GDPR Compliance for Personal / Free Accounts

As far as I can see, Dropbox could either provide a single person business account, or just make the agreement applicable to their other types of accounts. Maybe it is good business for them :sunglasses:

Actually, Google and Mailchimp are providing DPAs to non-fee paying accounts - they use model contract clauses. So I wonder whether Dropbox could also do this?

Dropbox does that too, but only for Business Account holders with a minimum of 3 users. So even if you pay for a Personal account they don't provide anything and small one person businesses are toast

It would seem rather short sighted not to make a simple electronic agreement available for personal and plus account holders in the way that Evernote and many other large companies are doing.

A business account just doesn't make sense for me, and my solicitor has advised me that I do need a DPA agreement or should stop using the service.

I agree. It took me about 5 email to get Dropbox support to say clearly that "yes, Bacis and Personal accounts can't get a DPA". I have asked them to reconsider but as they try to get us on their Business accounts I don't expect them to change. When I asked if they could guarantee my data to be stored in Europe rather than the US their answer was that it can be negotiated if you have more than 250 users. Up there in the clouds..

Thanks Norah, I really hope Dropbox will change this. Currently the statement that the Basic and Personal accounts comply to the GDPR are false.

Kind regards,

Auke

It is compliant - from all of the legal advice I've been given for my own personal businesses they are compliant. The biggest risk we have is from my devices so thats where we had to tighten things up.

As Dropbox is part of the US Privacy Shield is is more than robust to use:
https://www.privacytrust.com/privacyshield/gdpr-vs-privacy-shield.html
https://www.transatlantic-lawyer.com/2018/03/is-privacy-shield-gdpr-compliant/

I do think a lot of this is because the guidance is so wooly around what we can and cannot do though. I honestly think its going to be one of these regulations thats going to dramatically change due to court cases or similar over the next few years (with big companies, not us small fry) when things like TalkTalk happen (again!) and that we need to keep an eye on the Privacy Shield thing above as that is likely to be dramatically updated. 

The EU GDPR clearly states that you need a Data Processing Agreement with all those who process our data. Therefor businesses in Europe cannot use a Dropbox Free or Personal account to store personal data as Dropbox will not 'sign' such agreements with those customers. Our legal advisor conforms that and Dropbox has admitted this is the case and 'advices' to upgrade to a Business Account.

Sorry Ed, you can't state that you will meet all requirements. If you don't provide DPA's, you don't comply with the GDPR for any business using Free or Personal accounts to store personal data. No matter how many security measures you take or privacy policies you write.

One simple agreements would solve that but up to now your company is unwilling to provide this. It seems this is driven more by the desire for more profit than any technical reason, since you state that everything is in place by the GDPR.

I am a Dropbox Plus customer, and I was searching everywhere on dropbox.com for the DPA. I couldn't understand why it was so difficult to find, until i finally found (stumble upon) this thread.

I don't understand why a DPA is not available to ALL (or at least all paying) users, and why it is so difficult to get good valid information regarding aquiring an DPA from Dropbox.

GDPR clearly states that i need a DPA to be compliant with the law and for now the only solution seems to be an upgrade to business. As i really dont think i'll be able to afford that in the long run, I feel kinda let down by a service i have been using and promoting to others for many years :(

It does appear to be a cynical move by companies to force customers to pay more by only providing a DPA for business accounts (which will remain completely under utilised).

I store 1.8GB of data (most of which are PDF raster scans for our purchase ledger. I don't need 2TB, I don't need 3 users, I don't need API access. In fact I need very little of what Dropbox Business provides.

I use Dropbox to store documents in a manner that I can access from multiple locations, that's it. Rather than offering a simple solution to small businesses and sole traders who only need a single user,  Dropbox are saying "Pay for our business solution, that you'll completely under-utilise", or don't use us at all.

I'll be opting for the latter, and not using it at all...

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JB13 wrote:

Actually, Google and Mailchimp are providing DPAs to non-fee paying accounts - they use model contract clauses. So I wonder whether Dropbox could also do this?

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Hi JB13 - could you point me in the direction of the info for a DPA on Google non-fee paying accounts?  It's something I haven't managed to find.

many thanks!

Claire

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Ed wrote:
Hi All

To add to that:
Our Dropbox Terms of Service and Privacy Policy govern Dropbox Basic, Professional and Plus products while our DPA is only applicable for Dropbox’s Business users. Additionally, Dropbox is bound by the language of the Privacy Policy with respect to Dropbox Business customers and the users on a Dropbox Business team.

While Data Processing Amendments are only for Dropbox Business customers, Dropbox will meet the requirements of the GDPR by May 25, 2018 as required across all its services, including Dropbox Basic, Plus, Pro, and Business.

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So, what I take from this is that business users can have a DPA - which allows them to use Dropbox to store personal data they are controllers for.   If you have a basic account - Dropbox will be GDPR compliant in terms of what they have to do to store our details i.e. Dropbox customers data who are from the EU (not personal data that their customers are controllers of).

They are complient as far as individual users are concerned, but not if you use their service for work related items. So Dropbox can not be used by contractors/people who are self employed or small businesses who do not require 3 user accounts.

Dropbox is using server capacity in Germany for business customers.

"Dropbox versucht dem Misstrauen gegenüber den Serverstandort in den USA entgegenzuwirken, indem es Unternehmenskunden beziehungsweise professionellen Nutzern anbietet, deren Daten auf Servern in Deutschland zu speichern (dieses Angebot gibt es allerdings nicht für Privatnutzer). Dropbox nutzt hierfür die Ressourcen der Amazon Web Services im Frankfurter Rechenzentrum." (www.pcwelt.de)

What I am wondering is, if there is GDPR compliance economy and business class at Dropbox. And why Mailchimp is able to provide the necessary DPA.

I was hoping, that Dropbox would find a solution, and not leave its (paying) customers in the cold. My 12-month-plan just extended automatically, and there is obviously no chance to get money refundet, when I cancel the plan now.

After all is Dropbox not the only company offering cloud services (let alone that others do comply to GDPR AND provide DPAs).

So is this likely to change or are we all going to need to cancel our subscriptions please ? I pay for Dropbox already but not business as I am a one man band photography business. I don't need all that extra storage.  I just need enough to transfer images. I will need to find somebody else if I can't show a DPA. 

Dropbox does not guarantee that they store the data of business customers in Europe. I asked and they said that if I have 250 users I can negotiate it :-( 

But that is not a requirement for de GDPR, but you do need to inform your customers that the data can be stored in the US (which is of course something not everybody will like given how the US government gets access to data).

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nicolabisseker wrote:

So is this likely to change or are we all going to need to cancel our subscriptions please ? I pay for Dropbox already but not business as I am a one man band photography business. I don't need all that extra storage.  I just need enough to transfer images. I will need to find somebody else if I can't show a DPA. 

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It seems so - you will need one of the business accounts where a DPA is available.  However, if you are already paying - it might be that the business accounts might not be much more than you already paying and you could upgrade?