I have long maintained that fines under GDPR are the last resort, and that the ICO do NOT want to use Article 83 of the GDPR as a stick to scare organisations into compliance.
The ICO commissioner, Elizabeth Denham has even said as much herself, using the word “nonsense” when it was suggested that large fines would become the norm, that “Issuing fines has always been, and will continue to be, a last resort[…]“, and “While fines may be the sledgehammer in our toolbox, we have access to lots of other tools that are well suited to the task at hand and just as effective […]“.
I have made no secret of my distain for the ‘GDPR Practitioner Certification‘ badge, and I still have no time for it, or its recipients who pass it off as real-world experience. But what alternatives are there if you want to obtain some form of data protection certification / privacy education?
The de facto standard, and really the only player in town, is the International Association of Privacy Professionals (IAPP), and their flagship badge, the Certified Information Privacy Professional (CIPP), is the most widely recognised and respected acronym you can add to your CV/resume. It’s the equivalent of the CISSP for those of us in the cybersecurity industry.
It is with some surprise (and frankly, confusion) that I now realise not all security professionals think information security policies (ISPs) should [must!] be aspirational in nature.
By ‘aspirational’, I mean that at least some aspects of your ISPs require a greater degree of control / implementation / assurance etc. than you are currently capable of achieving in reality.
The ‘accurate policy’ proponents feel that if the policies do not reflect exactly what you are doing, then what you are doing is in violation of your own policies, thereby effectively rendering those policies useless. I assume, by extension, that they consider compliance with any regulatory regime is also nullified.
Each time I think I’m getting to the heart of the challenges faced by those on all sides of cybersecurity recruiting, a further complexity raises its ugly head.
While I still think that job titles are horribly limiting, that job descriptions completely miss the point, and that the cybersecurity skill-gap misconception is mostly the fault of the organisations asking for help, there’s no getting away from the fact that cybersecurity recruiters are doing themselves no favours.