Monthly Archive May 2018
The key to GDPR is common sense
by Tom Fairfax, Managing Director
It is not often that EU-wide legislation is likened to a children’s story. Consider, however, the story of Goldilocks and the three bears. When it comes to the General Data Protection Regulation there are three types of organisation. There are those who are running around in a state of panic, going completely over the top, deleting all their data and sending frenzied emails to their databases. There are others who are simply doing nothing. Then there is the third group which is following and communicating a measured plan and, in short, doing it just right. The key is common sense.
The fact is that most people probably need to be doing something. There is a clear obligation to act and doing nothing is simply not an option. The policy of ‘let’s wait and see’ or corporate procrastination will only lead to tears at bedtime. GDPR builds on existing Data Protection legislation, protecting the rights of individuals and their data and this means that every organisation from a small voluntary group to a large multinational must have an enacted plan or risk falling foul of the regulation.
Organisations and individuals alike should already have a clear idea of what they need to do. If they haven’t they should step back and think about what personal data they hold and why. Many of us may still be holding unnecessary levels of personal data; many of us will have failed to consider what data we actually need and many may have failed to get appropriate permissions. For the majority of organisations it may be necessary (and possibly desirable) to have a robust data weeding project. Some data, however, is likely to be held for legitimate operational purposes, and in some cases, its wanton destruction may disenfranchise stakeholders.
Common sense should prevail. Data collection, storage and processing should be driven by a business need and supported by appropriate permissions. It is also necessary to think hard about when information actually becomes redundant and to have a sensible process to pick this up and delete it. This is not new: we should really have been doing this anyway. The ‘just right’ group will have worked out what they need to do and will have made a plan.
The important thing to remember is that whilst GDPR does not actually have an explicit compliance programme, its key intent is to ensure the safety of personal data. For those wrestling with widespread compliance, those following the compliance guidelines of regulatory bodies such as the Payment Card Industry, Mifid II (for the financial industry) or the international standards such as ISO 27001 will have done much of the work already and will just need to understand the gaps that exist.
If a system is properly safeguarded with an inbuilt process of compliance, maintenance and development through these recognised compliance processes then many of the principles of GDPR will likely be adhered to. The job of the Data Protection Officer (DPO) or Chief Information Security Officer (CISO) is to complete due diligence to ensure this is the case. Professional expert guidance will provide these key individuals with the support they require in making these judgement calls.
It is not sufficient to simply draw up a policy, however, no matter how detailed, informed or expert it may be. Plans and policies simply demonstrate management intent. If the plan is not disseminated and implemented and if clear, understandable guidelines are not provided in a timely way, even those with a meticulous plan will simply be left with cold porridge.
How PCI compliance puts you on course for GDPR
For a long time the General Data Protection Regulation has been looming on the horizon but in just a few short days it will arrive; a permanent aspect of the data protection landscape. From 25th May 2018 this European-wide data protection will be a legal requirement for virtually every UK organisation. The task should not be overwhelming; particularly for those who are already PCI compliant, or working towards it. This is because the PCI compliance process means they are already well on course for GDPR. All that remains is an identification of gaps to bring systems and policies in line with GDPR.
The important thing to bear in mind at this stage is that the GDPR, although aimed at the entirety of an organisation and largely enforceable, is less prescriptive than the PCI DSS standard that already exists. GDPR provides detail about what needs protecting but very little in the way of a solid action plan.
PCI DSS on the other hand offers a detailed framework upon which to build, specifying what needs to be done and how, and even giving regular updates and guidance on reviews. The two complement each other and therefore the GDPR will be best enacted alongside the existing PCI DSS. A further aspect to note, is that a PCI breach will also be a GDPR breach, since the information on your cardholder data environment is subject to regulation by GDPR.
GDPR should not be seen in a negative way. It is a positive piece of legislation which will help to build trust. Similarly, PCI DSS compliance provides you and your customers with peace of mind that data is secure. This is the metaphorical carrot. There is also a stick: those who do not comply and suffer a breach will face loss of customer trust, enforced PFI investigations and fines.
For those that are already compliant with the PCI DSS, an annual review of the data being processed should form an integral part of the project. This ensures that any new technologies or processes are not excluded and ongoing compliance is maintained. Once you have identified the data that GDPR affects, applying the PCI approach to the implementation of the GDPR will assist greatly as the framework is already there. There will still be a few gaps to fully adhere to GDPR so professional advice will be of benefit.
And for those who aren’t PCI compliant? Seeking guidance from a qualified advisor and reviewing the gaps in their documentation, policies, training, IT systems and processes should be a pressing matter.
With one of the largest QSA teams in Europe, SRM provide unrivalled technical and compliance expertise within the PCI arena. Our GDPR team provide a business-focused service to organisations at all ends of the GDPR-readiness spectrum. For help and support, or to discuss any aspect of PCI DSS compliance or GDPR contact Mark Nordstrom at email@example.com or 03450 21 21 51.
To gauge your level of GDPR readiness, complete our free GDPR Self Assessment Questionnaire
For more information on our GDPR services, visit our GDPR page.
To view a recording of our webinar GDPR: the roles of manual and automated penetration testing, click here.
Read more on GDPR related blogs.
Webinar Wednesday 30th May 3pm: Incident Response & Forensic Expertise – would your business survive a cyber attack or security breach?
Register for the free SRM webinar here.
As organisations endeavour to be as proactive as possible to protect themselves from a cyber attack or security incident, it is time to question if you have access to the correct expertise to respond efficiently, limit the impact and minimise disruption if you were to suffer a breach.
Join us for this informative free webinar where Alan Batey, Head of the SRM forensic team, will take you through:
- What is a retained Incident and Forensic response service?
- Why do organisations need it?
- What is the impact of not having it?
- Why is there such a market appetite for this service in the current climate?
- Followed by a Q&A.
Register for the free webinar here.
What we can all learn from the NHS response to WannaCry
To be truly resilient against potential attacks, it is not enough to simply look at patching the last one, but to anticipate the next. When commenting on the news that the NHS had not fared well in the recent round of cyber security checks, Matt Hancock, Secretary of State for Digital, Culture, Media and Sport summed up the issue.
He said on BBC Radio 4 last month that ‘The NHS has made improvements since the WannaCry attack last year, but one of the challenges in cyber security is that the criminals and the malicious actors who are trying to harm our space are moving fast, and you have to run to stay still. You can’t just make one update, you’ve got to constantly be updating’. NHS cyber security chiefs described their existing practices as ‘relatively unsophisticated’, and admitted that 88 of the 236 trusts that were assessed by NHS Digital failed to pass the required cyber security standards.
In spite of the negative publicity surrounding the event, the report did state that WannaCry’s lasting effect would have been significantly more widespread, had it not been so quickly disabled. With this issue front of mind, the Former Chairman of NHS Digital still blamed ‘a lack of focus and a lack of taking it seriously’.
So what actions are in the pipeline in order to safeguard the UK’s health service? Of course, every hospital authority will be ensuring that all software update patches are installed, after this proved to be the crippling weakness of the 80 trusts affected in last year’s cryptoworm attack. The majority of trusts had acted on this but the hesitation came from the potential implications and disruption to other IT and medical equipment.
Along with praising the initial response, it should be said that the robust plans going forward are setting the bar for others to follow. A cyber security ‘handbook’ is being issued to all employees, along with ongoing staff training and development; bringing the issue to the forefront and ensuring that everyone has their part to play.
Robust Incident Response, Business Continuity and Disaster Recovery plans are soon to be in place, reducing disruption to the operations even further in the event of an attack. This is to be reviewed and changed annually, in line with industry best-practice. It will work in tandem with both an annual ‘cyber incident rehearsal’ and Red Team-style engagements using ethical hacking teams that will consistently carry out both manual and automated penetration testing to the NHS networks. Finally, this links to their plans to appoint a CISO, after recognising that cyber security is indeed a board level issue and should be dealt with as such, as soon as possible.
It is these key practises that businesses across the globe should be looking to adopt into their next information security strategies. If your organisation is looking to mirror the proactive efforts of the NHS, SRM’s specialist solutions encompass the full scope of the governance, risk and compliance agenda. The trusted partner of government agencies, high street brands and SMEs alike, our bespoke and consultative approach enables our clients to achieve peace of mind.
To discuss how our services can help you stay safe in cyberspace, contact Mark Nordstrom on firstname.lastname@example.org or 03450 21 21 51. Or visit our website.
Three stages to building a robust defence against external threats
How attack is the best form of defence when it comes to protecting against the rising trend in phishing and social engineering attacks