Reasonable Security Measures

GDPR: How Do You Define ‘Appropriate’ Security Measures?

Ask a lawyer what ‘appropriate’ or ‘reasonable’ means and they’ll come back with something like; “What would be considered fair by a disinterested third party with sufficient knowledge of the facts.”, or “Fair, proper, or moderate under the circumstances.”

Now translate that into what kind of security measures are considered appropriate? How would you justify that what you are doing is reasonable, fair, or proper under the circumstances?

Because that’s what you’ll have to do if things go wrong under GDPR. You’ll have to justify that the measures you took to protect personal data were underpinned by an appropriate program for measuring and treating risk. If your breach was shown to be anything other than a determined attacker, all you’ll have in your defence will be poor excuses. This is no better than negligence.

When you consider that the General Data Protection Regulation (GDPR) – and every other regulatory compliance for the matter – was written by lawyers, should we not be able to work out what ‘appropriate’ means for a security program? After all, lawyers have no problem defining the word ‘reasonable’, they even apply it to their fees!

The good news is that the process is not only well known, it’s simple; it’s called Risk Management, and it’s been around for decades.

Step 1: Complete your Asset Register;

Step 2: Map your assets to your business processes (which should already be mapped to revenue);

Step 3: Map your business processes to your business goals;

Step 4: Run a Risk Assessment against all business processes and / or key IT systems;

Step 5: Document the business impact of each risk (mapped against both revenue and business goals);

Step 6: Document Senior Leadership’s risk appetite against each business goal;

Step 7: Perform full analysis of security controls, determine if there are any gaps between the current state and the risk appetite;

Step 8: Fill the gaps;

Step 9: Document everything; and

Step 10: Repeat annually, or prior to any major changes.

Now put yourself in the shoes of an auditor after you have been breached. What are they going to task you for? What could anyone reasonably expect of you to have in place if you were taking your duties seriously?

If I was an auditor I’d ask for 5 things up front, as without them I know there is no way you have an appropriate security program in place:

  1. A mapping of your policies, standard and procedures to whatever security framework you based your on;
  2. Your risk assessment procedure, and the results of the last one conducted;
  3. Your risk register;
  4. Your change control procedure; and
  5. Your incident response procedure.

At this stage I would care nothing for your technology, or how much you spent on it. A technology purchase outside of a properly defined business need is nothing more than smoke and mirrors. Besides, no regulator has ever tried to qualify how much you spent. It’s up to you to show why you spent what you did, and why you didn’t spend more.

Thing thing to bear in mind here is that the validation of ‘appropriateness’ is not a conversation, it’s documentation. It’s not even evidence of the technologies you have running, it’s showing that the technologies you do have meet the risk you have defined. While from a lawyer’s perspective, appropriate is demonstrated by precedent, in cybersecurity, appropriate is demonstrated by the extent and capability of your security program.

Complying with the cybersecurity of the GDPR is simple, every step is written down for you somewhere. There are a few things to bear in mind though:

  1. GDPR is 90% about how you get the data, and what you then do with it when you have it. Anything you spend on security should be justified against the business goals, not a compliance requirement;
  2. There is no cyber insurance against loss of reputation, this should not be about the money;
  3. Any security vendor offering “GDPR Compliance” is at best telling you 10% of the story, at worst, is lying to you.

While I agree it may be difficult to sort through the good advice and the crap when it come to this stuff, there is no excuse for  doing nothing. GDPR and every regulation to come will not change the basics, security will be same regardless.

The issue is not regulation, it’s that organisations still aren’t asking the right questions.

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ISO 27001 Certification

ISO 27001 Certification, Is It Really Worth It?

For the last decade, ISO 27001 certification has been the de facto standard for security programs across the globe. The only problem is, few organisations can be bothered with it. In the years of its existence, I have been asked about implementing a total of twice.

Why?

The reasons are numerous, and vary from organisation to organisation. However, they most often fall within these categories. The client has:

  1. never actually heard of it;
  2. doesn’t care about cybersecurity;
  3. thinks it’s too difficult;
  4. thinks it’s too expensive; and
  5. cannot see a return on investment (ROI).

But the biggest reason I have not been involved in ISO that much?… The Payment Card Industry Data Security Standard (PCI DSS). Which coincidentally, began at almost the same time.

All by itself, PCI has sucked the security budgets out of enough organisations that there was little left for anything else. And if I’m honest, because of PCI, I haven’t had to go looking for any other work.

Think about that for just a minute…

A very basic, controls-only standard, related to a single form of data, that’s not even a law has driven enough business my way that I have not had to worry about diversifying.

And frankly, I still don’t, but with what’s going on here in the EU, we are all going to need something better. From the General Data Protection Regulation (GDPR) to the Payment Services Directive (PSD2), the regulatory landscape is finally making real security a necessity.

It follows therefore that organisations will begin looking to ISO for options.

And that’s really the point, can the ISO standards actually help, or is the 2700X series just a bunch of meaningless paperwork? At first glance, it certainly looks that way, and few organisations choose to go any further. And the ones that do, get so lost in the paperwork that they forget why they are doing it. It’s only when the framework is fully customised and implemented, that you see its true and significant benefits.

However, before you look to ISO, you absolutely MUST do your homework! You have to know exactly what an Information Security Management System (ISMS) is, why you’re doing it, and how you’re going to keep it going. If you can’t answer those questions, don’t start, because you will never cross the finish line.

The biggest killers of ISO certification projects, are, in this order:

  1. Grossly underestimating the level of effort;
  2. Doing it just to land a big contract (or for marketing purposes);
  3. Tying the certification to an overly aggressive deadline;
  4. Ignoring the expert help; and
  5. Having no business goals in mind.

These are usually exacerbated by not getting senior leadership support, and then failing to tailor ISO to your needs. So what organisations end up with 99 times out of 100 is a stalled project and an external consultant taking all the blame.

ISO 27001 certification is bloody difficult…

…just accept that from the beginning. It requires commitment from every aspect of your organisation, and will only be effective if you enable the culture shift necessary to embrace it properly.

Strangely enough though, it actually looks fairly simple, as the ISO 27001 standard itself is only 30-odd pages long and only 114 controls. However, for every 1 of those controls, there are an average of 4 additional aspect to consider from the NINETY-odd page ISO 27002. Then, if that’s not enough, you must show some kind of evidence that you actually doing what you say you are!

For example, the very first ISO 27001 control is “A.5.1.1 – Policies for information security – A set of policies for information security shall be defined and approved“. Sounds simple enough until you realise that there are a minimum of 19 suggested ‘Implementation Guidance’ factors behind it.

From requiring that Information Security Policies address; “business strategy” and “regulation, legislation and contract“, to the suggested ‘examples’ of “policy topics”, A.5.1.1 becomes a project all by itself. Then, assuming you get all this paperwork together, you have to ensure that the policies are; “communicated to employees and relevant external parties in a form that is relevant, accessible and understandable to the intended reader, e.g. in the context of an “information security awareness, education and training programme” (see 7.2.2).” Finally, you then need to provide some ‘record’ that this is all implemented , or that you have a risk treatment plan in place that shows you’re going to get it implemented …how …and when.

There are 114 of these, and even if you decide a few of them are not relevant to you, you must fully justify their EXclusion.

Not trying to put you off, the implementation of an appropriate ISMS is one of the best things you can do for your business as a whole. Just make sure you start out the project for the right reasons, with the right support, and the right goals in mind. And for GOD’S sake, get an expert in for a day FIRST to show all major stakeholders what to expect BEFORE you commit to the full project!

I see ISO 27001 certification becoming a must-have for almost any business, but only if it’s done properly.

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