Is Approov in Compliance with TTDSG?

Compatibility of the Approov security solution with the German Telecommunications and Telemedia Data Protection Act (TTDSG).

The compatibility of the Approov security solution with the German Telecommunications and Telemedia Data Protection Act (TTDSG) primarily involves examining how the solution handles user data and maintains confidentiality, especially considering the strict privacy regulations imposed by the TTDSG and other relevant European data protection laws such as the GDPR.

Approov Security Architecture and Data Handling

Approov's security architecture is designed to ensure that no personal data (PII) is stored or transmitted unnecessarily. The system uses a device's integrity and authentication mechanisms to ensure that API calls are from genuine, untampered versions of the application. This is done without transmitting or storing personal data, which is a crucial aspect of complying with TTDSG.

Approov's service does not store any application code, only signatures of the applications which are used to verify authenticity. This minimizes the amount of data processed and stored, reducing the risk of data breaches and ensuring that data handling practices comply with TTDSG’s requirement for data minimization and purpose limitation.

Privacy by Design

The TTDSG emphasizes the importance of implementing data protection principles right from the design phase of any service or application. Approov’s security solution includes features like dynamic pinning and token validation, which do not require personal data to function. This approach of using technical measures to ensure data security without processing personal data aligns well with the concept of privacy by design, which is advocated by both the TTDSG and GDPR.

Data Protection Impact Assessment (DPIA)

For technologies that might pose a high risk to the privacy rights of individuals, TTDSG requires a Data Protection Impact Assessment. While the document does not explicitly mention DPIA, the security mechanisms employed by Approov, such as encrypted communications and minimal data retention, suggest a low risk to personal data which would be favorable in any DPIA process.

Compliance with ePrivacy and Cookie Regulations

TTDSG regulates the use of cookies and similar technologies. Approov's model, which does not rely on such technologies for user tracking or data analysis, inherently complies with these regulations. Instead, security tokens and API keys are used to manage sessions and authenticate requests, which are not stored on user devices like cookies and do not track users across the internet.

Conclusion

The Approov security solution's focus on minimal data usage, secure communication, and integrity verification without extensive data collection or user tracking aligns well with the requirements of the TTDSG. By ensuring that personal data is neither stored nor necessary for the operation of the security measures, Approov helps facilitate compliance with the stringent privacy and data protection standards required under German law. This makes Approov a compatible choice for organizations looking to enhance their app security while complying with TTDSG.