Happy Data Privacy Day! At Cloudflare, our mission is to help build a better Internet, and we believe data privacy is core to that mission. But we know words are cheap — even data brokers who sell your personal information will tell you that “privacy is important” to them. So we wanted to take the opportunity on this Data Privacy Day to show you how our commitment to privacy crosses all levels of the work we do at Cloudflare to help make the Internet more private and secure — and therefore better — for everyone.
Privacy on the Internet means different things to different people. Maybe privacy means you get to control your personal data — who can collect it and how it can be used. Or that you have the right to access and delete your personal information. Or maybe it means your online life is protected from government surveillance or from ad trackers and targeted advertising. Maybe you think you should be able to be completely anonymous online. At Cloudflare, we think all these flavors of privacy are equally important, and as we describe in more detail below, we’ve taken steps to address each of these privacy priorities.
Governments don’t necessarily take the same view on what privacy should mean either. Europe has its General Data Protection Regulation (GDPR), under which people have the right to control how their information is used, and the protection of data is a fundamental right under the EU Charter of Fundamental Rights. The United States takes a consumer-centric approach focusing on deceptive use of information, the sale of information, and privacy from unwarranted government surveillance. Brazil’s privacy law is similar to that of Europe’s, and Canada, New Zealand, Japan, Australia, China, and Singapore (to name a few) have some variation on the theme of a national, comprehensive privacy law.
Rather than viewing privacy of personal data as an ocean of data to be regulated through the lens of any particular government, we think privacy merits a different approach. To begin with, we don’t think there should be an ocean of personal data. We believe in empowering individuals and entities of all sizes with technological tools to reduce the amount of personal data that gets funneled into the data ocean — regardless of whether you live in a country with laws protecting the privacy of your personal data. If we can build tools to help you share less personal data online, then that’s a win for privacy no matter your privacy priorities or country of residence.
Technologies that Enable the Privacy of Personal Data
We’ve said it before — the Internet was not built with privacy and security in mind. But as the Internet has become more essential to daily life and more central to even the most critical corporate and government systems, the world has needed better tools to provide privacy and security for these online functions. When we talk about building a better Internet, for us that means (re)building the Internet with privacy baked in. Since Cloudflare launched in 2010, we’ve released a number of state-of-the-art, privacy-enhancing technologies that can help individuals, businesses, and governments alike:
- Universal SSL: In 2014, there were 2 million websites that supported encrypted connections. In September of that year we introduced universal SSL (now called Transport Layer Security) for all of our customers, paying and free, and overnight we were able to make SSL easily available at scale to the millions of websites that use Cloudflare. Supporting SSL means that we support encrypting the content of web pages, which had previously been sent as plain text over the Internet. It’s like sending your private, personal information in a locked box instead of on a postcard.
- Privacy Pass: Cloudflare supports Privacy Pass, which lets users prove their identity across multiple sites anonymously without enabling tracking. When people use anonymity services or shared IPs, it makes it more difficult for website protection services like Cloudflare to identify their requests as coming from legitimate users and not bots. To help reduce the friction for these users — which include some of the most vulnerable users online — Privacy Pass provides them with a way to prove they are legitimate across multiple sites on the Cloudflare network. This is done without revealing their identity, and without exposing Cloudflare customers to additional threats from malicious bots.
- ESNI: We announced beta support for encrypted Server Name Identification (ESNI) in 2018. Server Name Identification (SNI) was created to allow multiple websites to exist on the same IP address (something that became necessary with the shortage of IPv4 addresses), but it can reveal which websites users are visiting. As described here, ESNI encrypts the SNI, fixing what has been a glaring privacy hole.
- 22.214.171.124 Public DNS Resolver: In 2018, we announced our public privacy-focused resolver, the 126.96.36.199 Public DNS Resolver (which also turned out to be the world’s fastest public DNS resolver). It was our first consumer product, it’s free, and we built it because we believe that consumers should have the ability to browse the Internet without providers in the middle monitoring user activity. So our public DNS resolver service will never store 188.8.131.52 public DNS resolver users’ IP addresses (referred to as the source IP address) in non-volatile storage, and we anonymize the source IP addresses of 184.108.40.206 public DNS resolver users before logging any data. This way, we have no information about what website a specific user has looked up using the 220.127.116.11 Public DNS Resolver service. We can’t tell who is visiting any given website, and we don’t want to know.
- DNS over HTTPS (DoH): Using the 18.104.22.168 Public DNS Resolver means that your ISP won’t get all of your browsing data from acting as your DNS resolver, but they will still get it from provisioning those requests unless you encrypt that channel. For those reasons, we added support for DoH. DNS requests can contain some alarmingly personal data, such as your location, the domains and subdomains you have visited, the time of day requests were submitted, and how long you stayed on certain sites. Encrypting those requests ensures that only the user and the resolver get that information, and that no one involved in the transit in between sees it. In addition to DoH, we’ve partnered with Mozilla to support private web browsing in Firefox. We have also employed query minimization to ensure that those who don’t need to access the full URL you are requesting, simply don’t.
- 22.214.171.124 Mobile Application with WARP: People are accessing the Internet from their mobile devices more and more, so in 2019 we launched our 126.96.36.199 Mobile Application with WARP. You can enable our mobile application in DNS-only mode to ensure that all of your mobile device’s DNS queries are sent to our 188.8.131.52 Public DNS Resolver using either DNS over HTTPS or DNS over TLS. You can also enable WARP in our mobile application, which includes everything from our DNS-only mode and will also route traffic from your device through the Cloudflare network via encrypted tunnels. This means that even if you are accessing websites or mobile applications that are not using HTTPS, the content transmitted to and from your device will be encrypted if you have WARP enabled and will not be sent as plain text over the Internet.
How We Do Privacy at Cloudflare
The privacy-enhancing technologies we build are public examples of how we put our money where our mouth is when it comes to privacy. We also want to tell you about the ways — some public, some not — we infuse privacy principles at all levels at Cloudflare.
- Employee Education and Mindset: An understanding of privacy is core to a Cloudflare employee’s experience right from the start. Employees learn about the role privacy and security play in helping to build a better Internet in their first week at Cloudflare. During the comprehensive employee orientation, we stress the role each employee plays in keeping the company and our customers secure. All employees are required to take annual data protection training, which introduces employees to the fundamentals of the Fair Information Practices (FIPs), GDPR and other applicable laws, and we do targeted training for individual teams, depending on their engagement with personal data, throughout the year.
- Privacy in Product Development: We have built the FIPs and GDPR requirements into product development. Cloudflare employees take privacy-by-design seriously. We develop products and processes with the principles of data minimization, purpose limitation, and data security always front of mind. We have a product development lifecycle that includes performing privacy impact assessments when we may process personal data. We retain personal data we process for as short a time as necessary to provide our services to our customers. We do not cross-track individual Internet users across sites. We don’t sell personal information. We don’t monetize DNS requests. We detect, deter, and deflect bad actors — we’re not in the business of looking at what any one person (or more specifically, browser) is doing when they browse the Internet. That’s not what we’re about.
- Internal Compliance with Privacy Regulations: Even before Europe’s watershed GDPR went into effect in 2018 and the California Consumer Privacy Act (CCPA) took effect earlier this month, we were focusing on how to implement the privacy principles embodied in regulations globally. A key part of this has been to minimize our collection of personal data and to only use personal data for the purpose for which it was collected. We view the GDPR and CCPA as a codification of many of the steps we were already taking: only collect the personal data you need to provide the service you’re offering; don’t sell personal information; give people the ability to access, correct, or delete their personal information; and give our customers control over the information that, for example, is cached on our content delivery network (CDN), stored in Workers Key Value Store, or captured by our web application firewall (WAF).
- Security as a Means to Enhance Privacy: We’re a security company, so naturally we view security as a critical element of ensuring data privacy. In addition to the extensive internal security mechanisms we have in place to protect our customers’ data, we also have become certified under industry standards to demonstrate our commitment to data security. We are ISO 27001 and AICPA SOC 2 Type II certified. Cloudflare’s SOC 2 Type II report covers security, confidentiality, and availability controls to protect customer data. We also maintain a SOC 3 report which is the public report of Security, Confidentiality, and Availability controls. In addition to this, we comply with our obligations under the EU Directive on Security of Network and Information Systems (NIS).
- Privacy-focused Response to Government and Third-Party Requests for Information: Our respect for our customers’ privacy applies with equal force to commercial requests and to government or law enforcement requests. Any law enforcement requests that we receive must strictly adhere to the due process of law and be subject to judicial oversight. We believe that U.S. law enforcement requests for the personal data of a non-U.S. person that conflict with the privacy laws of that person’s country of residence (such as the EU GDPR) should be legally challenged. Consistent with both the U.S. CLOUD Act and the proceedings in the Microsoft Ireland case, providers like Cloudflare may ask U.S. courts to quash requests from U.S. law enforcement based on such a conflict. In addition, it is our policy to notify our customers of a subpoena or other legal process requesting their customer or billing information before disclosure of that information, whether the legal process comes from the government or private parties involved in civil litigation, unless legally prohibited. We also publicly report on the types of requests we receive, as well as our responses, in our semi-annual Transparency Report. Finally, we publicly list certain types of actions that Cloudflare has never taken in response to government requests, and we commit that if Cloudflare were asked to do any of the things on this list, we would exhaust all legal remedies in order to protect our customers from what we believe are illegal or unconstitutional requests.
- Bringing Privacy and Security to Vulnerable Entities (Project Galileo): Since 2014, we have been providing a wide range of security products to important, yet vulnerable, voices on the internet with Project Galileo. Privacy is essential to the more than 900 organizations receiving free services under the Project, as many face threats from powerful adversaries. These organizations range from humanitarian groups and non-profit organizations, to journalism and media sites that are repeatedly flooded with malicious attacks in an attempt to knock them offline.
- Spreading the Message on What We Think Privacy Should Look Like: It isn’t enough to build tools with privacy in mind; we also feel a responsibility to share best practices we have learned and work with policymakers to help them understand the implications of regulation on complex technologies. For example, Cloudflare has actively supported efforts to develop a framework for US Federal privacy standards, urging policymakers to adopt technology-neutral approaches that allow standards to change and improve as technology does. In Europe, we are engaged in the ongoing discussions on the draft ePrivacy Regulation, which aims to enshrine the important principle of confidentiality of communications and guides companies on cookie usage and direct marketing. We are also actively contributing to the EU debate on the draft eEvidence Regulation, which seeks to facilitate cross-border access to data. We believe this initiative must fully respect the EU Charter of Fundamental Rights and the EU data protection framework.
So What’s Next?
Protecting the privacy of personal data is an ongoing journey. Our approach has never been to check the boxes of compliance and move on. We are continually evaluating how we handle personal data and looking for ways to minimize the amount of personal data we receive. We will continue to be self-critical and examine our own motivations for the technologies we develop. And we will keep working, just as we have for the past ten years, to find new ways to secure privacy and security for our customers and for the Internet as a whole.