This overview summarizes how Mattermost can help users in support of their internal compliance initiatives, including:
U.S. Export Compliance
The following overview summarizes how Mattermost software can be used to assist in compliance programs covering the European Union’s General Data Protection Regulation, also known as Regulation (EU): 2016/679 (See full text) and how Mattermost, Inc., itself, adheres to regulatory requirements.
Mattermost is a collaboration hub for highly-trusted organizations and is committed to supporting the principles of GDPR to protect the data of people in the European Union. Mattermost adheres to this mission through the use of:
Security Infrastructure: Continual investment in security, privacy and compliance capabilities.
Product Features: To ensure data management and data portability.
To stay up to date with our efforts, please subscribe to our regular newsletter.
Mattermost enables organizations to protect their information, and the information of their users and customers, through self-hosted communication infrastructure that has been developed with a high standard of security. The features of this security infrastructure include:
Security Features in Mattermost open source and commercial offerings that enable deployment of your organization’s own infrastructure.
Responsible Disclosure Policy for security researchers around the world to confidentially report suspected vulnerabilities, which can be addressed in updates to Mattermost software.
Security Reviews conducted by both our own internal security review team and external security researchers.
ISO 27001 Standards which are met to achieve alignment with international security guidelines.
Mattermost adheres to contractual obligations for ensuring the proper management of data through:
GDPR-Compliant Data Processing Addendum included with Mattermost’s standard terms.
Mattermost supports features that ensure data management and data portability.
Data Retention: Use data retention to automatically erase data after a set period of time, a feature that meets the Right to Erasure principle. In Team Edition, you can use database scripts to achieve the same result.
Profile Deletion: Delete a user’s personal information via mmctl user delete, or via the CLI. Both the mmctl and the CLI command permanently deletes all user information including messages created by the user.
Self-Hosted Push Notification Service: Self-host your own push notification service, or deploy mobile apps with any EMM provider that supports AppConfig to meet security and compliance policies. See our Mobile App deployment documentation to learn more.
Data Import: Use the bulk loading tool to migrate data from an existing messaging system, or for pre-populating a new installation with data. Review this guide which summarizes the different approaches and meets the Right to Data Portability principle.
Data Export: Use compliance exports to export conversations from public, private and direct message channels in XML or EML format. Those in Team Edition can export conversations directly from the database, both in MySQL and in PostgreSQL.
Adherence with accessibility standards is assisted in the following ways:
508 Compliance: For U.S. public sector organizations seeking to confirm 508 compliance, Mattermost publicly shares its Voluntary Product Accessibility Template (VPAT) online.
WCAG 2.0L: For meeting Web Contact Accessibility Guidelines 2.0 (WCAG), Mattermost has received a third-party “A” rating and is working towards an “AA” rating.
ADA: Mattermost compliance with the Americans with Disabilities Act (ADA) is achieved by offering the accessibility support detailed in the VPAT and WCAG 2.0 guidelines with Mattermost’s online experience as the interface to accessibility tools.
Remediation: Any technical issue in a current or future product release that would prevent compliance with accessibility ratings stated in product documentation would be considered a product defect and Mattermost would welcome the public filing of an issue report against the defect so that it may be resolved.
Mattermost, Inc. implements a number of controls and processes to comply with U.S. trade compliance laws.
IP blocking: We use IP blocking to deny access from certain countries to our commercial systems, such as signing up for our commercial and proprietary offerings.
Automated compliance scanning: We use an automated export compliance tool called Descartes. In Salesforce account records there is a prominent Descartes box in the top right indicating safety levels. Accounts that are flagged need to be signed-off by Tim Quock, VP Finance, who is connected with our export compliance counsel.
Manual compliance review: At times announcements about changes to sanctions regulations happen faster than our export compliance tool can adapt. In the cases where sanctions have been announced, we can proactively review our business and make changes to enforce sanctions ahead of the automated solution being updated.
Legal restrictions: Our commercial software contains legal terms that apply to both administrators and end users prohibiting use that would violate U.S. sanctions law.
U.S. trade laws referenced here can be found online at: https://www.bis.doc.gov/index.php/policy-guidance/lists-of-parties-of-concern/entity-list
If you feel your organization is miscategorized under U.S. sanctions, please email email@example.com.
The customer is contacted via email with either manually or through an automated process with firstname.lastname@example.org cc’d and the communication is written back into SFDC for record keeping.
Export Control Classification Number (ECCN)
Mattermost Enterprise Edition E10
Mattermost Enterprise Edition E20
Mattermost Team Edition
Not subject to the U.S. Export Administration Regulations (EAR) given software is publicly available and fully available to compile from publicly available source code at https://github.com/mattermost/
The U.S. government regulates the transfer of information, commodities, technology and software considered to be strategically important to the U.S. in the interest of national security, economic and/or foreign policy concerns. Many countries outside of the U.S. have similar controls on exports for the same reasons.
There is a complex network of U.S. agencies and inter-related regulations that govern exports collectively referred to as “Export Controls.”
It is the policy of Mattermost to comply with all export compliance laws in all countries in which it transacts business. Because Mattermost is a U.S.-based global company, our products, collectively referred to as “Commodities,” which include our software as well as our equipment, materials and services, are subject to the export laws and regulations of every country in which we conduct business. Non-compliance with export control regulations can subject Mattermost and its affiliates, including its customers, employees and business partners to criminal and civil penalties, the seizure of assets, the denial of export privileges, and suspension or debarment from Government Contracts.
For these reasons, please take the time to familiarize yourself with applicable export (and import) controls in the jurisdictions in which you operate. Although Mattermost cannot provide advice on export matters, this web page provides the information needed in order to export Mattermost products.
Start by taking a look at the U.S. Bureau of Industry and Security website. Then, navigate to Part 730 of the U.S. Export Administration Regulations to understand what the regulations cover and what is “Subject to the EAR” under 734.2 (“export controlled”).
Although what is subject to the Export Administration Regulations is quite broad, that does not mean an export license is required for every transaction. The foundation of understanding export controls related to hardware, software and technology can be found within the Commerce Control List (CCL), which has 10 categories, 0-9, and is set up as a positive list. The first step is determining if the item to be exported is subject to the EAR.
At Mattermost, our Team Edition software is outside the scope of the EAR, as it is derived from publicly available encryption source code and the complete software package for both the source code (https://github.com/mattermost/) and binary versions are publicly available. Mattermost enterprise software is found in Category 5, Part 2 of the CCL as Telecommunications and Information Security items (hardware, software and technology). Most items in this category have encryption.
Often a license exception under Part 740 is available where a Commerce Control List item lists the available license exception(s) specific to an Export Control Classification Number (ECCN), based on a combination of factors.
Mattermost Enterprise Edition software is found under ECCN 5D002, with a license exception available from “ENC” for our Enterprise and Professional software, with encryption features derived from open-source software. Encryption products, under the export regulations, have multiple levels of controls and requirements. BIS has a separate section of their website that has an overview, and many links, covering encryption under Policy Guidelines that you may want to review. These guidelines include helpful flow charts for determining if an item is subject to encryption controls, tables and other details.
The other key areas to be aware of for an export of Mattermost software or technology are:
Sanctions: There are comprehensive sanctions to Cuba, Iran, North Korea, Syria, and other countries/territories. with specific prohibitions, such as Venezuela. Details can be located at BIS and OFAC. The countries and their sanctions are subject to change.
WMD (Weapons of Mass Destruction): Mattermost, its customers and its business partners may not export to parties involved in proliferation of weapons of mass destruction, along with other prohibited end-uses under the U.S. Export Administration Regulations (“EAR”).
General Prohibitions: Information on General Prohibitions under the EAR is located here. Application of the applicability of these General Prohibitions is based on a combination of factors. These include: classification of the commodity, destination, end-user, end-use and conduct.
Restricted Parties: You may not export to parties listed on the US government’s restricted parties lists, and should be screening against these prior to export. There is a consolidated screening list provided by the U.S. government at export.gov at no charge that can be used for screening.
Deemed Exports: Release of controlled technology to foreign persons in the U.S. is “deemed” to be an export to the person’s country or countries of nationality and is found in 734.2(b) of the EAR, which you can read about under the Export Administration Regulations on the BIS website.
Know Your Customer: By reviewing the BIS website, you will notice that it is very important to “know your customers,” and to be aware of “Red Flags”. Be sure to screen business partners and customers to ensure compliance.
Mattermost makes this data available for informational purposes only. It may not reflect the most current legal developments, and Mattermost does not represent, warrant or guarantee that it is complete, accurate or up to date. This information is subject to change without notice. The materials on this site are not intended to constitute legal advice or to be used as a substitute for specific legal advice. You should not act (or refrain from acting) based upon information on this site without obtaining professional advice regarding particular facts and circumstances.
Based on our interpretation of GDPR, it is not required to hide message contents in email notifications to remain compliant for the following reasons:
Every user has the ability to disable email notifications in Settings. Therefore, every user has the ultimate control over whether or not they want information sent via email. This option aligns with most other products, but we will follow updates on interpretations of GDPR closely to see if we need to make changes in this area.
Mattermost offers TLS encryption to protect communication between the Mattermost server and the SMTP email server.
If you’re uncertain whether the first two points cover GDPR compliance, you can disable notifications completely on your Mattermost server. To use Mattermost in production with no email notifications, you also need to disable a “preview mode” notice banner.
Based on our interpretation of article 49 of GDPR, processing personal data for the purpose of ensuring network and information security is acceptable. Moreover:
You can control access to the logs via restricted access to the System Console and the server.
As a self-hosted software, you have full control and ownership of the logs, with the ability to set up a purge schedule to meet your needs.
You can use a reverse proxy to provide obfuscation to IP addresses.
We are in the process of acquiring Authority to Operate (ATO) and Certificate of Networthiness (CON) certifications.
When the customer’s installation of Mattermost is self-hosted, Mattermost does not process any personal data under the jurisdiction of the data privacy laws governing within the European Union. The Mattermost support team leverages Zendesk customer service software, which hosts Mattermost information within the United States. For more information on Zendesk, please see their Privacy and Data Protection page.
Zendesk privacy and data protection safeguards notwithstanding, the provision of support services is part of the contractual obligations between Mattermost and its customers. In order for Mattermost to provide such support, a customer must be able to identify as a licensed user, therefore requiring the user to provide personal data to the support agent. Regardless of where the support agent is located, the personal data will indeed be hosted outside of the EU.
*DISCLAIMER: MATTERMOST DOES NOT POSITION ITS PRODUCTS AS “GUARANTEED COMPLIANCE SOLUTIONS”. WE MAKE NO GUARANTEE THAT YOU WILL ACHIEVE REGULATORY COMPLIANCE USING MATTERMOST PRODUCTS. YOUR LEVEL OF SUCCESS IN ACHIEVING REGULATORY COMPLIANCE DEPENDS ON YOUR INTERPRETATION OF THE APPLICABLE REGULATION, AND THE ACTIONS YOU TAKE TO COMPLY WITH THEIR REQUIREMENTS. SINCE THESE FACTORS DIFFER ACCORDING TO INDIVIDUALS AND BUSINESSES, WE CANNOT GUARANTEE YOUR SUCCESS, NOR ARE WE RESPONSIBLE FOR ANY OF YOUR ACTIONS. NO GUARANTEES ARE MADE THAT YOU WILL ACHIEVE ANY SPECIFIC COMPLIANCE RESULTS FROM THE USE OF MATTERMOST OR FROM ANY RECOMMENDATIONS CONTAINED ON OUR WEBSITES, AND AS SUCH, THIS SHOULD NOT BE A SUBSTITUTE TO CONSULTING WITH YOUR OWN LEGAL AND COMPLIANCE REPRESENTATIVES ON THESE MATTERS.