The Chinese government has been working for several years on a comprehensive Internet security/surveillance program. This program is based on the Cybersecurity Law adopted on 2016. The plan is vast and includes a number of subsidiary laws and regulations. On December 1, 2018, the Chinese Ministry of Public Security announced it will finally roll-out the full plan.
Complaint filed with European Commission over decision not to give more to watchdog
For a Government obsessed with the optics it is surprising how often this current administration does things that leave it wide open to criticism.
FULL STORY: https://www-irishtimes-com.cdn.ampproject.org/c/s/www.irishtimes.com/business/technology/is-ireland-breaching-eu-rules-by-underfunding-data-regulator-1.4047897?mode=amp
Several members-only dark web forums are reportedly auctioning what appears to be a stolen government database featuring the personal information of 92 million Brazilian citizens.
The 16GB SQL database contains such information as name, birth date, mother’s name, gender and tax details including taxpayer IDs, according to BleepingComputer, which credits the discovery to a researcher with the Twitter user name Breach Radar.
Data breaches that occurred over the last few months have quite literally impacted close to one-third of the US population. This staggering number supports the inevitable conclusion that something is very wrong, and that data vulnerabilities represent possibly one of the greatest threats facing not only corporate enterprise, but government agencies as well. Aetna, Equifax, and Time Warner Cable, companies that collectively manage the health information, credit ratings (including highly sensitive financial data), and the communications of a large percentage of the population, recently admitted to massive data breaches and notified those impacted customers that their personal information had been compromised. Reasons given vary from exploitation of a website vulnerability and an affiliate accidently leaking sensitive personal information. These companies will face not only potential litigation and regulatory enforcement action that could represent billions of dollars of loss. Equifax shares have dropped 21 percent since their breach was disclosed on Sept. 7, the biggest two-day drop since 1998. (https://www.bloomberg.com/news/articles/2017-09-11/equifax-backed-out-of-public-investor-presentation-after-breach). Even more sobering, had these breaches occurred after May 25, 2018, the official start data for enforcement of the new EU General Data Protection Regulation, which at least in the case of Equifax also resulted in significant data loss for UK personal information, these companies could have faced additional staggering penalties of up to 4% of their global annual revenue.
As the Director of Sales I am often asked a basic question, “Which edition of BeyData Librarian is right for me?” This is a good question and one that people should consider based on their mission. The different editions were purpose built for specific needs and therefore the wrong edition could lead to a waste of resources or not having what you need.
To understand this better let us first look at a couple of early product roles:
- Create Assessments
- Run and Use Assessments
So, on many teams an assessment may be created by a law firm or consultant. These then would be given to their client. If you are never going to run an assessment except to test if it functions as designed than the personal edition is right for you. It is in the running of the assessments themselves where you will see a difference.
Let us ask some Questions and show the version for each answer in a grid:
Who will be using the software?
|It will be a single user on their personal computer||Best Choice||Not Required||Not Required|
|There will be three users of the software in one location||Will not work||Best Choice||Would work, may be overkill|
|There will be many users across our organization in multiple locations||Will not Work||Not the Best Choice||Best Choice|
|Reports do not need customization||Best Choice||Not Required||Not Required|
|Need to customize all reports||Will not work||Will Work||Will Work|
|Just me||Best Choice||Not Required||Not Required|
|Need Windows Authentication||Will not work||Will Work||Will Work|
|Need Active Directory Support||Will not Work||Will Work||Will Work|
Assessments and Diagrams?
|I only need to create Assessment Templates, Nothing else||Best Choice||Overkill||Overkill|
|I need to create Assessments, Data Flow / UML Diagrams, and Run Assessments||Will not work||Will Work||Will Work|
|I need to Run Assessments||Will Work||Will Work||Will Work|
The Personal Edition is good for those just starting out where the work being done is NOT team based. Additionally, this version is great for a technical person that is building assessment templates but will not actually be completing any assessments. It is also a good way to run a full fledge trial of the software with all functionality enabled.
The Professional Edition is often referred to as the Team Edition. Multi User support with SQL Express and Server Support along with support for multiple Authentication methods. The Professional edition also adds the ability to customize the reporting to match your company and brand.
The Enterprise Edition has everything that the previous versions have but adds Azure support for the Hybridicity required by many organizations who also work with third parties and external organizations.
BeyData Librarian ships with many templates but you may need to create a company specific Assessment. This may seem like a daunting task but it is quite simple. This blog post is designed to take you through the steps to automating a manual or spread sheet process that you currently use. For this example, we will use the Cloud Accountability Projects, Data Protection Impact Assessment. You can view the PDF here: Assessment PDF and more information regarding the cloud accountability project can be found here: http://www.a4cloud.eu/ . This assessment is provided under creative Commons with an Attribution and ShareAlike requirement (https://creativecommons.org/share-your-work/licensing-types-examples/).
What we want to do is replicate the “Cloud DPIA Questionnaire” from this document so that instances of the assessment can be run and rerun in an automated process. Here are the steps:
- Create a new Assessment: We will call the project CDPIA by Selecting the [ Add] button and then renaming the default new name of “Assessment Definition 1” to “CDPIA”
- Now let’s go ahead and Edit the New Assessment by Selecting the [Edit] button which brings up the assessment editor.
- From here we can start adding blocks. To save time we have completed this assessment before writing the blog post. For your information, this is a simple process of dropping blocks and connecting them. Let us talk about block types used.
The Task Block is simple and can be identified by its shape of a rectangle. The first one we have is EU Activities and more importantly it corresponds with the first question in the assessment
So, in this first line there are some questions regarding the type of project and defining territory
First, “Is the establishment of your activities in European territory?”
Then there is an Explanation section for the Privacy Pro completing the Assessment: “Whether the processing of personal information of your undertaking takes place in the European Union or not is not relevant. If you are not established in European Union territory, but you offer goods or services to individuals in the EU or monitor them, then you should answer Y to this question.”
The type of question is a Yes/No and for our purposes we will turn this into a checkbox and Checked\Unchecked (Yes/No or True/False) as we will need to test this answer.
Here is what the Task block pages look like with descriptions:
The first page defines the task, you can have one or many. There is the Task Subject /Question and then the description. There is of course the assignment and whether you want to send an email alert. The “Assessment Team” as shown here is a user group, you could also just send it to an individual. Some people prefer not to use email updates as part of the workflow, this is not required.
The Assessment comes with Guidance related to the Response, in Column one the Response Yes is: You have to comply with European Union laws, and Response No is blank. The Actions for each item are important.
The status of this task can be an Open/Done value or the approval type.
Some Privacy Pros will want to attach or review attachments for any instance of the assessment. This tab is where you define those items.
The Answers Page is where we define the items for which we want answers. It can be one to many items and how the answer is provided is up to you. In this case we want a check box but you can also use text, date time, memo, drop down choices. In many cases in this assessment we will use both Check boxes and drop downs.
Finally, there is the task expiration page, and this can be set to whatever you require. The assessment that ships with BeyData Librarian by default ships with no expiration.
The Actions are important and step one has the following actions:
If Yes: Go to the next question
If No: This Questionnaire is addressed to businesses and/or organisations which are established in the European Union. Since you are not established in the EU, this Questionnaire does not apply to you. (So Exit the Assessment)
You can see this clearly in the flowchart:
A “Yes” answer continues to the next step and a “No” answer ends the assessment.
The Score, Weight and Indicators need to be set on this first task block:
And for this first block it is: N/A – This answer is not counted in the overall score with a weight of zero and no risk indicators in this assessment they describe risk indicators as follows.
There are seven privacy indicators:
Sensitivity (SEN): Risks related to a sensitive market (i.e. elderly, children, etc.) and/or sensitive data (i.e. health or medical conditions, finance, sexual behavior)
Compliance (C): Risks related to compliance with external standards, policies, laws, etc.
Trans-border data flow (TB): Risks related to transfer of information across national borders
Transparency (T): Risks related to transparency in the areas of notice/user messaging and choice/consent
Data control (DC): Risks related to control of the data lifecycle (i.e., collection, usage, quality, and/or retention)
Security (SEC): Risks related to security of data and data flows
Data sharing (DS): Risks related to sharing data with third parties
- Now we have to decide programmatically what to do next, and we therefor put a decision block on the flowchart.
And here we ask if we are collecting European data and as required the answer “NO” ends the assessment and the answer “Yes” goes to the next step.
- Now we go on to line number two and question number two defines a checkbox question, “Do you handle information that can identify other people through one or more of the following activities?” With guidance, “Think for instance, if you use names, identification numbers or location data. The collection of information related to individuals can be potentially intrusive to the information privacy rights of these individuals. In some types of projects information provided is more sensitive than in other ones e.g. Financial data”. Regardless of the answer when complete we go to the next question.
- Web Browsing
- Account and/or Subscription Management
- Authentication and Authorization
We can handle both line two and three in this task block
What is different here is there are risk indicators that we must deal with
If “health, employment, social security and law enforcement” then 1, else if “historical, scientific statistical or research purposes” then 1/4, else if “exercise of the right to freedom of expression or information” then 3/4, else 0. With a weight of 1 and code SEN, here is an example:
So, to set risk for this task we would select the [ Set Risk] button
And under Risk to Individual set values as required.
PLEASE NOTE: You could also set these in the flowchart programmatically, please see the help file for more information on programmatic options.
- You repeat these steps as much as required, this assessment has 50 steps and branching based on conditions. And in the end the assessment looks like this in the assessment editor.
- Once created you need to test the Assessment and you do that by opening the assessment manager and selecting the [Run New] button and giving the test assessment a name and select [OK]
Remember even if you are setting the risk programmatically you must create the risk table for the instance as this is where risk values are stored for the assessment. After selecting [OK] you will get a message that the assessment instance and risk table are created – Once the instance is created the assessment is running.
To create the BeyData Librarian Assessment took three (3) hours and to run a complete test of the assessment and branching took 17 minutes. So in under 3.5 hours the assessment was created and new instances could be created at will. If we had the original spreadsheet it would have been quicker because when copying and pasting from a PDF many formatting updates are needed. It would have been under two hours if we had the original content.
Running our Example
You can Update your software to the latest build, or request that your account representative send you the new assessment template and import the template via the share functionality
If you do not have the software and want to see this in operation simply request a demo. https://www.beydata.com/RequestTrial.htm
Almost daily we hear about a new data breach. This has made businesses and individuals nervous. This of course makes sense if we want to deal with this problem on an emotional level. The data that has been exposed may be personal, sensitive and valuable, and in some cases, may cause great harm. However, the best way to be safe in any environment is to maintain situational awareness. The US Coast Guard Team Coordination Training Guide defines situational awareness in a way that is helpful:
“Situational Awareness is the ability to identify, process, and comprehend the critical elements of information about what is happening to the team with regards to the mission. More simply, it’s knowing what is going on around you.” (Coast Guard)
Simply put, we need to know what is going on around us. Whether you are a Pilot, Surgeon, Security Specialist, Chief Security Officer or Chief Privacy Officer, you must have situational awareness. You must know all the “known knowns and the known unknowns.” (Graham). This kind of perspective has been very difficult if not impossible to achieve and maintain, because today’s Data Protection Professional has been working mainly through the lens of a physical data security model and this is no longer sufficient.
As we continue porting our manual or legacy systems so that they are connected to the outer world, and as we become more global in our approach, it is obvious that we need broaden the understanding we have of our systems beyond the brick and mortar of our buildings (and our networks) to gain true Situational Awareness.
BeyData Librarian is the precursor to any meaningful data protection. While this may seem a strong statement, it is one that we think fits. As an example, we’ve heard from more than one prospective client, that the web based application where they store data in a private cloud was secure because they use AES encryption, so they had no security concerns. I know that many of our readers are smiling. There are many threat vectors in this situation where encryption is not a factor and data may not be secure. This is where BeyData Librarian comes into play.
Here are some, but not all, of the basic considerations you should evaluate to gain Situational Awareness of your data: Identify the Systems that you are using, the data within those systems, access points to and from those systems (for data in and data out), who within and outside of your organization has access to those systems, Data flows and locations of data, and then also consider a wide range of regulatory issues including Data Sovereignty, Consent, Third Party Access to (and use of) data, and Disposition of the data. These factors, along with others that may be specific to your business or industry, can be used to help you automate the process of understanding Risk to your business, customers, or individual data subjects if there is a breach, and then finally you should identify the likelihood of a breach. This process should be ongoing and reassessed with any changes in conditions and on a regular basis.
This by itself is not enough, because depending on your organization you may need to increase staff to properly assess your systems without the human error risk that comes from being short staffed or overworked.
BeyData Librarian handles these requirements by providing a solution that allows you to perform assessments for every new system that uses, collects, backs-up or archives data wherever it be. BeyData Librarian also allows you to calculate risk based on common models like those from the National Institute of Standards and Technology (“NIST”) and the Centre for Information Policy Leadership (“CIPL”) or any custom risk model you may have implemented.
Depending on an organizations risk tolerance the system will monitor and alert for risk levels that exceed what are acceptable. From a Security or Privacy Data Protection Officers perspective they now have an inventory of all their systems with associated risk levels. Putting a process in place that requires an assessment of any new system before it goes into production, provides insight into your system and data; collection, use and destruction, throughout the entire data lifecycle and simply put, situational awareness.
When you have the situational awareness, you are ready to implement a system of security and data protection controls that match your organizations security, legal, and statutory requirements that allows you to handle the known unknowns and the unknown unknowns!
Graham, W. R., Wikipedia (2017, July 10). There are known knowns. Retrieved July 19, 2017, from https://en.wikipedia.org/wiki/There_are_known_knowns
Coast Guard, U. (n.d.). Team Coordination Training Student Guide (8/98). Retrieved July 19, 2017, from https://www.uscg.mil/auxiliary/training/tct/chap5.pdf
Figure 1 – Known unknowns – The term was also commonly used inside NASA. Rumsfeld himself cited NASA administrator William Graham in his memoir; he wrote that he had first heard “a variant of the phrase” from Graham when they served together on the Commission to Assess the Ballistic Missile Threat to the United States during the late 1990’s
Videos on all aspects of using BeyData Librarian https://www.youtube.com/channel/UCR1sy8tnqvK-VNaspLoj6TA
BeyData’s “School Librarian Project” puts student privacy at the forefront with an advanced risk management system available to school districts regardless of their size and budget
School Librarian will enable schools of any size to build a simple and easily maintained privacy risk management program that will provide confidence to educators, parents, students and vendors that the proper controls are in place to protect children-our most vulnerable and important resources. The K12 license also provides access to free training resources and videos. To learn more about the BeyData School Librarian Project, or to apply for your educational license, please visit the project Web site at: https://www.beydata.com/schoollibrarian.html
Public Universities and Colleges may also contact BeyData for educational pricing
New Videos on YouTube https://www.youtube.com/channel/UCR1sy8tnqvK-VNaspLoj6TA/videos