Author: David Froud

In [X]aaS, The Outsource of Everything I made fun of the trend to “…as a Service.” everything under the sun, and that eventually we would run out of letters. Well, that happened years ago, so we’re now doubling and tripling up on the letters. Data Subject Consent as a Service (DSCaaS) is my latest attempt in a long line of failures to coin an acronym.

It’s every security professional’s dream.

And yes, Privacy Consent as a Service (PCaaS) would have been better, but that was taken by those damned Personal Computers!

Regardless of what it’s called, I believe the service is not only viable, it’s basically a necessity. 99% of organisations simply do not have the skill-sets, knowledge, or technical capability to manage the collection and management of consent. Especially in a fashion that has been vetted by privacy experts and kept up to date with EU-wide precedent.

Not that consent will be an organisation’s first choice for complying with GDPR. Legitimate Interest, contractual language, even binding corporate rules will likely be easier to maintain. But to get any of these to work requires each organisation to hire their own lawyers, and I’m fairly sure a lot of us would rather pay for a technology instead.

One of the first hurdles for any service like this is to explain to organisations that having yourselves the data is not your competitive edge. Making the best use of the data is. The only thing you should really care about is getting what you need out of the data, not what it took to get there, and definitely not where the data is. And let the experts worry about how to do that in line with the GDPR.

It’s like when I ask a room-full of merchants if credit cards are core to their business. 99% of them say yes, when it’s actually being paid that’s core to their business, not how they were paid.

So what does DSCaaS look like?

  1. First, it must clearly be a Cloud-based service with a seamless iFrame-esque integration with your organisation’s webpage. Where you would normally collect the personal information on your webpages, you would simply redirect this collection to a 3rd party provider;
    o
  2. Depending on the type of information collected and the reason for collection, very simple consent notices can be developed. For e-commerce for example, these consent notices can be pretty much boiler-plated into; payment authorisation, product/service updates, customer service, marketing, etc. For HR, these would be in-line with the individual employment contract and so on. This consent is now tracked by the DSCaaS provider;
    o
  3. The existing personal data previously collected by the organisation would be normalised/parsed and imported into the service in order to allow for the following:
    1. The removal of the vast majority personal data from an organisation’s systems (using tokenisation and APIs to link existing systems if required);
    2. tracking and collection of consent, plus renewal of consent where necessary;
    3. automated personal data removal/destruction based on data retention policies;
    4. online portal for data subject to change/erase data, or demand processing cessation;
    5. all data controller and processor contracts in place.
      o
  4. DSCaaS provider would need to be able to demonstrate ‘appropriate security measures’ through compliance with (and/or certification to) well-known standard like ISO 27001, ITIL, COBIT, NIST and so on;
    o
  5.  DSCaaS provider would have existing and robust relationships with supervisory bodies (ICO in the UK for example) to standardise reporting of processing (if required).

Clearly this is oversimplified, but if there’s one thing missing in all of these bandwagon ads for GDPR services it’s the spreading of the cost across multiple parties. Especially as it’s very likely that the millions of smaller organisation cannot afford privacy expertise on an individual basis.

The intent of the GDPR is a good one, and organisations have to understand that the data they are making so much money off does not belong to them. While I have no issue with them doing so – as long as I also benefit – I want complete control over what happens to it. The vast majority of organisations in the UK cannot even comply with the existing DPA, let alone one amended inline with the draft Data Protection Bill. For organisations to ‘comply’ with the intent of the GDPR, they will need help, and that help will not come from cybersecurity organisations, ‘certified’ GDPR practitioners, and not even privacy lawyers. It will come from organisations who combine all of these skills into a service where access to data is appropriately controlled.

Gone are the days when you could do whatever you wanted to profit from personal information. It’s what you do WITH the data that matters, and it’s almost always the best ideas that win out. We all need help doing that appropriately.

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This is going to be my shortest blog ever, because basically it’s just a warning: IGNORE THE MARKETING BULLSHIT AND THE DOOMSDAY JOURNALISTS!

Every time there is an outbreak of malware, or a new vulnerability exposed, or a protocol deprecated, the marketing departments of every security vendor go into overdrive. Their only goal; to make more money. Not to help, not to provide sound advice so that people don’t make bad decisions based on FUD, and not even because they know what the Hell they’re talking about.

Just money.

And the newspapers do what they do best; create panic with little to no understanding of the subject.

Yes, WPA2 has likely been broken, but because of the integrity of the researcher who discovered it we won’t have any information about it until later today. Which means we currently have no idea of the impact.

Apparently this is the guy you need to be watching; http://www.mathyvanhoef.com/

So here is what I would be doing right now if I were you:

  1. Determine what the impact would be on your organisation is WPA2 were truly broken;
  2. Update EVERY relevant device, as by now most of the bigger manufacturers should have a patch or a workaround;
  3. Tell your entire employee base NOT to panic, but they too should update their home computers (anti-malware etc.), mobile devices and home routers;
  4. Update your incident response plan to cover any issues.

The one thing you should NOT do is be part of the problem! Don’t spread rumours, spread fact, and be part of the SOLUTION! Share this blog if you want, or at least articles like it.

The security industry is rapidly becoming a bunch of used car salesmen, let’s each do our part to get THIS one right.

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Here we go again. A regulation or standard gets released and suddenly everyone’s an expert, every vendor has a solution or silver-bullet technology, and hundreds upon hundreds of organisations spend a fortune on something they were far better off doing themselves.

It happened with PCI, SoX, and a plethora of other smaller or more region/sector specific regulations, and now it’s happening to GDPR. All because most of us are just too bloody lazy to do a little bit of homework to find a real expert.

Or in a lot of cases, too lazy to even read the damned standard! Yes, it’s dull, but it’s not that difficult to decipher to the point you can ask a few intelligent questions.

But the real problem stems from the fact that most people don’t even know what privacy is. Personally, I am not an expert in privacy, I’m an expert in cybersecurity. If you think those two things are the same, or even very similar, you are already way off the mark. Yes, there is an overlap, but only in so far as a data breach can possibly lead to a loss in privacy.

But that’s the point, it’s only a possibility. Just because someone stole your data, does not mean they’re going to use it against you.

To summarise in a very general way:

Security = Preventing unauthorised ACCESS to your data; and

Privacy = Preventing unauthorised USE of your data.

It’s because this distinction is universally misunderstood, cybersecurity vendors are often the first ones organisations turn to. However, instead of steering these poor deluded fools in the RIGHT direction, vendors sell them what they asked for. What they got, and are still getting, is a fraction of what’s required. 3.34% to be exact.

I’m not saying a security expert cannot be a privacy expert as well. I’m also not saying that every vendor lacks integrity. But I am saying you’re the one blame if you end up with a muppet.

So How DO You Spot the Charlatans

Actually it’s rather easy, they use phrases like:

  • Avoid hefty fines by ensuring you’re GDPR compliant!;
  • Time is running out, save your business!;
  • Ask our security experts how to [enter rest of lie here];
  • They claim that ISO 27001 can cover the entirety of the regulation;
  • Any combination of words that includes “GDPR compliance” or “GDPR certification”;
  • Any sales pitch or article that leads with possible fines (unless it’s to put down those that try).

…or they are:

  • Regular cybersecurity vendors;
  • Any vendor selling ‘GDPR software’;
  • A recent Certified General Data Protection Regulation (GDPR) Practitioner (and has no other privacy experience);
  • Anyone with CISSP, CISA, CISM, CRISC etc. emblazoned on their LinkedIn profiles (and has no other privacy experience);
  • NOT A PRIVACY EXPERT!

Finding a real expert is not that difficult, you just have to look for people who have been doing privacy stuff for a long time. These people do not HAVE to be privacy lawyers, but it certainly helps. And while there will be a whole swarms of scum-bag lawyers chasing the GDPR ambulance, there are a lot of good ones out there anxious to help. My own sister is one.

On the positive side, look for things like this instead. These were bullet points taken from a free seminar that I have actually signed up for:

  • Understand the implications of the GDPR on your business-critical processes;
  • Learn how to prepare for the implementation of the GDPR;
  • Gain invaluable instruction and insight on the regulation and how to comply;
  • Discover the security solutions that can help to mitigate risks and assist in meeting your security obligations under the GDPR

This is the kind of education I can get behind. I really hope it’s not a well disguised sales pitch…

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[WARNING: Contains bad language.]

The 3 things I hate most about my chosen field of cybersecurity are, in no particular order:

  1. The proliferation of ‘silver bullet‘ / end-point protection technologies – when security is primarily concerned with people and process;
    o
  2. Security organisations using either F.U.D or regulatory compliance to make money without providing real benefit – with GDPR for example; and
    o
  3. Security ‘professionals’ who bad-mouth other security professionals at the lowest point in their careers – against Susan Mauldin for example.

In 4.5 years and close to 300 blogs I have never used the following words. But for those guilty of 3.;

Fuck you!

Seriously, how dare you!? Especially those who actually had the nerve to say Susan wasn’t qualified because she had a music degree and no other security related qualifications on her LinkedIn profile. Like certifications or even a degree are accurate representations of either a person’s skill-set, or their competence. I have no security relevant degrees, and my certifications were collected by reading a book and passing a pathetic multiple-choice test, but I will happily match my ABILITIES against anyone who does what I do.

More to the point, unless you actually work(ed) for the company that was just breached, you have no idea of what caused the breach in the first place. Yes, you can point to unpatched devices, and a host of other vulnerabilities POST-forensics, but you have NO idea of the business pressures the IS/IT teams were under. And if you think that should not matter, you’re not a true security professional.

I am in no way defending organisations that egregiously ignore security good practices just to increase profit. Nor am I defending the truly incompetent. But unless you have irrefutable evidence that either was the case, keep your opinions and reproaches to yourself. There is no such thing as 100% security, and there is no such thing as unlimited resources. The best you can ever hope for is that you have enough.

In security, a bad guy only has to be right once, security professionals have to be right ALL the time. Eventually we ALL make mistakes. Most of us are lucky, and our mistakes lead to nothing more than a minor event, but for some, the mistakes are career ending. Too often this is not because the people involved actually WERE incompetent, but because of the pressure to resign from the jerks who somehow think they are better. That the breach would not have happened under their watch.

Have you noticed though, that the people who are most critical and vitriolic tend to be mid-level no-bodies who will likely never make to the CISO level?

Do these people actually think that by taking cheap shots at the less fortunate that decent people won’t hate them for it. That Equifax and the other breach victims will suddenly reach out to them for help? That someone who has nothing better to do than kick someone while they’re down is just the kind of person they want on their team?

Let me ask you this: When was the last time you saw someone getting berated by his/her team for missing a penalty / field goal / you name it? You probably can’t remember, and why? BECAUSE THEY ARE ON THE SAME FUCKING TEAM!!

There are only 2 sides to cybersecurity; the good guys and the bad guys. Choose which side you’re on and stop being part of the problem.

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I think enough people are clawing over the Equifax carcass, so I’m just going to rant about how wonderfully simple security is instead.

Actually, it’s REALLY simple, or I would not be doing it! I’m lazy, and nowhere near smart enough to do something complicated. Therefore cybersecurity consultant is the perfect fit because it’s almost entirely common sense, and it’s not me who has to do the work! 🙂

Not only that, the things that you should be doing to secure your business have been written down for generations. Literally. So anyone who still thinks it’s complicated is not asking the right people the right questions, and anyone who says it’s complicated is probably extorting their clients by making it so.

Take GDPR for example. >96% of the GDPR is related to security of processing (basically privacy), and NOT the security of the data itself. Yet the number of security companies crawling out from under their rocks to capitalise on it increases daily. Anyone who knows the first thing about security would not be fooled by these charlatans. Cybersecurity security does NOT equal privacy, which IS complicated.

So here’s the real problem: If the cybersecurity industry was doing its job, it would be SIMPLIFYING things for everyone, not making them worse! Muddying the waters just to make a few extra quid is utterly reprehensible. But the fact that organisations are ALLOWING them to do this is just plain laziness. The answers are out there.

All that said, making security simple is actually very difficult, and only good consultants have this ability. This is the same in every profession and the sign of true mastery.

Rule of thumb: If you talk to a cybersecurity consultant and afterwards you have no idea how what they do benefits your business, they are the wrong fit for you.

Besides, the only reason you are talking to a consultant in the first place is because there is some business driver (regulatory compliance, contractual obligation etc.), so you’d better know how the deliverables are going to meet the objective. Frankly, if you are not a security practitioner yourself, I can pretty much guarantee you’re asking the wrong questions.

Crap analogy. When you go to the doctor do you:

  1. Tell them exactly what’s wrong with you and what they should be doing to fix it; or
    o
  2. Tell them you don’t feel well and where it hurts?

I assume you chose 2., but if the doctor then prescribes leeches, would you seek a second opinion? Of course you would, then you’d find someone whose solution to your illness made sense, right? Someone who explained things to you, someone who told what to expect (the good and the bad), someone who made sense. Right?

So why would you hire a cybersecurity person who can’t explain, simply, what you need and why you need it? Especially when 9 times out of 10 what they are proposing is likely not what you actually asked for? e.g. You asked a consultant to make you PCI compliant when what you should have asked for is a security program that covers the PCI requirements. Very different beasties.

In 4 years running my own consulting practice I have turned down several contracts because I knew they would go pear-shaped. In each of these cases I explained what it is that I do, what the long-term benefits would be. But in each case it was clear the prospect had absolutely no idea what I was talking about. Sometime simple just doesn’t sell, but it’s the only way I will do business.

I’ve just re-read this blog and I’ve completely failed to make my point. Oh well, I’m off to the pub…

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