GDPR Vulture

Want on the GDPR Bandwagon? Be Qualified, or Stay the Hell Off!

First, what do I mean by ‘qualified’? – I mean that the only people truly qualified to lead a GDPR project are lawyers specialising in privacy. That’s it.

EVERYONE else only has a part to play. Often a very significant part, but that’s it for them as well. A part.

I’m NOT saying that every single organisation has to make the significant investment in a privacy lawyer to meet the intent of GDPR. I’m saying that the only ones qualified to determine ‘intent’ in your organisation’s specific context, are privacy lawyers. No-one who is an expert in information technology, or cybersecurity, or any other subject is qualified …unless they are also a privacy lawyer.

To even further labour the point, a qualified person is neverCertified EU General Data Protection Regulation Practitioner …unless – you guessed it – they are also a privacy lawyer.

I’ve seen every type of vendor from Cyber Insurance providers, cybersecurity consultants, to single-function technology vendors, make the most ridiculous claims as to their suitability to ‘help’ with GDPR. All to make a bit more money while the GDPR bandwagon is on the roll.

The prize so far goes to a consultant who maintains that the entire GDPR can be ‘operationalized’ under the ISO 27001 standard. Unfortunately this attitude is pervasive, as no organisation seems to want to share the opportunity with appropriate partners. The attitude of ‘land-the-gig-and-we’ll-work-out-how-to-deliver-it-later’ cannot apply here. GDPR is a law, one with significant penalties attached, so unless you really know what you’re doing, stick to what you know. And ONLY what you know.

For example, I can be [very] loosely categorised as a ‘cybersecurity expert’, so that limits my ability to help with GDPR to:

  1. Data Security – As I’ve said a few times now, of the 778 individual lines of the GDPR Articles, only 26 of them are related directly to data security. That’s only 3.34%. Yes, I can help you implement ISO 27001 to cover that 3.34% (a.k.a. “appropriate security and confidentiality”), but if GDPR is the only reason you have to implement ISO, don’t bother, you’ve missed the point;
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  2. Secure Technology Implementation – GDPR is not about technology, but the implementation of GDPR will have significant technology implications. From collection of consent (Recital 32), to age identification (Recital 38), to the rights to erasure and rectification (Recital 39), technology will play a big role. All of this technology will require appropriate security wrappers in-line with demonstrable good security practices; and
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  3. Governance Design and Implementation – Any organisation that has a Governance function already has a GDPR Implementation Team in place. Since there can be no true Governance without full departmental representation (Technology, Security, Legal, PMO, Sales, Marketing and so on), it follows that the Security team will have full understanding of GDPR’s impact from the Legal team. In turn, Technology and Security will have significant input to Legal’s decisioning, and it’s this ‘negotiation’ under the Governance umbrella that gives GDPR its ‘organisation specific context’.

This should be more than enough for any security consultant, but apparently it’s not enough for some consultants who want to replace Governance all by themselves. But, what’s wrong with partnering up with others to do the parts you absolutely should not touch? Is it not better to be really good at the one thing you do for a living and be part of a team of experts who can cover the other bases?

To put this another way, do you really want to ruin your reputation by lying to your clients now, or be the resource they come to to solve every similar problem from this point forward? Do you want to sell used cars or be a trusted advisor?

GDPR, like security, is not complicated. It’s actually very simple, just BLOODY difficult to implement. There is not one individual who can simplify this for you, not even a privacy lawyer. So if you’re looking to implement GDPR, you can rest assured that anyone who is a) not a privacy layer, AND 2) not part of a team of experts with collaborative skill-sets, AND 3) trying to sell you something, should be listened to with caution.

As always, I am not going to lay the blame entirely at vendor’s feet, they too have a business to run. In the end, the only people who get the answers they need on GDPR are the ones asking the right questions.

You MUST do your homework!

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Human Resources

Human Resources, the Missing Piece From Every Security Program

Like a ‘service on the Internet’ – which we’ve had for decades – is now called The Cloud, Human Resources is now known by more touchy-feely names. Talent, People, Employee Success, all sound great, but they don’t represent a fundamental shift in the functions they perform. Or even HOW they perform those function from what I’ve seen.

Regardless of what the department is called, I’ve never seen one take an active part in their organisation’s security program. Not one, in the better part of 20 years, and as I hope to demonstrate, this a significant loss to everyone concerned.

HR are usually the very first people in an organisation that you talk to, often even before the interview process begins. They are first ones who can instill the security culture in new candidates from the get-go. Anyone who has tried to implement a security awareness program knows that the loss of this ‘first impression’ makes the task exceedingly difficult. Unnecessarily so. If the joiners had just been told how important security is, AND received appropriate training, they would just accept it as a fact of life. Try and force it on them after they have already learned the bad behaviours and your impact is enormously reduced.

But there are 5 fundamental areas in security, that with HR’s help, would be significantly more effective:

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  1. Onboarding – As I have already stated above, HR are the first people with whom new employees have interaction. The onboarding process is the perfect time to get everything out on the table. From Acceptable Use Policy / Code of Conduct, to security awareness training, security can be instilled from the very beginning. Now imagine if the CEO had a welcome letter prepared that emphasised the importance of data protection / privacy. Imagine further that this letter detailed what is expected them, and to take this aspect of their jobs seriously. There is ZERO cost associated with any of this, yet the positive impact of the security culture is immeasurable.
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  2. Role Based Access Control – The hint is in the title; ROLE based. If HR broke the org chart into specific roles, granting appropriate access to all joiners, movers , and leavers would be that much simpler. In theory, everyone gets what I call ‘base access’, usually consisting of email address and domain access. A role could then receive everything they need to perform their basic job functions automatically. Then, an individual could apply for any additional access they require. Everything is now recorded appropriately, allowing for not only a demonstrable access control process, but the raw material for all access reviews. Especially those with elevated privileges.
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  3. Policies, Standards, and Procedures – If you accept that policies represent the distillation of the corporate culture, standards are the baselines of ‘known good’ configurations, and procedures are the sum of all corporate knowledge, why aren’t these distributed at the beginning? First, most organisations don’t even HAVE these documents in place, at least not in a condition to meet the above criteria anyway. Second, even if they did exist, HR take no part in their distribution. Why not? If they assisted with RBAC per 2. above, surely it’s a simple step to have the relevant department heads which documents should be attributed to a specific role? Can you imagine it, every new employee knows 1) what they should and should not do, 2) how to do it, and 3) what to do it with!
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  4. Security Awareness Training – OK, so HR are not security experts and will take very little part in developing the SAT content, but they should be involved in HOW it’s delivered. HR are the people experts, IT and IS professions are usually quite the opposite. Training written by me would suit technical people, who’s going to write it for everyone else? After all, it’s usually the ‘everyone else’ who are the cause of most of the issues. HR should also be tracking the annual SAT program and flagging any issues to the employee’s supervisor etc.
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  5. Role Specific Procedures – This one is a bit of a stretch, but I can’t just have 4 bullet points. The concept is that part of everyone’s job description is to document every one of their repeatable tasks. If the procedure already exists, they could be challenged to improve it. In almost every job I’ve had there was a 3 month probation period. This review, and every performance review from that point forward could include a procedure section where failure to develop appropriate content has negative repercussions. Or, for the glass-half-full folks, great documentation has rewards attached to it. Imagine how nice it would be is every new starter just moved forward and didn’t have to waste time re-inventing the wheel.

The fact is most HR departments are not geared to perform any of the above functions. They are simply not trained to do so. I can’t help thinking this is a terrible waste.

I’d actually love to hear from some HR folks, even if you’re gonna tell me I’m way out of line! 🙂

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PCI to GDPR

Going From PCI to GDPR? You Are Starting from Square One

To be very clear from the outset, if you think the PCI DSS is a good ‘stepping stone’ to GDPR, you need to do a lot more homework. Data security represents less than 5% of the entire GDPR, and the PCI DSS is – in my admittedly biased estimation – no more than 33% of a true security program.

I have, for years, railed against the PCI DSS as an inadequate baseline for security, and even the card brands and the SSC have never claimed it be more than what it is; a set of MINIMUM security control related to the protection of cardholder data. Well, except for this ill-advised and rather naive quote perhaps;

People come to me and say, ‘How do I achieve GDPR compliance?’… Start with PCI DSS.

The PCI DSS was written for ONE very specific purpose, and it’s only ego, desperation, or vested interest that would lead people to think it’s anything more.

The reason for this particular blog is reading articles like the two samples below. It’s articles like these that lead organisations who don’t know better [yet] into making bad decisions. They also give cybersecurity professionals a bad name. Well, worse name, unscrupulous QSA companies and greedy product vendors have already caused significant damage.

Article 1, and by far the most egregiously overstated quote [so far] is from an article in SecurityWeek (PCI 3.2 Compliant Organizations Are Likely GDPR Compliant); “Any company that fully and successfully implements PCI DSS 3.2 is likely to be fully GDPR compliant — it’s a case of buy one and get one free.” Given the author’s apparent credentials, he should know better. Since when does the PCI DSS deal with explicit consent, or children’s data, or the right to erasure/correction/objection/portability and so on.

Then, in the very recent article 2; How the PCI DSS can help you meet the requirements of the GDPR – the author states that; “Failure to report breaches attracts fines of up to €10 million or 2% of annual turnover, whichever is higher. Breaches or failure to uphold the sixth data protection principle (maintaining confidentiality and integrity of personal data) can attract fines of up to €20 million or 4% of annual turnover (whichever is higher).

No part of the above statement is factually correct:

  1. Just because Article 33 – Notification of a personal data breach to the supervisory authority is included in Article 83(4)(a) – General conditions for imposing administrative fines, it does NOT mean that failure to respond in 72 hours will attract a fine. There are many caveats; e.g. Recital 85 states ; “the controller should notify the personal data breach to the supervisory authority without undue delay and, where feasible, not later than 72 hours after having become aware of it (Recital 85)”‘
  2. sixth data protection principle“? – Nothing to do with confidentiality and integrity, assume author meant the seventh principle (security).
  3. Maximum fines for data breaches are 2% (for an undertaking, a.k.a. a group of companies), not 4%.

The author then goes on to say; “The ICO is also likely to treat inadequate or non-implementation of the PCI DSS as a failure to implement appropriate “technical and organisational measures” to protect personal data…” which is clearly not the case. The ICO has always left loss of cardholder data / PCI up to the card schemes, and have already mentioned ISO 27001 in their “The Guide to Data Protection“.

Every article I have read on how PCI helps with GDPR, is at best, hugely overstated, and at worst, full of self-serving lies. I can fully appreciate the desire for cybersecurity companies (especially QSAs) to branch out from the massively price compressed and ultimately doomed PCI space, but to do so in this manner is unconscionable.

Unfortunately if you are falling for this advice, I can safely assume that you:

  1. have little idea of how limited the PCI DSS is, even as protection for the only form of data to which it’s relevant;
  2. have little idea what the GDPR is trying to achieve if you think a bunch of security controls are that significant a component; and
  3. don’t actually know what an ‘appropriate’ security program should look like.

This is actually not meant as a criticism, these things may not be your job, but if you have any responsibility for GDPR, you absolutely must learn to ask the right questions.  I will finish with some reasoning below, but leave to up to you work out whose guidance to take.

PCI and GDPR are very far removed from each other.

  1. Data protection Articles are only 3.34% of the Regulation – yes, I actually worked this out on a spreadsheet. That means the GDPR is 96.66% NOT security control relevant. Of course IT and IT security are important and intrinsic to GDPR, but PCI does not cover anything else other than than those things.;
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  2. PCI DSS makes no mention of the need for Governance – PCI compliance is almost invariably an IT project, and while this is obviously wrong, does not prevent organisations from achieving compliance. In GDPR, the IT folks have absolutely no idea where to start. Nor should they, IT/IS people aren’t lawyers and they do not control the organisation’s direction, they are business enablers who do as bid by senior management. GDPR requires a team effort from every department, which is exactly what Governance is.;
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  3. PCI DSS is about compliance to an already defined standard of security controls, the GDPR requires a demonstration of ‘appropriate security’ measures – For example, what if your annual risk assessment showed that the PCI controls were actually excessive? Could you scale some of them back? No, you can’t. Alternatively, what if your risk assessment showed that they weren’t enough, could your QSA insist that you went above and beyond? Again, no, so what the hell is the point of the risk assessment in PCI?
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  4. Only QSAs that started out as security consultants [not the other way around] have the skill-set to provide any help at all. If they were experts in ISO 27001, CoBIT, NIST etc., then yes, they can help you both define and implement ‘appropriate security’. If all they did was pass the QSA exam, the only guarantee you have is that they can read.
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  5. The PCI DSS can never keep pace with the threat landscape – It’s already way behind, and with its complete inability to change significantly, the DSS can never represent appropriate security. If the DSS did change significantly, both the card brands and the SSC would be lynched. Millions of organisations have spent BILLIONS on PCI, they will simply refuse to start all over again. GDPR on the other hand has no defined controls, it’s up to YOU to show that your controls meet the measured risk.

In the end, the only way PCI can help with GDPR is to use the assigned budget to do security properly. You will never reach GDPR ‘compliance‘ using PCI, but you will achieve both PCI and GDPR compliance on the way to real security.

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Wishes

So You Want to be a Cybersecurity Professional? – Redux

At the end of last year I wrote a blog that proved to be my most popular yet, by several orders of magnitude. In So You Want to be a Cybersecurity Professional? I threw together some very high-level thoughts for those wishing to get into the field. However, it’s wasn’t until the last week or so that it occurred to me to question why this blog in particular resonated as it did.

On the assumption that it’s because there are literally thousands of people out there struggling to find their way into security, I figured I’d expand a little on the original.

With the proliferation of both certifications and U”niversity degrees, there are many avenues that attempt to fast-track cybersecurity careers. Add to this a ridiculous number of ‘new’ technologies all claiming to address a rapidly growing number of threats and regulatory compliance regimes, and you have a combination that could not be better planned to lead candidates to a career dead-end.

The new modus operandi for cybersecurity professionals seems to be; University degree > industry certifications > Technology. But if your ultimate goal is CSO/CISO you have derailed yourself even before you start. I do not know one CSO/CISO who is primarily focused on technology …not any good ones anyway. It’s the people and processes that give technology context, not the other way around.

No course on the planet can teach you people and process, that’s something you must to learn for yourself. In security, experience is key.

While technology is an indispensable aspect of security, the majority of the product and security vendors who say they are trying to help are actually causing enormous damage. In their mad rush to stake a claim to a piece of multi-billion $/£/€/¥ security industry (and still growing), they are developing technologies so far removed from the basic principles as to be almost unrecognisable. Not only are these largely inappropriate to most businesses, but far too fleeting and ethereal to ever be rely on as a career foundation.

While I assume most University degrees will cover the ages-old basics of governance, policy & procedure, risk management etc. (like the CISSP’s CBKs do), without a real-world understanding of their implementation you will never be able to put a technology into a context your clients or employer has the right to expect. Basically you will be lost in a never-ending cycle of throwing technology after technology at something that could likely be fixed by adjusting the very business processes you’re trying to protect. Technology can only enhance what’s already working, it cannot fix what’s broken.

So where should new candidates start? I have no issue with University degrees or certifications, but from my own experience it was starting out at the most basic level that gave me the greatest foundation. From firewall and IDS administrator, to a stint in a 24X7 managed security service security operations centre I received an education that has stood the test of time. Networking, protocols, secure architecture, system management, incident response / disaster recovery, and just as important; the power of great paperwork. There is no-one who appreciates a comprehensive set of procedures and standards as someone who has just taken down a client’s firewall.

For the next phase of my career I was, for want of a better word, lucky. PCI was just kicking off and the desperate shortage of QSAs meant it was relatively easy for me to become one and be thrown immediately in front of customers. I learned as much in the next year as I did in the preceding 5. Not technical stuff per se, though that was certainly part of it, but the soft skills necessary to provide a good service.

From that point forward I have stayed in consulting, as I am fully aware of that is where both my interest and skill-set lay. I am not technical, never have been, so I’ll leave that up to others. I have also never wanted to be a high-level executive, that’s too far removed from anything I have ever enjoyed. What this means is, I already know a CISO role is very likely not in my future, and I’m absolutely fine with that.

I have my own thoughts in what a CISO is anyway.

I’m not saying that CSO/CISO need be your goal, if you’re quite happy managing firewalls, that’s great, but you absolutely have to know what your goal is or you’ll flounder around the edges of security missing every boat that comes along.

So:

  1. If you want to be a CISO, remember that the vast majority of the CISO function is just a series of consulting projects designed to help the business meet its goals. The final aspect of a CSO’s job borders of politics, so that had better be what you want.
  2. If you love technology, great, but get an understanding of how your technology(ies) fits into the client’s business goals before trying to shove it down their throats. And jumping straight out of Uni into a technology start-up may seem like a good move, but only 1 in 1,000 companies make any difference. Be prepared to fail many times.
  3. If consulting is your thing, stay high-level and stay with the basics. Be the person that your clients come to to solve their challenges, regardless of who ends up performing the actual remediation. A Trusted Advisor is a very rare thing, and very few ever earn it.

Regardless of your career goal, the basics of security will never change, and you will only be at the top of your game when what you are doing benefits everyone involved.

Finally, a warning: if you think anyone other than those making a career out of it care about security, you are mistaken. Not one, I repeat not ONE of my clients actually cares about security, they care about things ranging from genuine concern for their customers to just money. Security is only, and will only ever be, a means to an end. It enables a business, it does not direct one. It’s these things that you cannot learn from school or from technology alone.

Get a mentor, one who has been where you are and is where you want to be. And never, I mean NEVER follow the money.

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Policies & Procedures

Information Security Policy Set: It All Starts Here

Information Security Policies, or more accurately; Policies, Standards, & Procedures (a Policy Set) are the cornerstone of every security program. It is therefore rather odd, that not one client I have ever helped started with any of them in place. While not everyone is a security expert, everyone can be security savvy enough if, and ONLY if, what they are supposed to do is written down!

That’s what a good Policy Set is; an instruction manual on what to do, what not to do, why, and how.

I have written too many many times on why a good Policy Set is important, and have used the term ‘baseline’ more times than I’ve had hot dinners. I have described what a Policy Set consists of, and even how to manage one, but what I have not do up till now was to describe how to find a Policy Set that’s right for your business.

First, you may be wondering what’s so hard about finding policies. And I agree; type “information security policy example” into Google and you’ll get tens of millions of hits. Universities readily publish theirs for the world to see (e.g University of Bristol), and a whole host of organisations even make editable versions freely available. On top of that, online services with ridiculous promises like “THE ONLY WAY TO GET AN INFORMATION SECURITY POLICY CUSTOMIZED FOR YOU IN AN HOUR, GUARANTEED.” are depressingly common.

The challenge is that if you’re looking for information security policies in this fashion you clearly have no experience implementing them, let alone actually writing one yourself. An overly-dramatic analogy; I found thousands of instructions on emergency appendectomies, would you now trust me to perform one on you? A good Policy Set is one that is appropriate to your business. Not your industry sector, not the prevailing regulatory requirement, your business!

Therefore, if you don’t have security expertise in-house, it is very unlikely that you know the right questions to asks providers of Policy Sets. The vast majority of vendors will sell you what you ask for (can’t really blame them for this), so ensuring you get what you actually need is entirely based on the homework you performed beforehand.

To that end I have written something vaguely resembling a white paper to help you. In the imaginatively named ‘Choosing the Right Policy Set‘ I have broken the choosing of a policy set vendor into 15 Questions. These could easily form the core of an RFI or RFP if you were taking this seriously enough.

Simple questions like; “Can you provide a Document Management Standard and Procedure?” or “Does your service include a mapping of policy statements to the PCI DSS?” are sometimes not even considered. But when you consider that the choosing of a policy set can be the difference between compliance and non-compliance, it makes sense to ask them. Up front!

90% of organisation will end up either throwing something together themselves, or buying the cheapest option available. That’s fine, when regulatory fines start getting handed out they will realise just how expensive their choice was.

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