Breach-Proofing Your Data in a GDPR World
Here are six key measures for enterprises to prioritize over the next few months.
The massive data breaches that have hit the headlines in recent years, including Yahoo, Verizon, and particularly Equifax, have taken a toll on breach victims, consumers, and corporations. We've seen stocks drop precipitously, class-action lawsuits filed, CEOs shown the door, and executives called before Congress. This year, breaches could be even more costly for companies once the European Union's General Data Protection Regulation (GDPR) rules are in place come May 25.
The rules require businesses to protect the personal data and privacy of EU citizens for transactions that occur within EU member states, and also regulate the exportation of personal data of those consumers outside the EU. Penalties include fines of more than $27 million, or 4% of revenue, whichever is greater. For Equifax, which reported $3.14 billion in 2016 revenue, that could mean fines of $125.7 million. The company has already incurred $87.5 million in expenses so far in dealing with the breach and its aftermath. For a company the size of Apple, at $229.2 billion in revenue, the fines could reach as high as $9.17 billion. GDPR will apply to any company that processes the data of EU citizens, regardless of where the company is based. Given the global nature of Internet commerce, its impact will be far reaching.
Organizations are under the gun to get systems in place now to ensure that they are in compliance with the regulations, before it's too late. Here are six key measures for enterprises to prioritize over the next few months:
Protect data beyond your perimeter. Corporate networks continue to expand with increased use of the cloud. The average enterprise has over 1,000 cloud services on average in use, 92% of which are not enterprise-ready, according to a report last year from cloud security company Netskope. (Full disclosure: Netskope is among a number of companies that provide cloud security services.) Companies need to expand security practices to cover all the new ways in which users are interacting with technology. Expanding use of enterprise security controls is crucial, but end-to-end data protection is one of the most potent safeguards.
Make privacy awareness mandatory. By requiring every employee to participate in cybersecurity awareness training and conducting training on an ongoing basis, organizations can foster a culture of security awareness. Security team leads are responsible for identifying risks of noncompliance with GDPR, and managing those risks by implementing controls, policies, and procedures, and then communicating these and other security best practices to their employees. Employees need to hold themselves accountable for doing their part in helping the company comply with the GDPR — just as much as leadership does.
Ensure secure transmission of data in the cloud. As cloud adoption expands and data increasingly crosses physical boundaries, it becomes that much more important to vet and manage cloud providers where transmission and controls for data are monitored. With email, cloud storage, or collaboration apps like Slack, security teams need to keep a close eye on the many channels being used to communicate and share data. Rather than blocking use of those channels, security leads need to have the right guardrails in place to ensure employees aren't intentionally or inadvertently exposing the data to the outside world, and in turn exposing the company to fines.
Check the terms and conditions. Nearly 40% of cloud services provide terms and conditions that lack specifics around data ownership. In some cases, the user owns the data, but in others the cloud service provider owns it. Security teams need to increase employee awareness about this and encourage them to steer clear of services that want to own the data.
Know your data well. When I say get to know your data, I mean really know the data — what information is being collected, who's collecting it, and who's sharing it throughout the organization. Also, don't assume that your understanding of protected health information (known as PHI), personally identifiable information (PII), and other data profiles will directly map to the GDPR rules, because the scope of the regulations are different and can include things such as hobbies, political affiliations, and sexual orientation.
Follow your data. You need to know where your data travels — especially if it crosses geopolitical boundaries. In fact, 80.3% of the time, cloud data gets backed up to another geographic area. That is, after all, a deliberate design specification and a strength of the cloud for enabling high availability and disaster recovery. If that data includes regulated data under the GDPR, you'll need to talk to your cloud service provider about restricting backups to certain geographies. If your cloud service provider can't do that, look to third-party controls to take necessary precautions.
The GDPR may be a European Union regulation, but its reach covers businesses the world over. It will force companies to strengthen their protections for customer data or face fines. The regulations may not prevent breaches from happening, but they will help minimize the amount and severity of the data that gets exposed, and thus reduce the harm to consumers. Organizations need to hasten their efforts to put measures in place to comply with the new regulations. Doing so won't just save them money; it's good for business in general to have strong data protections in place.
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