GDPR and Information Security: What you Need to Do

Hackers? What are they? What do they look like? They used to be 17-year-old kids in their parents’ basements. Now, they’re 35-40 years old and associated with organized crime.

What do they do?

  • Malware – probably the most visible, and very volume-driven and opportunistic. Largely subsumed by Ransomware. A few people write the malware, but many people distribute it – sometimes with 24/7 telephone support!
  • APT – Advanced persistent threats are highly targeted malware, attempting to breach and infiltrate your network.
  • Activists – Target- and burst-driven, largely about vandalism.
  • Insiders – for example, Edward Snowdon who was a SharePoint admin.
  • Nation states– probably not as big a risk as the news reports suggest. But how do you define against nations states with big budgets?

And, of course, they all do it for money. We digitalize things, criminals digitize things. They are on their own digitalization journeys.

Example: Equifax

Equifax is a consumer credit reporting agency, that got hacked. They were slow to patch a known bug and in that time they were compromised. This is how hackers work: they get in, they spend a while in the system and they start extracting data.

Example: Software supply chain attack

There are two critical business packages you need to use if you do business in Ukraine. One of them, MeDoc was breached. That software had an automated patching system, but their updating system was hacked and used to release a patch with a backdoor in it. Nobody knows what was done in the after the systems were compromised, but eventually, the hackers released a destructive virus which encrypted people’s computers.

Half of the planet is connected to the internet now. Ransomware is a multi-billion dollar business. There are 200 billion IoT devices connected to the internet. Cybercrime is estimated to reach $6 trillion by 2021.

It’s only going to get more messed up – unless we act – and we need to act together. The General Data Protection Regulation (GDPR) is the first sign that government doesn’t think that business is acting to get this under control.

GDPR

The General Data Protection Regulation protects EU residents, so it affects all companies who hold information. It’s a blunt instrument. It suggests three roles you need to consider:

  1. The data subject – the person whose data is held
  2. The data controller – the person who decides what is done with the data
  3. The data processor – the person who analyzes or acts on the data

The general principle is that you should only hold data for a limited purpose and with permission, you should hold no more than that and you should dispose of it when it is no longer of use.

The six legal grounds for holding information are incredibly important, and you must provide proof you are adhering to them:

  1. Consent
  2. Contractual
  3. Legal Obligation
  4. Vital Interests
  5. Public Task
  6. Legitimate Interest

Be careful of the last: it’s not the escape clause it looks like. There’s a balancing test you need to provide there.

Responsibility is split between vendor and customer.

The IFS Information Security Manifesto, has four key elements:

  1. Safety – keeping everyone in the ecosystem safe
  2. Built-in – security by design and by default
  3. Trusted – we adopt industry best practices
  4. Transparent – we are transparent about our information security and provide the information our customers need

Positioning GDPR in GRC

You need information, governance activities and compliance activities. How do you manage breaches? How do you stay in compliance? If you can define that, you can bring GDPR in the IFS Government Regulatory Compliance (GRC) process.

IFS can support you as a trusted supplier who has put a lot of work into their technology and security process. They have secure-by-design products and are constantly keeping up with change and events and they will use that in their products and communications.