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 »

CyberSecurity Jobsite
Perimeter 81

Directory of Suppliers

ZenGRC

ZenGRC

ZenGRC - the first, easy-to-use, enterprise-grade information security solution for compliance and risk management - offers businesses efficient control tracking, testing, and enforcement.

Syxsense

Syxsense

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

Perimeter 81 / How to Select the Right ZTNA Solution

Perimeter 81 / How to Select the Right ZTNA Solution

Gartner insights into How to Select the Right ZTNA offering. Download this FREE report for a limited time only.

XYPRO Technology

XYPRO Technology

XYPRO is the market leader in HPE Non-Stop Security, Risk Management and Compliance.

North Infosec Testing (North IT)

North Infosec Testing (North IT)

North IT (North Infosec Testing) are an award-winning provider of web, software, and application penetration testing.

NUS-Singtel Cyber Security R&D Lab

NUS-Singtel Cyber Security R&D Lab

NUS-Singtel Cyber Security R&D Lab conducts research into predictive security analytics.

Skkynet Cloud Systems

Skkynet Cloud Systems

Skkynet is a leader in real-time data systems for the secure management and control of industrial processes (SCADA) and embedded devices (M2M).

BlueVoyant

BlueVoyant

BlueVoyant's Cyber Defense Platform is security operations platform that provides real-time threat monitoring for networks, endpoints, and supply chains.

Silicon:SAFE

Silicon:SAFE

Silicon:SAFE develops impenetrable hardware solutions that prevent bulk data theft during a cyber-attack.

Teramind

Teramind

Teramind provides a user-centric security approach to monitor employee behavior in order to identify suspicious activity, detect possible threats, monitor efficiency, and ensure industry compliance.

CERT-PH

CERT-PH

CERT-PH is the National Computer Emergency Response Team and the highest body for cybersecurity related activities in the Philippines.

Cyemptive Technologies

Cyemptive Technologies

Cyemptive's CyberSlice technology preempts and remove threats before they take hold, in seconds, compared to other’s hours, days, weeks and even months.

Kentik

Kentik

Kentik - one platform for Network Visibility, Performance, and Security.

High Security Center (HSC)

High Security Center (HSC)

High Security Center provide real-time threat protection. We protect your company from targeted and persistent attacks using technologies such as Machine Learning and Behavioral Analysis.

DigitalWell

DigitalWell

DigitalWell provide fully managed IT and communications solutions for a truly innovative end-to-end experience - for your customers and teams.

Halogen Group

Halogen Group

Halogen Group is the leading Security Solutions Provider in West Africa. Services encompass Physical Security, Electronic Security, Virtual & Cyber Security, Risk Assessments and Training.

Snare

Snare

Snare is a comprehensive set of event monitoring and analysis tools designed to address critical auditing and security requirements.

Singularico

Singularico

Singularico help secure your software using the power of AI.

Increase Your Skills (IYS)

Increase Your Skills (IYS)

Armed and ready: raise awareness of cyberattacks in your company with the Full-Service Awareness Platform from IYS – fast and effective. We help you develop a robust, sustainable security strategy.

Incode

Incode

Incode is the leading provider of world-class identity solutions that is reinventing the way humans authenticate and verify their identities online.

Orca Fraud

Orca Fraud

Orca is an AI-driven fraud orchestration platform. We empower fraud fighters to outpace fraud using our custom ML models.