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Data privacy protection is considered a fundamental human right in the EU market. With the popularity of smart security equipment, cameras (IP Camera/Smart Camera) have become the key law enforcement targets of EU regulatory agencies because they involve the collection of sensitive biometric information such as faces, voices and home environments. For Chinese export companies, just passing LVD (safety regulations) and EMC (electromagnetic compatibility) in CE certification is no longer enough to meet market access requirements. Complying with the compliance assessment of the EU GDPR Data Act has become a necessary condition for products to land in the EU.
1. Strict definition: GDPR's specific requirements for hardware manufacturers
Although the General Data Protection Regulation (GDPR) is a law and regulation, when implemented in camera hardware products, it is mainly reflected in "Privacy by Design" and "Privacy by Default". This means that in the initial stage of product development, enterprises must block the risk of data leakage from the bottom of technology.
Currently, the industry-recognized assessment basis mainly refers to the ETSI EN 303 645 standard (Consumer Internet of Things Network Security Standard). This standard translates the principles in the EU GDPR Data Act into enforceable technical test items and is currently the most effective way to prove that a product meets the technical requirements of GDPR.
2. Core technical review points for camera GDPR compliance
In actual laboratory evaluations, camera products usually need to pass strict review in the following key dimensions:
Data transmission encryption: Data transmission between the camera, mobile APP, and cloud server must use TLS 1.2 or higher encryption protocol. Transmitting video streams in plaintext is an absolute "red line".
Weak password and authentication mechanism: It is strictly forbidden to use common default passwords (such as admin/123456). The device must force the user to change a strong password for the first time, or use a unique random factory password.
Data minimization principle: The data collected by the equipment should not exceed the range required for the function. For example, unnecessary recording features should be turned off by default.
Vulnerability disclosure and software updates: Vendors must establish a clear vulnerability disclosure policy and inform users of the support period of security updates (OTA).
3. Handling process: from gap analysis to compliance statement
GDPR compliance is not simply issuing a certificate like traditional certification, but a systematic assessment process. The standardized handling process is as follows:
Step 1: Technology Gap Analysis
The technical experts of GTG Group pre-evaluate the software and hardware architecture of the product, and compare the ETSI EN 303 645 standard to identify the gap between the current design and the regulatory requirements.
Step 2: Penetration Testing
The network security laboratory conducts simulated attack tests on cameras, including port scanning, firmware reverse analysis, replay attack tests, etc., to verify whether there are high-risk vulnerabilities that can be exploited in the device.
Step 3: Document review and rectification
Review the Privacy Policy, User Agreement, and data processing flow chart. Assist enterprises to establish documentation systems that meet the requirements of the EU GDPR Data Act.
Step 4: Issue a report and compliance statement
After passing the test, a network security assessment report (Evaluation Report) and a GDPR compliance certificate (Attestation of Compliance) are issued.
Special tips:
Although GDPR is an EU regulation, the technical requirements of California SB-327 Act and the UK PSTI Act are highly convergent with them. When an enterprise completes an assessment based on the ETSI EN 303 645 standard, it can usually achieve "one test, multi-country compliance", greatly reducing compliance costs.
4. Professional compliance advice from GTG Guangce Group
Faced with the increasingly severe data compliance situation, enterprises should abandon the traditional thinking of "emphasizing hardware over software". It is recommended that Secure Development Lifecycle (SDL) management be introduced at the project establishment stage. In addition, for supporting mobile APPs and cloud servers (Cloud Servers), it is also necessary to ensure that the physical location of the servers is located within the EU (or complies with the cross-border transmission agreement), which is an easily overlooked link in the GDPR review.
GTG Guangce Group has a professional network security assessment laboratory, which can provide enterprises with one-stop solutions from technical rectification suggestions, penetration testing to compliance certification, helping China's intelligent manufacturing to go overseas safely.
If you need to handle it, please contact email: net04@gtggroup.com