Welcome to DISC InfoSec blog | Awareness and education are key in information security, we share InfoSec & compliance related information..to Learn more contact us »
French data protection authority says Google Analytics is in violation of GDPR
The French national data protection authority, CNIL, issued a formal notice to managers of an unnamed local website today arguing that its use of Google Analytics is in violation of the European Unionâs General Data Protection Regulation, following a similar decision by Austria last month.
The root of the issue stems from the websiteâs use of Google Analytics, which functions as a tool for managers to track content performance and page visits. CNIL said the toolâs use and transfer of personal data to the U.S. fails to abide by landmark European regulations because the U.S. was deemed to not have equivalent privacy protections.
European regulators including CNIL have been investigating such complaints over the last two years, following a decision by the EUâs top court that invalidated the U.S.âs âPrivacy Shieldâ agreement on data transfers. NOYB, the European Center for Digital Rights, reported 101 complaints in 27 member states of the EU and 3 states in the European Economic Area against data controllers who conduct the transatlantic transfers. Â
Privacy Shield, which went into effect in August of 2016, was a âself-certification mechanism for companies established in the United States of America,â according to CNIL.
Originally, the Privacy Shield was considered by the European Commission to be a sufficient safeguard for transferring personal data from European entities to the United States. However, in 2020 the adequacy decision was reversed due to no longer meeting standards.
An equivalency test was used to compare European and U.S. regulations which immediately established the U.S.âs failure to protect the data of non-U.S. citizens. European citizens would remain unaware that their data is being used and how it is being used, and they cannot be compensated for any misuse of data, CNIL found.
CNIL concluded that Google Analytics does not provide adequate supervision or regulation, and the risks for French users of the tool are too great.
âIndeed, if Google has adopted additional measures to regulate data transfers within the framework of the Google Analytics functionality, these are not sufficient to exclude the possibility of access by American intelligence services to this data,â CNIL said.
The unnamed site manager has been given a month to update its operations to be in compliance with GDPR. If the tool cannot meet regulations, CNIL suggests transitioning away from the current state of Google Analytics and replacing it with a different tool that does not transmit the data.Â
The privacy watchdog does not call for a ban of Google Analytics, but rather suggests revisions that follow the guidelines. âConcerning the audience measurement and analysis services of a website, the CNIL recommends that these tools be used only to produce anonymous statistical data, thus allowing an exemption from consent if the data controller ensures that there are no illegal transfers,â the watchdog said.Â
Most management systems, compliance, and certification projects require documented policies, procedures, and work instructions. GDPR compliance is no exception. Documentation of policies and processes are vital to achieve compliance.
ITG GDPR Documentation Toolkit gives you a complete set of easily customizable GDPR-compliant documentation templates to help you demonstrate your compliance with the GDPR’s requirements quickly, easily, and affordably.
âHaving recently kicked off a GDPR project with a large international organisation I was tasked with creating their Privacy Compliance Framework. The GDPR toolkit provided by IT Governance proved to be invaluable providing the project with a well organised framework of template documents covering all elements of the PIMS framework. It covers areas such as Subject Access Request Procedure, Retention of Records Procedure and Data Protection Impact Assessment Procedure helping you to put in practice policies and procedures to enable the effective management of personal information on individuals. For anyone seeking some support with their GDPR plans the toolkit is well work consideration.â
Two-thirds of remote workers risk potentially breaching GDPR guidelines by printing out work-related documents at home, according to a new study from Go Shred.
The confidential shredding and records management company discovered that 66% of home workers have printed work-related documents since they began working from home, averaging five documents every week. Such documents include meeting notes/agendas (42%), internal documents including procedure manuals (32%), contracts and commercial documents (30%) and receipts/expense forms (27%).
Furthermore, 20% of home workers admitted to printing confidential employee information including payroll, addresses and medical information, with 13% having printed CVs or application forms.
The issue is that, to comply with the GDPR, all companies that store or process personal information about EU citizens within EU states are required to have an effective, documented, auditable process in place for the collection, storage and destruction of personal information.
However, when asked whether they have disposed of any printed documents since working from home, 24% of respondents said they havenât disposed of them yet as they plan to take them back to the office and a further 24% said they used a home shredding machine but disposed of the documents in their own waste. This method of disposal is not recommended due to personal waste bins not providing enough security for confidential waste and therefore still leaving employers open to a data breach and potential fines, Go Shred pointed out.
Most concerning of all, 8% of those polled said they have no plans to dispose of the work-related documents they have printed at home, with 7% saying they havenât done so because they do not know how to.
Personal data breach notification procedures under the GDPR
Organizations must create a procedure that applies in the event of a personal data breach under Article 33 â âNotification of a personal data breach to the supervisory authorityâ â and Article 34 of the GDPR â âCommunication of a personal data breach to the data subjectâ.
Help with creating a data breach notification template
The picture above is an example of what a data breach notification might look like â available from the market-leading EU GDPR Documentation Toolkit â which sets out the scope of the procedure, responsibilities and the steps that will be taken by the organization to communicate the breach from:
A privacy notice is a public statement of how your organisation applies data protection principles to processing data. It should be a clear and concise document that is accessible by individuals.
Articles 12, 13 and 14 of the GDPR outline the requirements on giving privacy information to data subjects. These are more detailed and specific than in the UK Data Protection Act 1998 (DPA).
The GDPR says that the information you provide must be:
Concise, transparent, intelligible and easily accessible;
Written in clear and plain language, particularly if addressed to a child; and
Free of charge.
Help with creating a privacy notice template
The privacy notice should address the following to sufficiently inform the data subject:
If you are looking for a complete set of GDPR templates to help with your compliance project, you may be interested in the market-leading EU GDPR Documentation Toolkit. This toolkit is designed and developed by expert GDPR practitioners, and has been used by thousands of organisations worldwide. It includes:
A complete set of easy-to-use and customisable documentation templates, which will save you time and money and ensure GDPR compliance;
Helpful dashboards and project tools to ensure complete GDPR coverage;
With the advent of the European Union (EU) deadline for General Data Protection Regulation (GDPR) (EU 2016/679 regulation) coming up on 25 May 2018, many organizations are addressing their data gathering, protection and retention needs concerning the privacy of their data for EU citizens and residents. This regulation has many parts, as ISACA has described in many of its recent publications and events, but all of the efforts revolve around the protection and retention of the EU participantsâ personal information. The 6 main areas for data protection defined in this regulation are:
Data security controls need to be, by default, active at all times. Allowing security controls to be optional is not recommended or even suggested. âAlways onâ is the mantra for protection.
These controls and the protection they provide must be embedded inside all applications. The GDPR view is that privacy is an essential part of functionality, the security of the system and its processing activities.
Along with embedding the data protection controls in applications, the system must maintain data privacy across the entire processing effort for the affected data. This end-to-end need for protection includes collection efforts, retention requirements and even the new âright to be forgottenâ requirement, wherein the customer has the right to request removal of their data from an organizationâs storage.
Complete data protection and privacy adds full-functional security and business requirements to any processing system in this framework for data privacy. It provides that business requirements and data protection requirements be equally important during the business process.
The primary requirement for protection within the GDPR framework demands the security and privacy controls implemented are proactive rather than reactive. As its principal goal, the system needs to prevent issues, releases and successful attacks. The system is to keep privacy events from occurring in the first place.
With all of these areas needed under GDPR, the most important point for organizations to understand about GDPR is transparency. The EU wants full disclosure of an organizationâs efforts, documentation, reviews, assessments and results available for independent third-party review at any point. The goal is to ensure privacy managed by these companies is not dependent upon technology or business practices. It needs to be provable to outside parties and, therefore, acceptable. The EU has purposely placed some strong fine structures and responses into this regulation to ensure compliance.
Having reviewed various organizational efforts in preparation for GDPR implementation, it has been found that it is good practice to look at these 6 areas for all the collected and retained data, not just EU-based data. This zero-tolerance approach to data breaches is purposely designed to be stringent and strong. Good luck to all in meeting and maintaining the data privacy and security requirements of GDPR.
Those who have studied the Regulation will be aware that there are many references to certification schemes, seals and marks. The GDPR encourages the use of certification schemes like ISO 27001 to serve the purpose of demonstrating that the organisation is actively managing its data security in line with international best practice.
Managing people, processes and technology
ISO 27001 is the international best practice standard for information security, and is a certifiable standard that is broad-based and encompasses the three essential aspects of a comprehensive information security regime: people, processes and technology. By implementing measures to protect information using this three-pronged approach, the company is able to defend itself from not only technology-based risks, but other, more common threats, such as poorly informed staff or ineffective procedures.
By implementing ISO 27001, your organisation will be deploying an ISMS (information security management system): a system that is supported by top leadership, incorporated into your organisationâs culture and strategy, and which is constantly monitored, updated and reviewed. Using a process of continual improvement, your organisation will be able to ensure that the ISMS adapts to changes â both in the environment and inside the organisation â to continually identify and reduce risks.
What does the GDPR say?
The GDPRÂ states clearly in Article 32 that âthe controller and the processor shall implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate:
the pseudonymisation and encryption of personal data;
the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;
a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.â
Letâs look at these items separately:
Encryption of data is recommended by ISO 27001 as one of the measures that can and should be taken to reduce the identified risks. ISO 27001:2013 outlines 114 controls that can be used to reduce information security risks. Since the controls an organisation implements are based on the outcomes of an ISO 27001-compliant risk assessment, the organisation will be able to identify which assets are at risk and require encryption to adequately protect them.
One of ISO 27001âs core tenets is the importance of ensuring the ongoing confidentiality, integrity and availability of information. Not only is confidentiality important, but the integrity and availability of such data is critical as well. If the data is available but in a format that is not usable because of a system disruption, then the integrity of that data has been compromised; if the data is protected but inaccessible to those who need to use it as part of their jobs, then the availability of that data has been compromised.
Risk assessment
ISO 27001 mandates that organisations conduct a thorough risk assessment by identifying threats and vulnerabilities that can affect an organisationâs information assets, and to take steps to assure the confidentiality, availability and integrity (CIA) of that data. The GDPR specifically requires a risk assessment to ensure an organisation has identified risks that can impact personal data.
Business continuity
ISO 27001 addresses the importance of business continuity management, whereby it provides a set of controls that will assist the organisation to protect the availability of information in case of an incident and protect critical business processes from the effects of major disasters to ensure their timely resumption.
Testing and assessments
Lastly, organisations that opt for certification to ISO 27001 will have their ISMSs independently assessed and audited by an accredited certification body to ensure that the management system meets the requirements of the Standard. Companies need to regularly review their ISMS and conduct the necessary assessments as prescribed by the Standard in order to ensure it continues protecting the companyâs information. Achieving accredited certification to ISO 27001 delivers an independent, expert assessment of whether you have implemented adequate measures to protect your data.
The requirements to achieve compliance with ISO 27001 of course do not stop there. Being a broad standard, it covers many other elements, including the importance of staff awareness training and leadership support. ISO 27001 has already been adopted by thousands of organisations globally, and, given the current rate and severity of data breaches, it is also one of the fastest growing management system standards today.
The GDPR will replace these with a pan-European regulatory framework effective from 25 May 2018. Â The GDPR applies to all EU organizations â whether commercial business or public authority â that collect, store or process the personal data (PII) of EU individuals.
Organizations based outside the EU that monitor or offer goods and services to individuals in the EU will have to observe the new European rules and adhere to the same level of protection of personal data. This potentially includes organizations everywhere in the world, regardless of how difficult it may be to enforce the Regulation. Compliance consultant must know the following 9 tenants of the GDPR.
Supervisory Authority – A one-stop shop provision means that organizations will only have to deal with a single supervisory authority, not one for each of the EUâs 28 member states, making it simpler and cheaper for companies to do business in the EU.
Breach Disclosure – Organizations must disclose and document the causes of breaches, effects of breaches, and actions taken to address them.
Processor must be able to provide âsufficient guarantees to implement appropriate technical and organizational measuresâ to ensure that processing will comply with the GDPR and that data subjectsâ rights are protected. This requirement flows down the supply chain, so a processor cannot subcontract work to a second processor without the controllerâs explicit authorization. If requested by subject you must cease processing and using his or her data for some limited period of time.
Data Consent – The Regulation imposes stricter requirements on obtaining valid consent from individuals to justify the processing of their personal data. Consent must be âfreely given, specific, informed and unambiguous indication of the individualâs wishesâ. The organization must also keep records so it can demonstrate that consent has been given by the relevant individual. Data can only be used for the purposes that data subject originally explicitly consented. You must obtain and document consent for only one specific purpose at a time.
Right to be forgotten – Individuals have a right to require the data controller to erase all personal data held about them in certain circumstances, such as where the data is no longer necessary for the purposes for which it was collected. If requested by subject, you must erase their data on premises, in apps and on devices.
Data portability – Individuals will have the right to transfer personal data from one data controller to another where processing is based on consent or necessity for the performance of a contract, or where processing is carried out by automated means
Documentation – The Regulation requires quite a bit of documentation. In addition to the explicit and implicit requirements for specific records (especially including proof of consent from data subjects), you should also ensure that you have documented how you comply with the GDPR so that you have some evidence to support your claims if the supervisory authority has any cause to investigate.
Fines – Major noncompliance of the law will be punishable by fines of up to either 4% or âŹ20 million of group annual worldwide turnover.
Data protection by design â Organization must ensure data security and data privacy across cloud and endpoints as well as design their system and processes that protects from unauthorized data access and malware. Specifically, organizations must take appropriate technical and organizational measures before data processing begin to ensure that it meets the requirements of the Regulation. Data privacy risks must be properly assessed, and controllers may use adherence to approved codes of conduct or management system certifications, such as ISO 27001, to demonstrate their compliance.
How to improve information security under the GDPR
Although many businesses understand the importance of implementing the right procedures for detection, report and investigate a data breach, but not many are aware of how to go about this effectively, especially during implementation phase.
Seven steps that can help you prevent a data breach:
Find out where your personal information resides and prioritize your data.
Identify all the risks that could cause a breach of your personal data.
Apply the most appropriate measures (controls) to mitigate those risks.
Implement the necessary policies and procedures to support the controls.
Conduct regular tests and audits to make sure the controls are working as intended.
Review, report and update your plans regularly.
Implement comprehensive and robust ISMS.
ISO 27001, the international information security standard, can help you achieve all of the above and protect all your other confidential company information, too. To achieve GDPR compliance, feel free to contact us for more detail on implementation.
As part of an EU General Data Protection Regulation (GDPR) compliance project, organisations will need to map their data and information flows in order to assess their privacy risks. This is also an essential first step for completing a data protection impact assessment (DPIA), which is mandatory for certain types of processing.
The key elements of data mapping
To effectively map your data, you need to understand the information flow, describe it and identify its key elements.
1. Understand the information flow
An information flow is a transfer of information from one location to another, for example:
From inside to outside the European Union; or
From suppliers and sub-suppliers through to customers.
2. Describe the information flow
Walk through the information lifecycle to identify unforeseen or unintended uses of data. This also helps to minimise what data is collected.
Make sure the people who will be using the information are consulted on the practical implications.
Consider the potential future uses of the information collected, even if it is not immediately necessary.
3. Identify its key elements
Data items
What kind of data is being processed (name, email, address, etc.) and what category does it fall into (health data, criminal records, location data, etc.)?
Formats
In what format do you store data (hardcopy, digital, database, bring your own device, mobile phones, etc.)?
Transfer method
How do you collect data (post, telephone, social media) and how do you share it internally (within your organisation) and externally (with third parties)?
Location
What locations are involved within the data flow (offices, the Cloud, third parties, etc.)?
Accountability
Who is accountable for the personal data? Often this changes as the data moves throughout the organisation.
Access
Who has access to the data in question?
The key challenges of data mapping
Identifying personal data Personal data can reside in a number of locations and be stored in a number of formats, such as paper, electronic and audio. Your first challenge is deciding what information you need to record and in what format.
Identifying appropriate technical and organizational safeguards The second challenge is likely to be identifying the appropriate technology â and the policy and procedures for its use â to protect information while also determining who controls access to it.
Understanding legal and regulatory obligations Your final challenge is determining what your organisationâs legal and regulatory obligations are. As well as the GDPR, this can include other compliance standards, such as the Payment Card Industry Data Security Standard (PCI DSS) and ISO 27001.Once youâve completed these three challenges, youâll be in a position to move forward, gaining the trust and confidence of your key stakeholders.
Data flow mapping
To help you gather the above information and consolidate it into one area, Vigilant Software, a subsidiary of IT Governance, has developed a data flow mapping tool with a specific focus on the GDPR.
Accelerate your GDPR compliance implementation project with the market-leading EU GDPR Documentation Toolkit used by hundreds of organizations worldwide, now with significant improvements and new content for summer 2017:
A complete set of easy-to-use and customizable documentation templates, which will save you time and money, and ensure compliance with the GDPR.
Easy-to-use dashboards and project tools to ensure complete coverage of the GDPR.
Direction and guidance from expert GDPR practitioners.
Includes two licenses for the GDPR Staff Awareness E-learning Course.
The General Data Protection Regulation (GDPR) is a new law that will harmonize data protection in the European Union (EU) and will be enforced from May 25, 2018. It aims to protect EU residents from data and privacy breaches, and has been introduced to keep up with the modern digital landscape.
Who needs to comply with the GDPR?
The GDPR will apply to all organizations outside of the EU that process the personal data of EU residents.
Non-compliance can result in hefty fines of up to 4% of annual global turnover or âŹ20 million $23.5 million) â whichever is greater.
Organizations that are compliant with the new Regulation will also find that their processes and contractual relationships are more robust and reliable.
What do US organizations need to do to comply with the GDPR?
The transition period for compliance with the GDPR ends in May 2018. This means that organizations now have less than ten months to make sure they are compliant.
For US organizations, the most significant change concerns the territorial reach of the GDPR.
The GDPR will supersede the current EU Data Protection Directive. Under the current Regulation, organizations without a physical presence or employees in the EU have one main compliance issue to deal with: How to legally transfer data out of the EU. The EUâUS Privacy Shield provides such a mechanism for compliance.
Almost all US organizations that collect or process EU residentsâ data will need to comply fully with the requirements of the GDPR. US organizations without a physical EU presence must also appoint a GDPR representative based in a Member State.
Save 10% on your essential guide to the GDPR and the EUâUS Privacy Shield
Augustâs book of the month is the ideal resource for anyone wanting a clear primer on the principles of data protection and their new obligations under the GDPR and the EUâUS Privacy Shield.
Much attention and excitement within the security world has recently been focused on the lucrative surge in crypto-mining malware and hacks involving or targeting cryptocurrency implementations themselves. Yet the volume of âreal worldâ transactions for tangible goods and services currently paid for with cryptocurrency is still relatively niche in comparison to those that are being paid for every minute of the day with the pieces of plastic we know as payment cards.
According to the British Retail Consortium, in the UK, card payments overtook cash for the first time ever last year. An upward trend assisted no doubt by the increasingly ubiquitous convenience of contactless micropayments. No coincidence either perhaps that contactless related card fraud in the UK also overtook cheque-based fraud in the first half of 2017.
For the foreseeable future, card payment channels are likely to present a continued risk to both businesses and individuals for the exact same reason that bank robber Willie Hutton gave us in the last century for his chosen means of income. In todayâs digital economy, however, agile cyber criminals will not only âgoâ as Mr. Hutton suggested âwhere the money isâ but will swiftly adapt and evolve their tactics to âgo where the insecurity is.â Hence, whilst according to a range of sources EMV chip cards have cut counterfeit fraud at âpoint of saleâ (POS) in the UK by approximately a third since the technology was introduced and similar improvements are now being cited for its more recent adoption in the US, a marked and plausibly corresponding uptake in online âcard not presentâ (CNP) fraud continues to rise.
The Payment Card Industry Data Security Standard (PCI-DSS) has formally existed since 2004 to help reduce the risk of card fraud through the adoption and continued application of a recognized set of base level security measures. Whilst many people have heard of and will often reference PCI-DSS, the standard isnât always as well understood, interpreted, or even applied as best it could be. A situation not entirely helped by the amount of myths, half-truths, and outright FUD surrounding it.
The PCI Security Standards Council website holds a wealth of definitive and authoritative documentation. I would advise anyone seeking either basic or detailed information regarding PCI-DSS to start by looking to that as their first port of call. In this blog, however, I would simply like to call out and discuss a few common misconceptions.
MYTH 1: âPCI JUST DOESNâT APPLY TO OUR BUSINESS/ ORGANIZATION/VERTICAL/SECTOR.â
It doesnât matter if you donât consider yourself a fully-fledged business, if itâs not your primary activity, or if card payments are an insignificant part of your overall revenue. PCI-DSS applies in some form to all entities that process, store, or transmit cardholder data without exception. Nothing more to say about this one.
MYTH 2: âPCI APPLIES TO OUR WHOLE ENVIRONMENT, EVERYWHERE, AND WE SIMPLY CANâT APPLY SUCH AN OBDURATE STANDARD TO IT ALL.â
Like many good myths, this one at least has some origin in truth.
Certainly, if you use your own IT network and computing or even telephony resources to store, process or transmit cardholder data without any adequate means of network separation, then yes, it is fact. It could also rightly be stated that most of the PCI-DSS measures are simply good practice which organizations should be adhering to anyway. The level of rigor to which certain controls need to be applied may not always be practical or appropriate for areas of the environment who have nothing to do with card payments, however. A sensible approach is to, therefore, reduce the scope of the cardholder data environment (CDE) by segmenting elements of network where payment related activity occurs. Do remember though, that wherever network segmentation is being used to reduce scope it must be verified at least annually as being truly effective and robust by your PCI assessor.
Whilst scoping of the CDE is the first essential step for all merchants on their road to compliance, for large and diverse environments with a range of payment channels, such an exercise in itself is rarely a straightforward task. Itâs advisable for that reason to initially consult with a qualified PCI assessor as well as your acquirer who will ultimately have to agree on the scope. They may also advise on other ways of reducing risk and therefore compliance scope such as through the use of certified point-to-point encryption solutions or the transfer of payment activities away from your network altogether. Which takes us directly on to discussing another area of confusion.
MYTH 3: âOUTSOURCING TRANSFERS OUR PCI RISK.â
Again, there is a grain of truth here but one that is all too frequently misconstrued.
Outsourcing your payment activity to an already compliant payments service provider (PSP) may well relieve you of the costs and associated âheavy liftingâ of applying and maintaining all of the necessary technical controls yourself. Particularly where such activity is far-removed from your core business and staff skill sets. As per Requirement 12.8 in the standard, however, due diligence needs to be conducted before any such engagement, and it still remains the merchantâs responsibility to appropriately manage their providers. At the very least via written agreements, policies and procedures. The service providerâs own compliance scope must, therefore, be fully understood and its status continually monitored.
It is important to consider that this doesnât just apply to external entities directly processing payments on your behalf but also to any service provider who can control or impact the security of cardholder data. Itâs therefore likely to include any outsourced IT service providers you may have. This will require a decent understanding of the suppliers Report or Attestation of Compliance (ROC or AOC), and where this is not sufficient to meet your own activity, they may even need to be included within your own PCI scope. Depending on the supplier or, service this may, of course, be a complex arrangement to manage.
MYTH 4: âCOMPENSATORY MEANS WE CAN HAVE SOME COMPLACENCY.â
PCI is indeed pragmatic enough to permit the use of compensatory controls. But only where there is either a legitimate technical constraint or documented business constraint that genuinely precludes implementing a control in its original stated form. This is certainly not to be misjudged as a âsoft option,â however, nor a way of âgetting aroundâ controls which are just difficult or unpopular to implement.
In fact, the criteria for an assessor accepting a compensatory control (or whole range of controls to compensate a single one in some cases) means that that the alternative proposition must fully meet the intent and rigor of the original requirement. Compensatory controls are also expected to go âabove and beyondâ any other PCI controls in place and must demonstrate that they will provide a similar level of defense. They will also need to be thoroughly revaluated after any related change in addition to the overall annual assessment. In many cases and especially over the longer term, this may result in maintaining something that is a harder and costlier overhead to efficiently manage than the original control itself. Wherever possible, compensatory controls should only be considered as temporary measure whilst addressing the technical or business constraint itself.
MYTH 5: âWE BOUGHT A PCI SOLUTION SO WE MUST BE COMPLIANT, RIGHT?â
The Payment Application Data Security Standard (PA-DSS) is another PCI Security Standards Council controlled standard that exists to help software vendors and others develop secure payment applications. It categorically does not, however, follow that purchasing a PA-DSS solution will in itself ensure that a merchant has satisfactorily met the PCI-DSS. Whilst the correct implementation or integration of a PA-DSS verified application will surely assist a merchant in achieving compliance, once again it is only a part of the overall status and set of responsibilities.
IT security vendors of all varieties may also claim to have solutions or modules that although they may have nothing directly to do with payments themselves have been specifically developed with PCI-DSS compliance in mind. They are often sold as PCI-related solutions. If deployed, used and configured correctly, many of these solutions will no doubt support the merchant with their compliance activity whilst tangibly reducing cardholder data risk and hopefully providing wider security benefits. No one technology or solution in itself will make you PCI compliant, however, and anyone telling you (or your board) that it does either does not understand the standard or is peddling âsnake oil.â Or both.
MYTH 6: âWEâRE PCI-DSS COMPLIANT SO THAT MEANS WE MUST BE âSECURE,â RIGHT?â
PCI-DSS should certainly align and play a key part within a wider security program. It should and cannot be an organizations only security focus, however. Nor should being compliant with any standard be confused with some unfeasible nirvana of being completely âsecureâ whatever that may mean at any given point in time. There have, after all, been plenty examples of PCI-compliant organizations who have still been harshly and significantly breached. Some reports of high profile incidents have voiced scathing comments about the potentially ostensible nature of the breached organizationâs PCI compliance status, even questioning validity of the standard itself. Such derision misses some key points. In the same way that passing a driving test does not guarantee you will never be involved in an accident, reasonably speaking, it will certainly decrease those chances. Far more so than if nobody was ever required to take such a test. PCI or any other security compliance exercise should be viewed with a similar sense of realism and perspective.
Applying PCI-DSS controls correctly, with integrity and unlike a driving test re-assessing them annually, must surely help to reduce the risk of card payment fraud and breaches. More so than if you werenât. Something that is to everyoneâs benefit. It cannot possibly, however, protect against all attacks or take into account every risk scenario. That is for your own wider security risk assessment and security program to deal with. Maybe yes, itâs all far from perfect, but in the sage fictional words of Marvelâs Nick Fury, âSHIELD takes the world as it is, not as weâd like it to be. Itâs getting damn near past time for you to get with that program.â
About the Author:Angus Macrae is a CISSP (Certified Information Systems Security Professional) in good standing, a CCP (NCSC Certified Professional for the IT Security Officer role at Senior Practitioner level) and PCIP (PCI SSC Payment Card Industry Professional.) He is currently the IT security lead for Kingâs Service Centre supporting the services of Kingâs College London, one of the worldsâ top 20 universities
Data protection is challenging for many businesses because the United States does not currently have a national privacy law â like the EUâs GDPR â that explicitly outlines the means for protection. Lacking a federal referendum, several states have signed comprehensive data privacy measures into law. The California Privacy Rights Act (CPRA) will replace the stateâs current privacy law and take effect on January 1, 2023, as will the Virginia Consumer Data Protection Act (VCDPA). The Colorado Privacy Act (CPA) will commence on July 1, 2023, while the Utah Consumer Privacy Act (UCPA) begins on December 31, 2023.
For companies doing business in California, Virginia, Colorado and Utah* â or any combination of the four â it is essential for them to understand the nuances of the laws to ensure they are meeting protection requirements and maintaining compliance at all times.
Understanding how data privacy laws intersect is challenging
While the spirit of these four statesâ data privacy laws is to achieve more comprehensive data protection, there are important nuances organizations must sort out to ensure compliance. For example, Utah does not require covered businesses to conduct data protection assessments â audits of how a company protects data to determine potential risks. Virginia, California and Colorado do require assessments but vary in the reasons why a company may have to take one.
Virginia requires companies to undergo data protection assessments to process personal data for advertising, sale of personal data, processing sensitive data, or processing consumer profiling purposes. The VCDPA also mandates an assessment for âprocessing activities involving personal data that present a heightened risk of harm to consumers.â However, the law does not explicitly define what it considers to be âheightened risk.â Colorado requires assessments like Virginia, but excludes profiling as a reason for such assessments.
Similarly, the CPRA requires annual data protection assessments for activities that pose significant risks to consumers but does not outline what constitutes âsignificantâ risks. That definition will be made through a rule-making process via the California Privacy Protection Agency (CPPA).
The state laws also have variances related to whether a data protection assessment required by one law is transferable to another. For example, letâs say an organization must adhere to VCDPA and another state privacy law. If that business undergoes a data protection assessment with similar or more stringent requirements, VCDPA will recognize the other assessment as satisfying their requirements. However, businesses under the CPA do not have that luxury â Colorado only recognizes its assessment requirements to meet compliance.
Another area where the laws differ is how each defines sensitive data. The CPRAâs definition is extensive and includes a subset called sensitive personal information. The VCDPA and CPA are more similar and have fewer sensitive data categories. However, their approaches to sensitive data are not identical. For example, the CPA views information about a consumerâs sex life and mental and physical health conditions as sensitive data, whereas VCDPA does not. Conversely, Virginia considers a consumerâs geolocation information sensitive data, while Colorado does not. A business that must adhere to each law will have to determine what data is deemed sensitive for each state in which it operates.
There are also variances in the four privacy laws related to rule-making. In Colorado and Utah, rule-making will be at the discretion of the attorney general. Virginia will form a board consisting of government representatives, business people and privacy experts to address rule-making. California will engage in rule-making through the CPPA.
The aforementioned represents just some variances between the four laws â there are more. What is clear is that maintaining compliance with multiple laws will be challenging for most organizations, but there are clear measures companies can take to cut through the complexity.
Overcoming ambiguity through proactive data privacy protection
Without a national privacy law to serve as a baseline for data protection expectations, it is important for organizations that operate under multiple state privacy laws to take the appropriate steps to ensure data is secure regardless of regulations. Here are five tips.
Partner with compliance and legal experts
It is critical to have someone on staff or to serve as a consultant who understands privacy laws and can guide an organization through the process. In addition to compliance expertise, legal advice will be a must to help navigate every aspect of the new policies.
Identify data risk
From the moment a business creates or receives data from an outside source, organizations must first determine its risk based on the level of sensitivity. The initial determination lays the groundwork for the means by which organizations protect data. As a general rule, the more sensitive the data, the more stringent the protection methods should be.
Create policies for data protection
Every organization should have clear and enforceable policies for how it will protect data. Those policies are based on various factors, including regulatory mandates. However, policies should attempt to protect data in a manner that exceeds the compliance mandates, as regulations are often amended to require more stringent protection. Doing so allows organizations to maintain compliance and stay ahead of the curve.
Integrate data protection in the analytics pipeline
The data analytics pipeline is being built in the cloud, where raw data is converted into usable, highly valuable business insight. For compliance reasons, businesses must protect data throughout its lifecycle in the pipeline. This implies that sensitive data must be transformed as soon as it enters the pipeline and then stays in a de-identified state. The data analytics pipeline is a target for cybercriminals because, traditionally, data can only be processed as it moves downstream in the clear. Employing best-in-class protection methods â such as data masking, tokenization and encryption â is integral to securing data as it enters the pipeline and preventing exposure that can put organizations out of compliance or worse.
Implement privacy-enhanced computation
Organizations extract tremendous value from data by processing it with state-of-the-art analytics tools readily available in the cloud. Privacy-enhancing computation (PEC) techniques allow that data to be processed without exposing it in the clear. This enables advanced-use cases where data processors can pool data from multiple sources to gain deeper insights.
The adage, âAn ounce of prevention is worth a pound of cure,â is undoubtedly valid for data protection â especially when protection is tied to maintaining compliance. For organizations that fall under any upcoming data privacy laws, the key to compliance is creating an environment where data protection methods are more stringent than required by law. Any work done now to manage the complexity of compliance will only benefit an organization in the long term.
*Since writing this article, Connecticut became the fifth state to pass a consumer data privacy law.
Earlier this year, the White House announced that it is working with the European Union on a Trans-Atlantic Data Privacy Framework. According to a White House statement, this framework will âreestablish an important legal mechanism for transfers of EU personal data to the United States. The United States has committed to implement new safeguards to ensure that signals intelligence activities are necessary and proportionate in the pursuit of defined national security objectives, which will ensure the privacy of EU personal data and to create a new mechanism for EU individuals to seek redress if they believe they are unlawfully targeted by signals intelligence activities.â
This is encouraging news. As The National Law Review pointed out, the EU had concerns about the protection of their citizensâ data from U.S. government surveillance. But it may also be the push needed to advance greater data privacy protections in America.
âThe joint statement references the U.S. putting in place ânew safeguardsâ to ensure that intelligence activities are ânecessary and proportionateâ, the definition and practical application of which will be one of the things that privacy campaigners will be looking at closely when the detailed text is drafted and made available,â said Stephen Bailey of NCC Group in an email comment.
Data Privacy and AppSec
The world runs on apps, so it is necessary to look at how the Trans-Atlantic Data Privacy Framework will impact app development and app security.
âFor application developers, the single biggest challenge to complying with increasingly rigorous data protection frameworks is getting control of their data, particularly sensitive and personally identifiable information,â explained Chris McLellan, director of operations at the nonprofit Data Collaboration Alliance.
Today, every new app, whether bought or built, traps data in a silo, which can only be connected through the exchange of copies or point-to-point data integration.
âThese copies make it incredibly difficultâand in some cases, even impossibleâto support GDPR outcomes like ubiquitous data access controls, portability, custodianship, deletion (the right to be forgotten) and precision auditability: Things that could potentially, although theyâre unlikely to, be included in the post-Privacy Shield framework. But they are definitely looming on the horizon both internationally and domestically, for example, in California and Utah,â said McLellan.
As data privacy frameworks become more common and we begin to see more joint efforts internationally, organizations have to think about how they share and store data in the future, taking compliance requirements into greater consideration.
Organizations need to get more serious about minimizing their use of data and start implementing strategies that introduce real control to the data they manage, McLellan says. They should be exploring ways now to eliminate data silos and copies that have resulted in rampant data proliferation.
No Quick Fixes
But, as McLellan pointed out, there are no quick fixes. Unwinding years of âan app for everything and a database for every appâ mantra will be difficult, and McLellan believes this is best approached in two stages.
Stage One: Immediately treat the symptoms of data proliferation by evaluating and adopting privacy-enhancing technologies that help organizations anonymize and encrypt data, and better manage consent. âThey should also investigate the potential to adopt first-party and zero-party data collection practices that redirect customer and other sensitive data away from the third-party apps (e.g. Google Analytics), over which they have no control,â McLellan explained. âOrganizations should also adopt processes and workflows that help them establish âpurpose-basedâ data access requests.â
Stage Two: Organizations should explore ways to address the root causes of data proliferation. Everyone within the organizationâs technology teamsâCIO, CDO, application development, data and IT teamsâshould familiarize themselves with emerging frameworks like zero-copy integration, a framework that is on track to become a national standard in Canada.
âItâs the evolution of privacy-by-design and signals the beginning of the end for application-specific data silos and copy-based data integration. Such frameworks are made possible by new categories of technology, including data fabrics, dataware and blockchain that support âzero copyâ digital innovation. Many leading organizations, particularly in finance and health care, are already ahead of the curve in adopting this approach,â said McLellan.
Data protection regulations at home and abroad reflect a burgeoning global trend toward citizens and consumers gaining greater control and ownership of data as its rightful owner.
âThese regulatory shifts,â said McLellan, âwill need to be met by an equally significant shift in how U.S. businesses manage data and build new applications if thereâs any hope to comply with new laws as theyâre passed.â
Cybersecurity experts would have you believe that your organizationâs employees have a crucial role in bolstering or damaging your companyâs security initiatives.
While you may disagree, data breach studies show that employees and negligence are the most typical causes of security breaches, yet these prevalent issues are least discussed.
According to a recent industry report from Shred-It, an information security provider, 47% of top business executives believe that employee error, such as the inadvertent loss of a device or document, has resulted in a data breach within their company. According to another study by CybSafe, human errors have been responsible for over 90% of data breaches in 2020.
Itâs no secret that companies of all sizes increasingly feel the sting of cybercriminals exploiting vulnerabilities in remote and hybrid working environments. However, little to no effort is made toward strengthening defenses. Now is the moment to train your personnel on security best practices, if you havenât already.
As a result of inadequate security measures, customers have long suffered the most. However, the stakes for employees and their businesses are higher than ever this year. Experian predicts 2022 will be a hangover from the âcyberdemicâ of 2021, making it crucial to stay ahead by designing a cybersecurity training program for employees and strengthening defenses.
Developing a cybersecurity training program requires knowing where the blind spots are. While there are numerous approaches to promoting a more cyber secure workplace, here are the most common and effective ways:
Trick Employees via a Phishing Campaign
You can test your employeesâ ability to distinguish authentic email content from fraudulent attachments by mass spear-phishing them. Employees who fall for the phishing email are the ones you need to be extra careful about.
They might be the ones that eventually end up disclosing a companyâs valuable digital assets. Once you have the data, you may measure the entire risk to your network and build remedies from there using custom reporting metrics.
Customize Your Security Training
All employees, irrespective of their designation or job role, should be a part of the security training. However, employees who fell for the spear-phishing campaign are the ones you need to observe and invest your security training into.
When delivering cybersecurity training, stress the importance of the training as an exercise that can also be applied elsewhere. Employees will be more inclined to utilize secure procedures at work if they do so at home on their computers and phones.
Incentivize the Security Training
Nothing motivates an employee more than being rewarded for their performance. Set up metrics and determine the level of participation, enthusiasm, and cybersecurity knowledge an employee obtains via quizzes or cross-questions. Employees who follow best practices should be rewarded, and others should be encouraged to improve their cybersecurity habits.
Cover Cybersecurity Topics
Engage your employees by introducing cybersecurity topics and certifications. Employees new to the cybersecurity realm would greatly benefit from relevant courses and learnings that might augment their skills and shine bright on their resumes.
Social media platforms are riddled with short instructional videos, which can be a great source of learning for those struggling to complete cybersecurity courses and manage work simultaneously.
Introduce Data Privacy Laws
Data privacy laws have been here for a while. However, they have recently received recognition after the EU introduced the General Data Protection Regulation (GDPR) in 2016, which came into force in 2018.
Most employees donât know much about data protection laws or donât know them altogether. Itâs crucial to educate employees regarding existing and upcoming data protection laws and how they impact the business. According to MediaPro, a multimedia communications group, 62% of employees were unsure if their company must comply with the California Consumer Privacy Act (CCPA).
Integrating data privacy laws and regulations within cybersecurity training is crucial. While employees do not need to be compliance specialists, they should have a fundamental understanding of their companyâs privacy policies, data handling procedures, and the impact of data privacy laws on their organization.
Address Security Misconceptions
Massive data breaches and ingenious hackers have muddied the waters of what is and isnât possible when carrying out a cyberattack, making it challenging for novice security personnel to tell the difference between facts and made-up security misunderstandings.
Lack of understanding and misconceptions make matters worse as employees tend to become too concerned about non-existent or misunderstood risks while being less concerned about real ones. That begs the question: Are employees taking cybersecurity seriously, or will they be a liability rather than an asset?
To move forward, begin by designing a survey that starts with the basic cybersecurity knowledge and distributing it across the organization. The survey could contain questions such as:
What is cybersecurity,
Why is cybersecurity important,
Do employees lock their devices and keep strong alphanumeric passwords for online accounts,
Do employees connect to a secure WIFI network provided by the company, etc.
The results will demonstrate the current knowledge base within the organization and whether the employees take cybersecurity seriously.
While discovering the loopholes within your organization is one thing, developing a cybersecurity training program specifically tailored to patch those vulnerabilities might not be enough. Not only this, keep a strategy that focuses on zero-day attacks to avoid any damages. As an individual entrusted with developing a training program, you should know that you need a long-term solution to the existing problem.
Humans have always been the weakest link in the cybersecurity chain, and human errors will only escalate despite the depth of training given. That leaves organizations in a tough spot and struggling to meet compliance requirements.
Understand the Consequences of Inadequate Security Training
Training just for the sake of training will not benefit anyone. Employees need to dedicate their hearts and minds to the training, and continuous sessions should take place so that employees always stay current with the latest happenings and privacy frameworks. Poor training may further confuse employees, which may also draw additional dangers.
With Securiti data privacy automation tools, you can reduce or eliminate reliance on employees and move towards a more modern and error-free framework.
With a passion for working on disruptive products, Anas Baig is currently working as a Product Lead at the Silicon Valley based company â Securiti.ai. He holds a degree of Computer Science from Iqra University and specializes in Information Security & Data Privacy.
An espionage attempt was made by an NSO Group customer to hack the phones of senior EU officials. Although thereâs some suggestion that it might have been QuaDreamâa similar Israeli spyware firm.
Commissioner for Justice Didier Reynders (pictured) seems to have been the main target, along with several of his staffers at the Directorate-General for Justice and Consumers. They were warned of the attack five months agoâby Apple.
But who ordered the hack? Might it have been the French government? In todayâs SB Blogwatch, weâre shockedâSHOCKEDâto discover un peu dâespionnage fratricide.
Your humble blogwatcher curated these bloggy bits for your entertainment. Not to mention: Shrimp can lobster.
âRemotely and invisibly take control of iPhonesâ Among them was Didier Reynders, a senior Belgian statesman who has served as the European Justice Commissioner since 2019. ⌠At least four other [Justice and Consumers] commission staffers were also targeted. ⌠The commission became aware of the targeting following messages issued by Apple to thousands of iPhone owners in November telling them they were âtargeted by state-sponsored attackers.â ⌠The warnings triggered immediate concern at the commission. ⌠A senior tech staffer sent a message to colleagues with background about Israeli hacking tools: ⌠âGiven the nature of your responsibilities, you are a potential target.â ⌠Recipients of the warnings were targeted between February and September 2021 using ForcedEntry, an advanced piece of software that was used by Israeli cyber surveillance vendor NSO Group to help foreign spy agencies remotely and invisibly take control of iPhones. A smaller Israeli spyware vendor named QuaDream also sold a nearly identical tool.
âComes at potentially the worst possible timeâ Itâs not totally clear why these officials were targeted or who used the malware against them. ⌠NSO has denied that it had any involvement. ⌠Reuters also reached out to QuaDreamâŻâŚâŻbut did not get any sort of comment or response. ⌠The claims that EU officials were targeted with NSO Group software comes at potentially the worst possible time for the company as it continues to battle both legal and financial troubles, as well as multiple government investigations. ⌠NSO is now appealing to the U.S. Supreme Court in a new effort to rid itself of a hefty lawsuit filed byâŻâŚâŻWhatsApp, [which] sued NSO in October of 2019 after the surveillance firmâs malware was allegedly discovered on some 1,400 usersâ phones. ⌠The company is also currently battling another lawsuit from Apple filed last November on similar grounds.
âUse of surveillance softwareâ The discovery of the misuse of NSO Groupâs tools certainly doesnât help the companyâs profile following the Pegasus scandal, when it was found the tool was used by governments to spy on journalists, activists, and government opponents, instead of for fighting crime. The adoption of Pegasus and other tools by government agencies led to lawmakers in the U.S. asking Apple and the FBI about the latterâs acquisition of NSO Group tools. ⌠Meanwhile, the European Parliament will be launching a committee on April 19 to investigate the use of surveillance software in European member states.
The European Union, huh?FOHEng thinks this should be a teachable moment:
Many of these same EU people think The App Store should be forced to open, increasing the vectors forâŻâŚâŻexploits to make it into devices. Theyâre as stupid as some US Senators, who arenât allowed to sideload Apps on their devices over security concerns, yet want to force Apple to allow this. They are truly delusional. ⌠Third party stores with Apps being vetted for security? An oxymoron if ever there was one. ⌠You think iOS third party stores are going to somehow be secure and Apps checked?
âNo big deal until it happens to me.â This story has been unfolding slowly for years, yet these EU officials didnât seem too bothered until Apple notified them about their phones being hacked. ⌠Thanks for all the concern.
But what of Apple in all this? Heed the prognostications of Roderikus:
More fines for offering a platform that is basically compromised while being marketed as âsafe.â
However,mikece is triggered by a certain word in the Reuter hed:
Throwing the adjective âIsraeliâ into the title is misleading as it suggest the state of Israel is somehow involved. ⌠Blaming Israel for this is like blaming Japan for all of the Toyota Hiluxes converted into gun platforms around the world.
Yet weâve still not dealt with the âwhoâ question. For this, we turn to Justthefacts:
CitizenLab did some clever geographic fingerprinting, and have a list of which countries are doing this. ⌠Out of these, the credible list is: France, Greece, Netherlands, Poland, UK, USA.
The target was the European Justice Minister from 2019 onwards. He doesnât have military or external trade secrets. Neither the UK nor USA are impacted in any way by what goes on in his office. So itâs either France, Greece, Netherlands, Poland.
If you have a look at the heat-map produced by CitizenLab, itâs the French government snooping on the EU. What were you expecting?
Nor the âwhyâ: What else do we know about the named victim? ffkom ffills us in: [Youâre ffiredâEd.]
Didier Reynders is [one of] those politicians who have continuously undermined EU data protection laws by agreeing to sham contracts like âSafe Harbourâ and âPrivacy Shield,ââŻâŚâŻknowing those were contradicting EU lawâŻâŚâŻand not worth the paper they were written on. He, personally, is also responsible for not enforcingâŻâŚâŻGDPR. ⌠It serves Mr. Reynders right that his data is exposed, just as much as he has helped to expose EU citizenâs data.
Are you planning a career as a DPO (data protection officer)?
Are you planning a career as a DPO (data protection officer)? Our unique combined GDPR (General Data Protection Regulation) and DPO training course is now available in a low-cost self-paced online format.
Work at your own pace with self-paced online training â a more affordable, flexible and less disruptive way to study. Designed by GDPR experts, this course features pre-recorded video modules supported by a learner guide and interactive exercises and tests.
The course includes essential elements of our GDPR / Data Privacy Roles Learning Path, which provides a unique guide to which training courses and qualifications will help you enhance your GDPR or DPO career.
Colorado and Virginia passed new data privacy laws in 2021. Connecticut and Oklahoma are among the states that could enact new legislation around data privacy protections in 2022. California, which kicked off the conversation around data privacy at the state level, is updating its laws. Couple that with the EUâs GDPR and other data privacy laws enacted worldwide, and it is clear that data privacy has become incredibly important within cybersecurity. And that includes within the DevSecOps process.
Itâs been enough of a challenge to integrate security into the DevOps process at all, even though it is now recognized that adding security early in the SDLC can eliminate issues further along in app development and deployment. But adding data privacy? Is it really necessary? Yes, it is necessary, said Casey Bisson, head of product growth at BluBracket, in email commentary. Applications now include more and more personal data that needs protection, such as apps that rely on medical PII. Those apps must have security and privacy baked into each phase of the SLDC via DevSecOps.
âThere have been far too many examples of leaks of PII within code, for instance, because many companies donât secure their Git repositories,â said Bisson. âAs more sensitive information has made its way into code, itâs natural that hackers will target code. True DevSecOps will bake privacy concerns into every stage and will make these checks automated.â
Data in the Test Process
In DevSecOps, applications are developed often by using test data. âIf that data is not properly sanitized, it can be lost,â said John Bambenek, principal threat hunter at Netenrich, in an email interview. âThere is also the special case of secrets management and ensuring that development processes properly secure and donât accidentally disclose those secrets. The speed of development nowadays means that special controls need to be in place to ensure production data isnât compromised from agile development.â Beyond test data, real consumer data has to be considered. Ultimately, every organization has information they need to protect so itâs important to focus on data privacy early in development so the team working on the platform can build the controls necessary into the platform to support the privacy requirements the data has, explained Shawn Smith, director of infrastructure at nVisium, via email. âThe longer you wait to define the data relationships, the harder it is to ensure proper controls are developed to support them.â
Bringing Privacy into DevSecOps
Putting a greater emphasis on privacy within DevSecOps requires two thingsâdata privacy protocols already in place within the organization and a strong commitment to the integration of cybersecurity with data privacy. âAn organization needs to start with a strong privacy program and an executive in charge of its implementation,â said Bambenek. âEspecially if the data involves private information from consumers, a data protection expect should be embedded in the development process to ensure that data is used safely and that the entire development pipeline is informed with strong privacy principles.â The DevSecOps team and leadership should have a strong understanding of the privacy laws and regulationsâboth set by overarching government rules and by industry requirements. Knowing the compliance requirements that must be met offers a baseline to measure how data must be handled throughout the entire app development process, Smith pointed out, adding that once you have the base to build upon, the controls and steps to actually achieve the privacy levels you want will fall into place pretty easily. Finally, Bisson advised DevSecOps professionals to shift security left and empower developers to prevent any credentials or PII from being inadvertently accessible through their code before it makes it to the cloud. âDevSecOps teams should scan code both within company repositories and outside in public repos; on GitHub, for instance. Itâs so easy to clone code that these details and secrets can easily be leaked,â said Bisson.
Consumers donât understand how or where in the development process security is added, and itâs not entirely necessary for them to understand how the sausage is made. The most important concern for them is that their sensitive data is protected at all times. For that to happen most efficiently, data privacy has to be an integral part of DevSecOps.
. It should be a clear and concise document that is accessible by individuals.
the requirements on giving privacy information to data subjects. These are more detailed and specific than in the 
Act 1998 (DPA).
, and has been used by thousands of organisations worldwide. It includes:
; and
) (EU 2016/679 regulation) coming up on 25 May 2018, many organizations are addressing their data gathering, protection and retention needs concerning the privacy of their data for EU citizens and residents. This regulation has many parts, as ISACA has described in many of its 
view is that privacy is an essential part of functionality, the security of the system and its processing activities.
across the entire processing effort for the affected data. This end-to-end need for protection includes collection efforts, retention requirements and even the new âright to be forgottenâ requirement, wherein the customer has the right to request removal of their data from an organizationâs storage.
demands the 
implemented are proactive rather than reactive. As its principal goal, the system needs to prevent issues, releases and successful attacks. The system is to keep privacy events from occurring in the first place.
, the most important point for organizations to understand about GDPR is transparency. The EU wants full disclosure of an organizationâs efforts, documentation, reviews, assessments and results available for independent third-party review at any point. The goal is to ensure privacy managed by these companies is not dependent upon technology or business practices. It needs to be provable to outside parties and, therefore, acceptable. The EU has purposely placed some strong fine structures and responses into this regulation to ensure compliance.
, it has been found that it is good practice to look at these 6 areas for all the collected and retained data, not just EU-based data. This zero-tolerance approach to data breaches is purposely designed to be stringent and strong. Good luck to all in meeting and maintaining the data privacy and security requirements of 
.
