discussion and input

Last Reviewed: February 2024

Original Prompt:

Is there awareness of Trimble Identity’s “Forget Me” flow and the responsibilities of the businesses and the applications to address our customers’ privacy rights?

Summary

Privacy standards like the General Data Protection Regulation (GDPR) safeguard individuals’ fundamental rights and freedoms in the digital age. Protecting user privacy has become paramount in today’s interconnected world, where vast amounts of personal data are generated and processed daily. Regulations, like GDPR, ensure that businesses and organizations handle personal information responsibly, granting individuals greater control over their data. The trend of GDPR fines indicates a growing emphasis on holding organizations accountable for data protection lapses, with regulatory authorities imposing substantial penalties to ensure heightened compliance.12

Trimble Identity is often considered when thinking about how customers’ personal data is introduced into Trimble. And this is appropriate since most Trimble applications leverage Trimble Identity as their authentication mechanism. However, the management of Trimble Identity data in accordance with these regulations alone is not enough.

A fundamental right under legislation such as GDPR is the “Right to be Forgotten”. This allows a data subject (sometimes our customer or end user) to request Personal Data3, including Personally Identifiable Information (PII), removal from Trimble in certain cases. To this end, Trimble Identity allows for a user to indicate they want their identity removed, and it is this explicit action that serves as one of the primary ways to indicate that they want all associated PII deleted from the Trimble Ecosystem.4

Activating the Trimble Identity deletion procedure removes the PII associated with the Identity record as well as cleanses all other Core Services of this information. But the user intention is not solely limited to removing their data from our Core Services, they intend that their personal data be removed Trimble-wide.

Applications and products may store the user’s PII data for the application to function. The data also could be found within the logs of these products. The application’s responsible for taking the necessary and timely action in reaction to the request.

But how are the application teams made aware? Trimble Identity publishes deletion activity to an event topic for consumption by other product teams.56 Assuming the flow and corresponding responsibilities are well understood, we should see a high correlation between the applications that have adopted Trimble Identity and those that are consuming this feed. But in practice, we do not; less than 1% of applications that utilize Trimble Identity are subscribed to the TID Delete event. While adhering to this flow and consuming this feed alone does not address the situation, it is a critical first step.

Action: We will track and publish the adoption of the Trimble Identity Delete event feed. Phase 1 success will be achieved when we start to see a high correlation between the applications that utilize Trimble Identity and subscribe to this feed.

Individual users vs enterprise users

Trimble’s responsibilities for data privacy compliance vary depending on the customer or user relationship (B2B, Enterprise, B2C/Personal, etc.). In some cases, Trimble is the Data Controller. In other cases, Trimble may only be a Data Processor.78

It is important to recognize that a Trimble Identity is not the same as a Trimble Customer. A Trimble Identity represents a user, and not all users have the same rights, e.g. the Right to be Forgotten. Getting this correct relies on clearer relationships of Users to Customer Accounts, and clarity on the type of Customer Account. Is the Customer Account an Individual User Account where the user must be capable of exercising their rights as a data subject? Or is the User part of an Enterprise Account, where the landscape is more complex, e.g. their employer may be the Data Controller?

Other strategy position papers further explore the topic of user and account relationships. As a practical step forward, we promote the following policy for Individual Users:

  • When a Trimble Identity user is not tied to a Trimble Account, Trimble assumes this Trimble Identity user is an Individual Account and must be able to exercise their Right to be Forgotten using the Trimble Identity Forget Me workflow.

  • When a Trimble Identity user belongs to a Trimble Account, then only the Account Administrator can request the Forget Me workflow.

    • A user that is the sole user in an Individual Account is, by default, the Account Administrator. That user can initiate the Forget Me flow for themself.
    • A user with the Account Administrator role in Trimble AXP should be able to initiate the Forget Me flow on behalf of users in their company.

Footnotes

  1. The Biggest GDPR Fines of 2022 ↩

  2. Spain – Google hit with €10 million fine over the right to be forgotten ↩

  3. Personal Data Guidelines ↩

  4. US residents can also indicate they also want their information deleted by filling out the form on our corporate privacy page. ↩

  5. The list of events streams supported in production. ↩

  6. These are not isolated events. Trimble Identity averages 40 “forget me” events per day. ↩

  7. gdpreu.org: Data Controllers and Processors ↩

  8. Trimble Data Protection Glossary ↩