Security Central: A Checklist of Client Must-Dos for GDPR
The deadline to be in compliance with the European Union’s General Data Protection Regulation (GDPR) is almost here. All companies that collect the data of EU citizens will need to be ready by May 25.
GDPR is expected be a huge disruptor for the channel between now and 2020, according to a survey of IT resellers and MSPs commissioned recently by Agilitas. The poll found more than one in three (37 percent) respondents expect GDPR to be the most disruptive challenge over the next three years. But they also predict opportunity in the regulation, with one in three (34 percent) partners noting that they expect to see a revenue boost related to GDPR.
A PwC survey shows that nearly all (92 percent) U.S. companies consider GDPR a top data-protection priority, with more than two in three (68 percent) U.S.-based companies planning to spend between $1 million and $10 million to meet GDPR requirements.
The opportunity for MSSPs is clear: Clients have budget and need guidance with this complex regulation.
“GDPR has taken CISOs off guard,” says Gary Southwell, general manager at CSPi, a network and IT security company. “The channel has the opportunity has to be a consultative partner to companies looking for help with compliance.”
Here is a list of some of the key recommendations for GDPR preparation that MSSPs should be advising clients on now.
Map Your Data
Data mapping is the process of identifying, understanding and mapping out the data in an organization to provide a thorough overview of how it flows to, within and from a company.
“Take inventory and understand where you keep PII (personally identifiable information). We often get people who don’t know that,” says Southwell of his own work with clients. “If you don’t know where it is, at least understand applications that are storing it. Once you understand where it is, you can now figure out ways to make sure it is protected. And you can go after data if it needs to be deleted, which is necessary under the ‘right to be forgotten.’”
The process of data mapping should involve all business units in your organization, he notes. Often you will find data that reside in multiple locations.
“Map your data,” agrees Oded Moshe of SysAid, a provider of IT service management solutions. “You need to get a clear picture of what data you hold on customers and citizens, and where it is held. That’s your first step.”
Moshe, who spearheads SysAid’s GDPR implementation efforts, also warns that in mapping, there are often overlooked areas – or blind spots – that need to be considered. Examples might include pictures of customers where they are identified, and client testimonies on marketing materials. Read more about GDPR blind spots in last week’s Security Central.
Be Prepared for Faster Breach Notification
GDPR requires organizations that discover a data breach to notify authorities within 72 hours of discovery. This has a number of Southwell’s clients on edge.
Multiple studies put the average time to detect a breach at 200 days. With just 72 hours to notify once detected, this means clients need to have quick access to a lot of affected data.
“Clients need a way to speed up the process to give information on what records have been exposed,” says Southwell. “Then you know which countries to notify.”
Southwell currently works with clients on advising which products provide a system to help expedite data-exposure information, and that includes data recording in and out of critical resources, and a search function to reveal records exposed.
Simulate Breach and Attack Scenarios
In order to be prepared for compliant breach notification, organizations should validate that the plans they have in place actually work through breach and attack simulations. But it’s not just under attack or after breach discovery when compliance can be tested. There are many aspects of the regulation that should be played out in advance.
“You need to make sure you’re prepared and should simulate various scenarios internally,” says Moshe. “You might have some EU citizens coming to you asking for you to delete their data under ‘right to be forgotten.’ You need to know how to deal with it. Simulate this with teams, and then double-check with the legal team that you’re covered. If you practice, you know what to do when it happens, and how to do it right.”
This isn’t just about the security and IT team. Moshe warns that most divisions need to be trained on relevant aspects of GDPR. Human-resources personnel is one example.
“If an employee who is an EU citizen leaves a company, they are going to engage with HR. They could come to HR when leaving and say, ‘I’d like to be forgotten please.’ HR needs to be prepared to handle that request. Training and awareness around this is important.”
Identify a Data Protection Officer
Most organizations must appoint a data protection officer (DPO) within the company under the regulation, and many are handling this by appointing existing people within the company and simply expanding roles.
“Some organizations will pick the CIO or CISO,” says Southwell. “There are firms that offer it as an outsourced service, but now you’re on a riskier slope because it means allowing an external party in to have access to your data and process as this person serves as your go-between for you and the government.”
Whoever is identified as the DPO needs to be work independently to conduct privacy assessments and without conflict to ensure laws and practices around data protection and compliance are up to date.
Stop Freaking Out
There is a lot of fear around GDPR, says Moshe. And many advising on GDPR preps are spreading needless worry. Ultimately, Moshe believes the regulation will be a positive step for overall privacy and data-retention practices. He thinks MSSPs should be conveying that message to clients.
“Stop scaring people about GDPR and start embracing it,” he says. “It’s good for us.”
Who is Security Joan? We’ll never tell, but all you really need to know is that she’s a huge Steely Dan fan (as if the nom de plume didn’t give it away). She’s also a veteran infosec journalist who has covered the evolution of the cybersecurity industry, its shadowy criminal underworld, and the good people trying to stop them for more than a decade. In addition to our weekly Security Central column, Security Joan helps inform the Channel Futures cybersecurity coverage with her sizable expertise. Say hi on Twitter @Security_Joan or shoot her an email at firstname.lastname@example.org.