Tag: Vendor Due Diligence

In April 1975, Gary Dahl had an idea. A genius idea as it turned out, particularly when you consider that he made roughly $28 million dollars (adjusted for inflation) from something that was, to all intents and purposes, completely useless.

The Pet Rock was just that, a rock. No paint, no googly eyes, nothing, just a rock taken from Rosarito Beach, packaged up and sold for $20 each.

He sold 1.5 million of them.

Continue reading “Beware of the ‘Pet Rock’ Cybersecurity Vendors” →

I have lost count of the number of times I have included phrases like; “You have to ask the right questions.” into my blogs, or into conversations with prospective clients. One of my primary roles as a consultant is to to either help my clients do just that, or to give them the right answers first if they are just too far behind the curve.

Continue reading “Finding the Right GDPR ‘Expert’ to Help Your Business” →

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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In direct response to a certain organisation’s ‘Top 10 Cyber Security Technologies to Watch in 2017’, [cough, Gartner, cough], I have come up my own list of bleeding edge security technologies that every organisation should spend millions of $/£/€/¥ on.

Yes, even if you don’t MAKE millions, you should borrow the money and buy them anyway.

Being honest, my fight to bring security ‘back to basics’ has failed – despite my enormous 210 person following – so I have decided to sell-out and promote nothing except buzz-phrases and acronyms. You know, like everyone else.

However, I am convinced that if you buy, implement, and actually take these technologies seriously, you can forget the security basics. The combination of these 10, never-seen-before, shiny new objects will provide the silver bullet you’re looking for:

  1. Directorate Approbation Paradigm (DAP) – Historically, achieving ‘management buy-in‘ was the ultimate goal for anyone attempting to implement a security program. Quite rightly, caring about the future of an organisation was considered naive, and proponents of this stone-aged technology were left begging for work on LinkedIn. Some of these poor souls even became CISOs. Now, with DAP technology, every single person in an organisation will take security seriously, even if their bosses don’t!
    o
  2. Command & Control Commission (CCC) – While not strictly a technology the CCC is responsible taking the output from the EIC below, combining it with the DAP above and obtaining the budget to buy everything else on this list. This is the spider in the middle of the web, making sure that all technologies work together. Called ‘governance‘ in the old days, the new CCC is clearly superior given that you’ve never heard of it, and it’s an acronym.
    o
  3. Protocol, Method, & Archetype Orchestrator (PMAO) – Much as leeches were seen as the go-to technology in medieval medicine, ‘policies, procedures and standards‘ were seen as a foundation for every security program. While clearly nothing more than a quaint superstition, they nevertheless laid the groundwork for the PMAO revolution. Imagine it; a series of artefacts designed to record not only an organisation’s entire security culture, but their process knowledge and system baselines as well! No way just policies, procedures and standards could do all of that!
    o
  4. Exposure Investigation & Computation (EIC) – I almost feel sorry for the poor saps who only had the ‘risk assessment‘ process to measure their risk profile. Can you imagine basing you risk treatment and technology purchasing decisions only on expert opinion and business goals!? Instead, EIC, in combination with AI, big data, The Cloud, and fairy dust, can tell you exactly how many millions to spend on technology! No more embarrassing moments when you try to explain to your boss how you tried to save them money by fixing the actual problem! Like people and process could ever be the problem!
    o
  5. Intelligence Preservation Administration Schema (IPAS) – Can you imagine the nerve of the International Standards Organisation when they came up with the Information Security Management System (ISMS)? A so-called ‘framework’ designed for “systematically managing an organization’s sensitive data” with – and you won’t believe this- “a set of policies and procedures”! How naive! Instead, with IPAS, you can basically ignore the hard work and common sense approach to doing security properly and hide behind an expensive appliance with flashing green lights! Blinking green, you know it’s working!
    o
  6. Transformation Regulation Authority (TAR) – Before the advent of TAR technology, organisations across the globe relied on a ‘change control board’ to ensure that unmeasured risk was not introduced into an environment. As yes, once again, actual humans – apparently those with ‘expert’ knowledge – were allowed to determine what was right for the business. A clearer case could not be made to put this in the safe ‘hands’ of technology written by someone else.
    o
  7. Episode Reply & Adversity Restoration (ERAR) – We’ve all seen those commercials from the 50’s where attractive actors extolled the virtues of smoking? Well, ‘incident response & disaster recovery‘ were just as misleading, and just as dangerous! Like anything involving people and process could possibly help you stay in business! ERAR on the other hand, will not only detect bad things happening, it will keep your business up and running! Surely THAT’S worth a few million all by itself!!
    o
  8. Capital Durability Projection (CDP) – The future of any organisation should never be placed in the hands of those who care. The experiment called corporate social responsibility failed because it was assumed that it’s the people who are the most important aspect of a business. At least now we know it’s money that’s most important, so the old concept of ‘business continuity planning’ can be replaced by EDC and those making the world better with technology. Finally the people can be safely ignored.
    o
  9. Asset Management (AM) – This is one aspect of security where technology is actually sadly lacking. Asset management is the centre of everything, and without it, no other aspect can be truly be done well. Spreadsheets just don’t cut it, and no GRC that I’ve seen gives asset management its due. This much change, even in The Cloud.
    o
  10. Continuous Compliance Validation (CCV) – This is an idea whose time has come, it’s about time technology provides a REAL solution to overly manual processes.

All facetiousness aside, I am a huge fan of technology. Or more accurately, I am a huge fan of the appropriate application of technology. If you buy something based on anything other than 1) the results of your risk assessment, and 2) answers to the RIGHT questions, you have no business being in charge of a budget.

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First, what do I mean by ‘qualified’? – I mean that the only people truly qualified to lead a GDPR project are lawyers (or equivalent!) specialising in privacy. That’s it. This does not preclude non-lawyer privacy experts or lawyers not specialised in privacy, but you get what you pay for.

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 never a Certified 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;
    o
  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
    o
  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 lawyer, 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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