CTAP For NGFW - Data Privacy Notice

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Data Privacy for

NGFW
Assessments
Cyber Threat Assessment Program
Data Privacy for NGFW Assessments

What EULA or privacy agreements do I need to have in


place prior to performing an assessment?
Fortinet does not require agreements up front in order to perform an assessment. However,
where the assessment is conducted in a country that requires informed consent to the end
user about the use of their data during the assessment, the FortiPartner is responsible for
complying with the applicable data protection laws to allow personal data transfers to and
processing by Fortinet.

FortiPartners may additionally send participants the information below:

1. By participating in the Cyber Threat Assessment Program, participants are subject to


Fortinet’s End User License Agreement (EULA), located at:
http://www.fortinet.com/doc/legal/EULA.pdf

2. Fortinet may collect information via the Cyber Threat Assessment Program, which
will be handled as outlined in Fortinet’s Privacy Policy:
https://www.fortinet.com/corporate/about-us/privacy.html

a. Fortinet may obtain personal information about participants, such as their


name (including company name), contact information (address, phone, email,
etc.), IP addresses, and the Fortinet products assigned to them. If
participants signed up for this program via an authorized Fortinet partner,
please contact the Fortinet partner for details on information that they may
have about them.

b. Fortinet’s products may automatically send usage and log data to Fortinet
during participation in this program.

3. If participants have any questions or concerns, please email ctap@fortinet.com.

From a privacy perspective, what kind of information is


sent to Fortinet and how is it used?
For the CTAP for NGFW assessment specifically, we are receiving a copy of inspection logs
for providing the user with a security report. Any data sent to Fortinet servers for processing
are bound by the Fortinet’s End User License Agreement, available here.

The CTAP for NGFW report is produced automatically based on these inspection logs. The
inspection logs contain IP addresses/hostnames associated with individual machines. We
intentionally do not identify individual user names (via LDAP for instance).

This data is processed in either Canada (for Americas-based assessments) or Germany (for
anything outside of Americas).

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Data Privacy for NGFW Assessments

Inspection is performed by automatically applying our latest threat intelligence and


technologies to your log data. None of the inspection is performed manually. No automated
decision-making or profiling is involved in the processing.

Log data is transported to Fortinet for processing via a secured channel (SSL encrypted).
Log data is only stored for the duration of the assessment. When an assessment is
completed, raw logs are permanently erased from any processing servers. The raw logs
collected are deleted as soon as the report is marked as “Completed.”

If Fortinet generates a report (Report Ready status) and the assessment creator does not
mark it “Complete,” we automatically delete the raw logs after 7 days. We occasionally get
requests to generate a second report, but we may be unable to because the raw logs have
already been deleted. This is implemented by design and was instituted to protect customer
privacy.

A subset of the customer’s assessment data is anonymized, transformed, then retained by


Fortinet for analytics purposes. Fortinet retains this information only for the purposes of
providing trend, threat guidance, and general usage data back to the communities we serve.
Typically, we provide this guidance in the form of quarterly reports (anonymized and
aggregated from customers worldwide).

For any questions about Fortinet steps to ensure privacy or the use of the end user’s data,
the assessment conductor should email ctap@fortinet.com for clarifications.

What if a customer asks for a Non-Disclosure


Agreement to be signed?
Non-disclosure Agreements (NDAs) are typically not required for running a Cyber Threat
Assessment. Partners may enter into their own NDAs with the customer; however, that is
outside the scope of Fortinet interactions. If a customer insists on an NDA with Fortinet
directly, please contact Fortinet legal for assistance.

What can I tell a prospect who doesn’t want their log


data being sent to another party?
Certain prospects may not be comfortable with sending log data to Fortinet. In those cases,
we recommend requesting a full on-site proof of concept
FortiGate/FortiSandbox/FortiAnalyzer deployment as necessary to accommodate individual
customer requirements.

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