GDPR Compliance & Personal Data Protection

The General Data Protection Regulation is set to be a fact of life in less than six months, and arguably the biggest challenge facing enterprises across the globe is locating personal data sources and classifying them correctly.

Most organisations will have some degree of legacy data, whether paper or digital, and before taking any technical steps at all it is essential to ensure that this personal data locked in ERP and CRM systems is classified according to risk.

Although the general thrust of GDPR has been widely debated in the media and among security industry peers, much of the coverage to date has focused on the huge penalties for non-compliance, rather than looking at the opportunities of data discovery and process improvements for enterprises of all shapes and sizes. Indeed, a recent study found that 60 percent of EU organisations say they will face serious challenges in being GDPR-compliant, and in fact 40 percent of respondents report that their organisations do not view compliance with GDPR by the deadline as a priority.

Geographical Complications
This is all a matter of fact, rather than conjecture, but business responses to GDPR and its implications have varied considerably in my experience. Anecdotally, not many European and UK organisations have been giving the regulation enforcement date as a high priority as perhaps they could have done. Some will only be kicking off in December 2017, leaving them a mere six months to comply.

US companies are generally speaking not particularly prepared, and the complexity of the legal landscape is going to make it difficult for those who have not thought ahead. 

For example, companies with significant operations such as head offices outside the EU face the issue of adequacy, so will potentially need to construct a lawful mechanism to transfer data. The model contract clause is one such mechanism, another is binding corporate rules, but this mechanism does require prior planning, and approval from the ICO.

Geography and legalities aside, the most important element of a robust GDPR strategy is to evaluate people and processes first, technology is a facilitator to the processes that need to be put in place. 

This initiative is not a tick box compliance approach, and there is no plugin or tool that will simply make it all go away. On the positive side, there is plenty of opportunity to take this watershed moment in personal data management and look at harmonising company data policies, which have often grown up over time with significant overlap.

Data Discovery
Finding the precise location of data defined as ‘personal’ under GDPR from among the thousands of tables and columns (or fields) in complex and customised packaged systems, represents a significant challenge. 
Traditional tools and methods, such as searching for documentation, using templates and reference models or employing external consultants, do not address the challenge in an effective and timely fashion.

Safyr offers an interesting approach, it interfaces with all the most popular ERP and CRM solutions in order to speed up that discovery process. 

Speed and accuracy here are vital for several reasons, obviously ‘bad’ data discovery initially means that risk assessments will be skewed, and even worse it may cause a loss of focus, so that less critical issues are fixed first, rather than the real high risk issues. These issues are the major benefit of using a discovery tool, rather than attempting hand cranked scripted procedures.

Data Protection Impact Assessment
Unstructured data will be a major challenge for many organizations because of the nebulous nature of it and obtaining full information about it. For example, Salesforce, which historically slurps up huge amounts of information that might not be essential for everyday business, but will be highly relevant in a GDPR context.

The result is hidden risk, where in the event of a data breach business could be exposed to far greater penalties than they think if information is not correctly categorised. 

All new systems or updates to data systems should have a complete data protection impact assessment (DPIA), as mandated under article 35, that assess the risk profile, as well as facilitating the scoping of a new system. A DPIA is an excellent programme management technique, and should from now be a matter of course - if it was not before!

Information Asset Register
Another vital element of preparation for and compliance with GDPR is the setting up of an Information Asset register, which is specifically detailed under article 30. The aim is to inventory all the systems, electronic and paper based, that hold personal information. 

Data glossaries and/or data dictionaries support this register, and there are plenty of tools that can help with this, including many content management systems.

Overall, the imminent arrival of GDPR should be seen as a fantastic opportunity to get in-house policies, systems and technologies into shape, as well as demonstrating compliance in time for the deadline. While many enterprises are only just beginning to get started, those with the longest run-up will be those with the fewest unforeseen problems come mid-2018.

Information-Management

For Further GDPR Information please also contact The GDPR Advisory Board

You Might Aslo Read: 

The GDPR Advisory Board Offers Expert Advice:

 

« US Cyber Soldiers Go To The Battlefield
Canada’s Electronic Spies Unleashed »

Infosecurity Europe
CyberSecurity Jobsite
Perimeter 81

Directory of Suppliers

CSI Consulting Services

CSI Consulting Services

Get Advice From The Experts: * Training * Penetration Testing * Data Governance * GDPR Compliance. Connecting you to the best in the business.

Clayden Law

Clayden Law

Clayden Law advise global businesses that buy and sell technology products and services. We are experts in information technology, data privacy and cybersecurity law.

DigitalStakeout

DigitalStakeout

DigitalStakeout enables cyber security professionals to reduce cyber risk to their organization with proactive security solutions, providing immediate improvement in security posture and ROI.

Syxsense

Syxsense

Syxsense brings together endpoint management and security for greater efficiency and collaboration between IT management and security teams.

TÜV SÜD Academy UK

TÜV SÜD Academy UK

TÜV SÜD offers expert-led cybersecurity training to help organisations safeguard their operations and data.

SABSACourses

SABSACourses

SABSA is a development process used for solving complex problems such as IT Operations, Risk Management, Compliance & Audit functions.

Allianz Commercial

Allianz Commercial

Allianz Commercial is the center of expertise and global line of Allianz Group for insuring mid-sized businesses, large enterprises and specialist risks.

ShmooCon

ShmooCon

ShmooCon is an annual east coast hacker convention offering three days of demonstrations and discussions of critical infosec issues.

PrimaTech

PrimaTech

PrimaTech provide process safety, cyber and process security, and risk management consulting, training and software for the process industries.

European Organisation for Security (EOS)

European Organisation for Security (EOS)

EOS represents all domains of security solutions and services.providers including ICT information and communications technologies.

Romanian Association for Information Security Assurance (RAISA)

Romanian Association for Information Security Assurance (RAISA)

RAISA promotes and supports information security activities and creates a community for the exchange of knowledge between specialists, academic and corporate environment in Romania.

Greensafe IT

Greensafe IT

Greensafe offer various onsite and offsite data erasure services, aimed at increasing data security whilst reducing any risk of data loss during transit.

About Cyber Security.

About Cyber Security.

About Cybersecurity provides a galaxy-wide knowledge base of cybersecurity tactics and techniques derived from actual experience.

Revere Technologies

Revere Technologies

Revere Technologies is a pure-play cyber security solutions and services provider in Sub-Saharan Africa.

McCrary Institute - Auburn University

McCrary Institute - Auburn University

The McCrary Institute seeks practical solutions to real-world problems in the areas of cyber and critical infrastructure security.

1Password

1Password

1Password combines industry-leading security with award-winning design to bring private, secure, and user-friendly password management to everyone.

Cigent Technology

Cigent Technology

Cigent keeps the most valuable asset in your organization safe—your data. Our advanced endpoint and managed network security solutions prevent ransomware and data theft.

European Center for CyberSecurity in Aviation (ECCSA)

European Center for CyberSecurity in Aviation (ECCSA)

ECCSA is a cooperative partnership within the aviation community to better understand emerging cybersecurity risks in aviation and provide collective support in dealing with cybersecurity incidents.

Allurity

Allurity

Allurity is a group of tech-enabled cybersecurity service providers, comprised of best-in-class experts with a common mission to enable a safe digital world.

PDQ

PDQ

PDQ helps IT professionals to manage and organize hardware, software, and configuration data for Windows- and Apple-based devices.

Pantherun Technologies

Pantherun Technologies

Pantherun is a pioneering force in the realm of encryption technology and data protection solutions.