Cloud Identity Engine Privacy The purpose of this document is to provide Palo Alto Networks customers of Cloud Identity Engine with information needed to assess the impact of this service on their overall privacy posture by detailing how personal information may be captured, processed1, and stored by and within the service. Product Summary The Cloud Identity Engine is a centralized service with three core functions: directory synchronization, cloud authentication service and user context. Directory synchronization fetches user, group, and device information from a customer’s on-premises Active Directory® and cloud directory providers (Microsoft Azure®, Okta®, etc.) and makes it available to supported applications running on the hub. For an on-premises Active Directory, the Cloud Identity Engine uses an on-premises agent to query data from Active Directory and stores said data in the Cloud Identity Engine on the hub. For cloud directories, the Cloud Identity Engine connects to the respective cloud services through APIs, then collects data. Applications running on the hub can connect to the Cloud Identity Engine service to fetch user, group or device information as needed. Customers can manage the Cloud Identity Engine through the Cloud Identity Engine app available via the hub. The second core Cloud Identity Engine function, cloud authentication provides user authentication using SAML 2.0-based Identity Providers (IdPs). When the user attempts to authenticate, the authentication request is redirected to the Cloud Identity Engine, which redirects the request to the IdP. After the IdP authenticates the user, the Palo Alto Networks products map the user and apply the security policy. The third core Cloud Identity Engine function is User Context. User context enables the ability to redistribute IP-user, IP-port user, User-tag, IP-tag, Host-ID, and Quarantine List mappings to selected firewalls. 1 In this document, we adopt the broad definition of “processing” that appears at Article 4(2) of the GDPR: "'processing' means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means …”, which includes, but is not limited to the following non-exhaustive series of examples: "collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction." Cloud Identity Engine Privacy Datasheet | 1 Last updated: January 2023 Information Processed Customer Directory Attributes Cloud Identity Engine collects the customer’s organization directory information, including attributes such as: ● ● ● ● ● ● Users, such as name, email, and title Groups, such as name, members, and group type Devices, such as name, OS, and OS version Organizational units (OUs) and containers, such as name, common name, and distinguished name Hierarchical information of OUs and containers Devices, such as device serial number For a complete list of data attributes the Cloud Identity Engine collects, please visit Cloud Identity Engine Attributes in our technical documentation. Metadata The Cloud Identity Engine also processes metadata, such as: ● ● ● ● ● ● Sync status of a domain; last successful sync of a domain; and counts of users, groups, computer, containers, and organizational units in a domain Cloud Identity Engine agent ID, domains the agent is monitoring, the status of the agent, timestamp of the last update, and certificate used Information about certificates issued and revoked for agent authentication; the Cloud Identity Engine does not store the private keys of certificates issued for agents Cloud Identity Engine Instance ID IP address of the Cloud Identity Engine agent as seen by Cloud Identity Engine User activity on the Cloud Identity Engine app Cloud Identity Engine Privacy Datasheet | 2 Last updated: January 2023 ● The Edge User-ID service also processes metadata, such as IP-user, IP-port user, User-tag, IP-tag, Host-ID, and Quarantine List (defined in User-ID TechDocs page) information from firewalls for use in enforcement policies. Data Flow Diagram Purpose of Data Processing The Cloud Identity Engine gathers information about users, groups, and computers from the on-premises Active Directory and Cloud Directory stores to provide more context about security events to other applications running on the hub. For this purpose, when the application’s administrator associates the Cloud Identity Engine with the application, the collected data is shared with other applications authorized by the customer in the hub. Locations of Processing Cloud Identity Engine is hosted in Google Cloud Platform (GCP™) and data is stored in MongoDB Atlas. The data that Cloud Identity Engine collects from a customer’s directory is stored in MongoDB Atlas in the region the customer selects when the Cloud Identity Engine instance is created. However, if a customer authorizes an application in a region that requires Cloud Identity Engine data residing in another region, the data will be transferred between regions. Some applications, such as Cortex XDR™, require the same location for the Cloud Identity Engine instance and the application. Cloud Identity Engine Privacy Datasheet | 3 Last updated: January 2023 Our Privacy Practices Palo Alto Networks captures, processes, stores, and protects personal information in accordance with our Privacy Policy and product Privacy Data Sheets. Our Trust Center provides numerous privacy resources, including descriptions of our privacy practices related to the California Consumer Privacy Act (CCPA), the European Union’s General Data Protection Regulation (GDPR), our subprocessors, and our U.S. Cloud Act Frequently Asked Questions (FAQ). For further information about the ways in which our products support customer GDPR compliance, please visit: https://www.paloaltonetworks.com/legal-notices/gdpr. Customer Privacy Options Palo Alto Networks designs its products to support our customers’ compliance with global data protection and compliance obligations. It does this by addressing threat intelligence and security challenges at the application, network, and endpoint levels, and in the cloud. In addition, Palo Alto Networks offers product features that help our customers meet their EU GDPR and other legal compliance goals. Such features include, but are not limited to: data localization options, policy enforcement, access controls, logging capabilities, individual rights processing, and cross-border data transfer mechanisms. Access and Disclosure Access by Customers Customers use the hub to access the Cloud Identity Engine app, where they can manage many components of Cloud Identity Engine, including viewing and deleting the data in their Cloud Identity Engine instance. If a customer no longer wants to use a Cloud Identity Engine instance, the instance can be deleted using the hub. To designate and manage authorized users for Cloud Identity Engine, customers use the hub to manage permissions and roles. For more information on managing roles, see Manage Cloud Identity Engine Roles. To enable two-factor authentication for administrators, customers use the Customer Support Portal. Access by Palo Alto Networks and Third-Party Apps To allow Palo Alto Networks apps and third-party apps to access their directory data, customers can use the hub to associate Cloud Identity Engine with an app. Only applications that the customer authorizes can access the directory data collected by Cloud Identity Engine. Access by Palo Alto Networks To maintain privacy and protect confidentiality, Palo Alto Networks applies a business need-to-know policy for access to customer data. Access to information in Cloud Identity Engine is restricted to the Research and Development (R&D) and Customer Support teams for troubleshooting, solving issues, and improving the effectiveness of security protections. Cloud Identity Engine Privacy Datasheet | 4 Last updated: January 2023 Cross-Border Data Transfer In the event of a need to share logs or information with Palo Alto Networks offices in other regions, we will do so in compliance with applicable requirements for transfer of personal data, including those of the EU Standard Contractual Clauses as approved by the European Commission and/or other legal instruments, recognized by EU data protection laws. For a more detailed assessment of our international data transfers, please refer to our GDPR Data Transfer Impact Assessment. Retention The data from a customer’s directory is automatically updated daily, but customers can configure more frequent updates. Directory Sync overwrites obsolete data with the latest data from the customer’s directory during the update. The customer’s directory data is retained until the customer deletes the data using the Cloud Identity Engine app or asks Palo Alto Networks Customer Support to delete the data. Security Data in MongoDB Atlas is stored on an encrypted disk that uses AES-256 encryption. The communication between the Cloud Identity Engine and MongoDB Atlas is mutually authenticated and encrypted using Transport Layer Security (TLS). The communication between the cloud-based directory and the Cloud Identity Engine service is encrypted using Transport Layer Security (TLS). The communication between the Cloud Identity agent and the Cloud Identity Engine is mutually authenticated and encrypted using TLS. The agent encrypts the directory information that is temporarily stored on the agent host while the data is transferred to the Cloud Identity Engine. The Palo Alto Networks platform supports a defense-in-depth security model to help protect the customer’s data at all stages of its lifecycle, in transit, in memory, and at rest, as well as through key management. The Trust 360 Program details the security, compliance, and privacy controls in place to protect our customers’ most sensitive data. Further information about Palo Alto Networks’ security safeguards is available here. These safeguards include firewall technology, an intrusion detection system, and network segmentation. Each respective customer is responsible for ensuring physical, technical, and administrative security measures are in place to protect data and must meet all applicable privacy and security standards required by their organization. Resources You may visit this directory of all of our available product privacy data sheets or view other selected product resources below: Cloud Identity Engine Privacy Datasheet | 5 Last updated: January 2023 ● Cloud Identity Engine app on the hub ● Technical documentation ● Supported directories and regions ● Cloud Identity Engine Attributes ● Customer Support Portal ● MongoDB Trust Center ● Manage Cloud Identity Engine Roles About This Datasheet The information provided with this datasheet that concerns technical or professional subject matter is for general awareness only, may be subject to change, and does not constitute legal or professional advice, nor warranty of fitness for a particular purpose or compliance with applicable laws. Cloud Identity Engine Privacy Datasheet | 6 Last updated: January 2023