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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 Union’s General Data Protection Regulation, following a similar decision by Austria last month. 

The root of the issue stems from the website’s use of Google Analytics, which functions as a tool for managers to track content performance and page visits. CNIL said the tool’s 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 EU’s top court that invalidated the U.S.’s “Privacy Shield” 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.  

Privacy Shield, which went into effect in August of 2016, was a “self-certification mechanism for companies established in the United States of America,” 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.’s 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.

“Indeed, 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,” 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. 

The privacy watchdog does not call for a ban of Google Analytics, but rather suggests revisions that follow the guidelines. “Concerning 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,” the watchdog said. 

source: https://

/french-data-protection-authority-says-google-analytics-is-in-violation-of-gdpr/

GDPR Practitioner Guide

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.

“Having 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.”

– Chris Prantl

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 haven’t 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 haven’t done so because they do not know how to.

Source: 66% of Workers Risk Breaching GDPR by Printing Work-Related Docs at Home via Infosecurity Magazine

The Information Commissioner’s Office levied fines against British Airways and Marriott International for violating the GDPR.

Source: ‘2019 is the year of enforcement’: GDPR fines have begun – Digiday

British Airways faces $230 million fine over GDPR breach

Marriott Faces GDPR Fines: A DPO and CISO Discussion

Steps to GDPR Compliance

Archived GDPR posts

Subscribe to DISC InfoSec blog by Email

After the ICO issues $450 million of GDPR fines in a week, be sure you’re not next.

Source: 5 ways to avoid a GDPR fine

GDPR For Consultants – Training Webinar

 

What You Need to Know about General Data Protection Regulation

DISC InfoSec – Previous articles in GDPR category

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Discover how to write a GDPR data breach notification procedure to help you with your GDPR compliance. Including a free template example. Read now

Source: How to write a GDPR data breach notification procedure – with template example – IT Governance Blog

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 – “Notification of a personal data breach to the supervisory authority” – and Article 34 of the GDPR – “Communication of a personal data breach to the data subject”.

Help with creating a data breach notification template

The picture above is an example of what a data breach notification might look like – available from the market-leading EU GDPR Documentation Toolkit – which sets out the scope of the procedure, responsibilities and the steps that will be taken by the organization to communicate the breach from:

• Data processor to data controller;
• Data controller to supervisory authority; and
• Data controller to data subject.

 

 

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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:

• Who is collecting the data?
• What data is being collected?
• What is the legal basis for processing the data?
• Will the data be shared with any third parties?
• How will the information be used?
• How long will the data be stored for?
• What rights does the data subject have?
• How can the data subject raise a complaint?

Below is an example of a customisable privacy notice template, available from IT Governance here.

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;
• Direction and guidance from expert GDPR practitioners; and
• Two licences for the GDPR Staff Awareness E-learning Course.

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 participants’ personal information. The 6 main areas for data protection defined in this regulation are:

1. Data security controls need to be, by default, active at all times. Allowing security controls to be optional is not recommended or even suggested. “Always on” is the mantra for protection.
2. 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.
3. 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 “right to be forgotten” requirement, wherein the customer has the right to request removal of their data from an organization’s storage.
4. 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.
5. 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.
6. 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 organization’s 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.

Steps to EU GDPR compliance

 

By Julia Dutton

Organizations have until 25 May 2018 to comply with the EU General Data Protection Regulation (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 organisation’s 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 – both in the environment and inside the organisation – to continually identify and reduce risks.

What does the GDPR say?

The GDPR states clearly in Article 32 that “the 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:

1. the pseudonymisation and encryption of personal data;
2. the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
3. the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;
4. a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.”

Let’s 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 27001’s 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 organisation’s 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 company’s 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.

Related articles:

Read more about ISO 27001 and the GDPR >>>>

GDPR Documentation Toolkit and gap assessment tool >>>>

Understanding the GDPR: General Data Protection Regulation >>>>

 

The GDPR will replace these with a pan-European regulatory framework effective from 25 May 2018.  The GDPR applies to all EU organizations – whether commercial business or public authority – 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 EU’s 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 “sufficient guarantees to implement appropriate technical and organizational measures” to ensure that processing will comply with the GDPR and that data subjects’ rights are protected. This requirement flows down the supply chain, so a processor cannot subcontract work to a second processor without the controller’s 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 “freely given, specific, informed and unambiguous indication of the individual’s wishes”. 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 €20 million of group annual worldwide turnover.

 

Data protection by design – 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:

1. Find out where your personal information resides and prioritize your data.
2. Identify all the risks that could cause a breach of your personal data.
3. Apply the most appropriate measures (controls) to mitigate those risks.
4. Implement the necessary policies and procedures to support the controls.
5. Conduct regular tests and audits to make sure the controls are working as intended.
6. Review, report and update your plans regularly.
7. 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.

Related articles on GDPR and ISO 27k

The GDPR and Personal Data…HELP! from Cloud Security Alliance

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 – and the policy and procedures for its use – to protect information while also determining who controls access to it.
• Understanding legal and regulatory obligations Your final challenge is determining what your organisation’s 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 you’ve completed these three challenges, you’ll 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.

 

Order Today

 

Data Protection / EU GDPR Toolkits

 

 

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:

EU General Data Protection Regulation (GDPR) Documentation Toolkit

By Chloe Biscoe

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 €20 million $23.5 million) – 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 EU–US Privacy Shield provides such a mechanism for compliance.

Almost all US organizations that collect or process EU residents’ 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 EU–US Privacy Shield

August’s 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 EU–US Privacy Shield.

Alan Calder’s EU GDPR & EU-US Privacy Shield – A Pocket Guide explains in simple terms:

• The terms and definitions used within the GDPR and the EU-US Privacy Shield
• The key requirements
• How to comply with the Regulation

 

Data Protection / EU GDPR Toolkits

 

A survey of cybersecurity decision makers found 77 percent think the world is now in a perpetual state of cyberwarfare.

In addition, 82 percent believe geopolitics and cybersecurity are “intrinsically linked,” and two-thirds of polled organizations reported changing their security posture in response to the Russian invasion of Ukraine.

Of those asked, 64 percent believe they may have already been the target of a nation-state-directed cyberattack. Unfortunately, 63 percent of surveyed security leaders also believe that they’d never even know if a nation-state level actor pwned them.

The survey, organized by security shop Venafi, questioned 1,100 security leaders. Kevin Bocek, VP of security strategy and threat intelligence, said the results show cyberwarfare is here, and that it’s completely different to many would have imagined. “Any business can be damaged by nation-states,” he added.

According to Bocek, it’s been common knowledge for some time that government-backed advanced persistent threat (APT) crews are being used to further online geopolitical goals. Unlike conventional warfare, Bocek said, everyone is a target and there’s no military or government method for protecting everyone. 

Nor is there going to be much financial redress available. Earlier this week Lloyd’s of London announced it would no longer recompense policy holders for certain nation-state attacks.

Late on Friday, Facebook agreed in principle to settle a US lawsuit seeking damages for letting third parties, including Cambridge Analytica, access the private data of users. The terms of the settlement have yet to be finalized.

Googlers uncover Charming email scraping tool

Researchers at Google’s Threat Analysis Group (TAG) have detailed email-stealing malware believed to be from Iranian APT Charming Kitten.

The tool, which TAG has dubbed Hyperscrape, is designed to siphon information from Gmail, Yahoo! and Outlook accounts. Hyperscrape runs locally on the infected Windows machine, and is able to iterate through the contents of a targeted inbox and individually download messages. To hide its tracks, it can, among other things, delete emails alerting users to possible intrusions.

Not to be confused with Rocket Kitten, another APT believed to be backed by Iran, Charming Kitten has been hijacking accounts, deploying malware, and using “novel techniques to conduct espionage aligned with the interests of the Iranian government” for years, TAG said. 

In the case of Hyperscrape, it appears the tool is either rarely used, or still being worked on, as Google said it’s only seen fewer than two dozen instances of the software nasty, all located within Iran. 

The malware is limited in terms of its ability to operate, too: it has to be installed locally on a victim’s machine and has dependencies that, if moved from its folder, will break its functionality. Additionally, Hyperscrape “requires the victim’s account credentials to run using a valid, authenticated user session the attacker has hijacked, or credentials the attacker has already acquired,” Google said.

While its use may be rare and its design somewhat restrictive, Hyperscrape is still dangerous malware that Google said it has written about to raise awareness. “We hope doing so will improve understanding of tactics and techniques that will enhance threat hunting capabilities and lead to stronger protections across the industry,” Google security engineer Ajax Bash wrote. 

Security professionals can find the indicators of compromise data for Hyperscrape in Google’s report.

French agency may investigate Google – again

A French governmental agency that has twice fined Google over violations of data privacy regulations and the GDPR has been tipped off by the European Center for Digital Rights (NOYB) about another potential bad practice: dressing up adverts to look like normal email messages.

According to NOYB, Google makes ads appear in Gmail user’s inboxes that appear to be regular emails, which would be a direct violation of the EU’s ePrivacy directive, as folks may not have technically signed up or consented to see this stuff.

“When commercial emails are sent directly to users, they constitute direct marketing emails and are regulated under the ePrivacy directive,” NOYB said. 

Because Google “successfully filters most external spam messages in a separate spam folder,” NOYB claims, when unsolicited messages end up in a user’s inbox it gives the impression it was something they actually signed up for, when that’s not the case.

“EU law already makes it quite clear: the use of email, for the purpose of direct marketing, requires user consent,” NOYB said, referencing an EU Court of Justice press release [PDF] from 2021 that outlines rules surrounding inbox advertising.

“It is quite simple. Spam is a commercial email sent without consent. And it is illegal. Spam does not become legal just because it is generated by the email provider,” said NOYB lawyer Romain Robert.

France’s Data Protection Authority (CNIL) has ruled in opposition to Google’s past behavior before. In February, Google was found to be breaching GDPR regulations by transmitting data to the US. Google has also been fined by the French Competition Authority for not paying French publishers when using their content.

NOYB said in its complaint [PDF] to CNIL that, because it accuses Google of violating the ePrivacy directive and not GDPR, the watchdog has no need to cooperate with, or wait for, the actions of other national data privacy authorities to decide to fine or otherwise penalize the American web giant. 

Nobelium is back with a new post-compromise tool

Microsoft security researchers have described custom software being used by Nobelium, aka Cozy Bear aka the perpetrators of the SolarWinds attack, to maintain access to compromised Windows networks.

Dubbed MagicWeb by Redmond, this malicious Windows DLL, once installed by a high-privileged intruder on an Active Directory Federated Services (ADFS) server, can be used to ensure any user attempting to log in is accepted and authenticated. That’ll help attackers get back into a network if they somehow lose their initial access.

Microsoft noted that MagicWeb is similar to the FoggyWeb malware deployed in 2021, and added that “MagicWeb goes beyond the collection capabilities of FoggyWeb by facilitating covert access directly.” 

This isn’t a theoretical malware sample, either: Microsoft said it found a real-world example of MagicWeb in action during an incident response investigation. According to Microsoft, the attacker had admin access to the ADFS system, and replaced a legitimate DLL with the MagicWeb DLL, “causing malware to be loaded by ADFS instead of the legitimate binary.”

MagicWeb is a post-compromise malware that requires the attacker to already have privileged access to their target’s Windows systems. Microsoft recommends treating ADFS servers as top tier assets and protecting them just like one would a domain controller. 

Additionally, Microsoft recommends domain administrators enable Inventory Certificate Issuance policies in PKI environments, use verbose event logging, and look out for Event ID 501, which indicates a MagicWeb infection. 

Redmond said organizations can also avoid a MagicWeb infection by keeping an eye out for executable files located in the Global Assembly Cache (GAC) or ADFS directories that haven’t been signed by Microsoft, and adding AD FS and GAC directories to auditing scans. 

Anti-cheat software hijacked for killing AV

It turns out role-playing game Genshin Impact’s anti-cheat software can be, and is being, used by miscreants to kill antivirus on victims’ Windows computers before mass-deploying ransomware across a network.

TrendMicro said it spotted mhyprot2.sys, the kernel-mode anti-cheat driver used by Genshin, being used kinda like a rootkit by intruders to turn off end-point protection on machines. The software is designed to kill off unwanted processes, such as cheat programs.

You don’t have to have the game installed on your PC to be at risk, as ransomware slingers can drop a copy of the driver on victims’ computers and use it from there.

It has the privileges, code signing, and features needed by extortionists to make their roll out of ransomware a cinch, we’re told. TrendMicro recommends keeping a look out for unexpected installations of the mhyprot2 driver, which should show up in the Windows Event Log, among other steps detailed in the link above. ®

https://www.theregister.com/2022/08/27/in-brief-security/

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We’ve all been feeling the effects of inflation recently. Prices rose by 8.2% in the twelve months to June 2022, with the largest increases being seen in electricity, gas and transport prices.

Meanwhile, the cost of renting commercial property continues to rise, despite the decreased demand for office space amid the uptick in remote work.

It should be obvious why costs are on the rise; substantial disruption remains related to COVID-19, Russia’s invasion of Ukraine has disrupted supply chains and interest rates have been raised several times this year.

The Bank of England says that the causes of rising inflation are not likely to last, but it has warned that the prices of certain things may never come down.

Clearly, then, rising costs are not simply a temporary issue that we must get through. We must instead carefully plan for how we will deal with increased costs on a permanent basis.

One apparent measure is to look at ways your organisation can cut costs. For better or worse, the most likely targets will be parts of the business that don’t contribute to a direct return on investment.

However, before you start slashing budgets, you should consider the full effects of your decisions.

Take cyber security for example. It’s already notoriously underfunded, with IT teams and other decision makers being forced to make do with limited resources.

According to a Kaspersky report, a quarter of UK companies admit underfunding cyber security even though 82% of respondents have suffered data breaches.

The risk of cyber security incidents is even higher in the summer months, when staff holidays mean that cyber security resources are even more stretched than usual.

What’s at stake?

The global cost of cyber crime is predicted to reach $10.5 trillion (£8.8 trillion) in the next three years, more than triple the $3 trillion (£2.5 trillion) cost in 2015.

We’ve reached record numbers of phishing attacks, with the Anti-Phishing Working Group detecting more than one million bogus emails last quarter. Meanwhile, there were more ransomware attacks in the first quarter of 2022 than there were in the whole of 2021.

These are worrying signs for organisations, and an economic downturn will only make cyber criminals more determined to make money – especially as they know their targets are focusing on cutting costs.

But it’s not just the immediate costs associated with cyber attacks and disruption that organisations should be worried about. There are also long-term effects, whether that’s lingering operational disruption, reputational damage or regulatory action.

Consider the ongoing problems that British Airways faced after it suffered a cyber attack in 2018. It took the airline more than two months to detect the breach, creating enduring difficulties and ultimately resulting in a £20 million fine.

The ICO (Information Commissioner’s Office), which investigated the incident, found that British Airways was processing a significant amount of personal data without adequate security measures in place, and had it addressed those vulnerabilities, it would have prevented the attack.

There were several measures that British Airways could have used to mitigate or prevent the damage, including:

• Applying access controls to applications, data and tools to ensure individuals could only access information relevant to their job;
• Performing penetration tests to spot weaknesses; and
• Implementing multi-factor authentication.

In addition to the fine, British Airways settled a class action from as many as 16,000 claimants. The amount of the settlement remains confidential, but the cost of the payout was estimated to be as much as £2,000 per person.

Remarkably, the penalty and the class action represent a case of strikingly good fortune for British Airways. Had it come earlier, it would have been at the height of the COVID-19 pandemic when airlines were severely affected, and were it any later, it would have come during a period of massive inflation.

It’s a lesson that other organisations must take to heart. The GDPR is being actively enforced throughout the EU and UK, so organisations must ensure compliance.

Failure to do so will result in unforeseen costs at a time when every precaution must be taken to reduce costs.

Invest today, secure tomorrow

It’s long been accepted that it’s a matter of ‘when’ rather than ‘if’ you will suffer a cyber attack. When you do, you’ll have to invest heavily in security solutions on top of having to paying remediation costs.

In times of uncertainty, you need your services to be as reliable as possible. The challenges your organisation will face in the coming months as a result of falling consumer confidence are enough to deal with without having to contend with cyber crime and its inevitable fallout.

Investing in effective cyber security measures will enable your organisation to make the most of its opportunities in straightened circumstances.

You can find out how you can bolster your organisation’s defences quickly and efficiently with IT Governance’s range of training courses.

We want to help our customers get the most from their cyber security training this August.

Book any classroom, Live Online or self-paced training course before the end of this month and automatically receive:

• A free Cyber Security for Executive Management Self-Paced Online Training Course; and
• A free 1-year licence for the Cyber Resilience Staff Awareness E-learning Suite.

Organisations Must Invest in Cyber Defences Before It’s Too Late

How to choose the most appropriate training

When implementing and maintaining a management system, it becomes vitally important to ensure that you have acquired adequate knowledge of the standard to ensure success. It does not matter if you are considering ISO 27001:2013 for information security, ISO 9001:2015 for quality management, or ISO 14001:2015 for environmental management, gaining the necessary knowledge about the standard requirements is an important first step to implementing. However, it can be difficult to pick the right course.

Below is a table explaining the different training courses available, including duration and suggested participants:

Which course should you choose?

So, with all of the training course options available, how do you pick the right course? This is very much dependent on which role you will play in the implementation and maintenance of the management system.

Here is a bit about the different types of courses to help you decide:

• Foundations course – Do you just need to understand the basics of the ISO standard? Then the foundations course might be what you want. This course becomes invaluable if you will have expert assistance for your implementation, but need to have a good overall understanding of the requirements. For instance, if you will have a consultant, but want to know what to do when they are done, then an overall understanding of the ISO standard could be enough knowledge.
• Data protection officer course – With the EU General Data Protection Regulation (GDPR) governing how personal information needs to be protected, you will want to have a main person in charge of meeting this regulation: the data protection officer. If this will be you, then the EU GDPR data protection officer course is what you need to understand the ins and outs of this regulation and what it means for your business.
• Internal auditor course – All management systems include a process for your organization to perform an audit of your processes internally to your organization to confirm for yourself that your processes are happening as you planned them to. If you will be one of the internal auditors who will perform these process audits, then this course will help you to understand not only the requirements of the standard, but also the requirements of how to perform a process audit to confirm conformity and find opportunities for improvement in your organization.
• Lead implementer course – The main person in charge of implementing the management system needs more than just a passing understanding of the standard requirements. If this will be you, then the lead implementer course will give you a more in-depth knowledge of what the standard requires, as well as knowledge of how to implement the requirements at your organization with practical tools to help. If you are going to be a consultant for others, this course is also an invaluable tool, with certification an option to demonstrate your competence.
• Lead auditor course – With the ISO management system standard, many companies will choose to apply for certification as an independent method to demonstrate their compliance with the standard. This process is done by auditors from a third-party, independent certification body who will confirm that the processes you have implemented meet the requirements of the ISO standard. The auditors who will perform these audits need to pass the examination for lead auditor certification. If you are performing internal audits for a company, this training can also be beneficial, as it allows you to understand the training taken by the certification auditors.

Find the training that is right for you

Remember, when picking the training, you should first think about how you will apply the knowledge to ensure you choose the most suitable training for your current or future role. You don’t want to finish training only to find that how you are intended to apply your newfound skills is incompatible with the knowledge gained, as you may then need to re-take additional training for the new role. Choose the right training from the start, and you can be better assured that your utilization of the knowledge will be better applied, and your management system implementation will be easier.

Putting PCI-DSS in Perspective

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 ‘real world’ 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 today’s digital economy, however, agile cyber criminals will not only ‘go’ as Mr. Hutton suggested “where the money is” but will swiftly adapt and evolve their tactics to ‘go where the insecurity is.’ Hence, whilst according to a range of sources EMV chip cards have cut counterfeit fraud at ‘point of sale’ (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 ‘card not present’ (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 isn’t 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: “PCI JUST DOESN’T APPLY TO OUR BUSINESS/ ORGANIZATION/VERTICAL/SECTOR.”

It doesn’t matter if you don’t consider yourself a fully-fledged business, if it’s 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: “PCI APPLIES TO OUR WHOLE ENVIRONMENT, EVERYWHERE, AND WE SIMPLY CAN’T APPLY SUCH AN OBDURATE STANDARD TO IT ALL.”

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. It’s 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: “OUTSOURCING TRANSFERS OUR PCI RISK.”

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 ‘heavy lifting’ 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 merchant’s responsibility to appropriately manage their providers. At the very least via written agreements, policies and procedures. The service provider’s own compliance scope must, therefore, be fully understood and its status continually monitored.

It is important to consider that this doesn’t 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. It’s 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: “COMPENSATORY MEANS WE CAN HAVE SOME COMPLACENCY.”

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 ‘soft option,’ however, nor a way of ‘getting around’ 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 ‘above and beyond’ 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: “WE BOUGHT A PCI SOLUTION SO WE MUST BE COMPLIANT, RIGHT?”

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 ‘snake oil.’ Or both.

MYTH 6: “WE’RE PCI-DSS COMPLIANT SO THAT MEANS WE MUST BE ‘SECURE,’ RIGHT?”

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 ‘secure’ 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 organization’s 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 weren’t. Something that is to everyone’s 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, it’s all far from perfect, but in the sage fictional words of Marvel’s Nick Fury, “SHIELD takes the world as it is, not as we’d like it to be. It’s getting damn near past time for you to get with that program.”

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 King’s Service Centre supporting the services of King’s College London, one of the worlds’ top 20 universities

PCI-DSS QSA Certification – Practice Questions 2022: Questions that will help you practice and advance your knowledge on the PCI-DSS QSA

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As data privacy laws expand, businesses must employ protection methods

Data protection is challenging for many businesses because the United States does not currently have a national privacy law  —  like the EU’s GDPR  —  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 state’s 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*  —  or any combination of the four —  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 states’ 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  —  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 “processing activities involving personal data that present a heightened risk of harm to consumers.” However, the law does not explicitly define what it considers to be “heightened risk.” 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 “significant” 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, let’s 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  —  Colorado only recognizes its assessment requirements to meet compliance.

Another area where the laws differ is how each defines sensitive data. The CPRA’s 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 consumer’s sex life and mental and physical health conditions as sensitive data, whereas VCDPA does not. Conversely, Virginia considers a consumer’s 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 — 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 — such as data masking, tokenization and encryption — 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, “An ounce of prevention is worth a pound of cure,” is undoubtedly valid for data protection — 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.

Data Privacy Law: A Practical Guide to the GDPR

Information Privacy Engineering and Privacy by Design: Understanding Privacy Threats, Technology, and Regulations Based on Standards and Best Practices

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