GDPR is coming…..
If your organisation does business with Europe, or more specifically does anything with the Personal Data of EU Citizens who aren't dead (i.e. Natural Persons), then, just like us, you're going to be in the process of living the dream that is Preparing for the General Data Protection Regulation. For many organisations, this is going to be a gigantic exercise, as even if you have implemented processes and technologies to meet with current regulations there is still additional work to be done.
Penalties for infringements of GDPR can be incredibly hefty. They are designed to be dissuasive. Depending on the type of infringement, the fine can be €20 million, or 4% of your worldwide annual turnover, depending on which is the higher amount. Compliance is not optional, unless you fancy being fined eye-watering amounts of money, or you really don't have any personal data of EU citizens within your control.
The Regulation applies from May 25th 2018. That's the day from which organisations will be held accountable, and depending on which news website you choose to read, many organisations are far from ready at the time of writing this blog. Preparing for GDPR is likely to be a cross-functional exercise, as Legal, Risk & Compliance, IT, and Security all have a part to play. It's not a small amount of regulation (are they ever?) to read and understand either – there are 99 Articles and 173 Recitals.
I expect if you're reading this, it's because you're hunting for solutions, services, and guidance to help you prepare. Whilst no single software or services vendor can act as a magic bullet for GDPR, Rapid7 can certainly help you cover some of the major security aspects of protecting Personal Data, in addition to having solutions to help you detect attackers earlier in the attack chain, and service offerings that can help you proactively test your security measures, we can also jump into the fray if you do find yourselves under attack.
Processes and procedures, training, in addition to technology and services all have a part to play in GDPR. Having a good channel partner to work with during this time is vital as many will be able to provide you with the majority of aspects needed. For some organisations, changes to roles and responsibilities are required too – such as appointing a Data Protection Officer, and nominating representatives within the EU to be points of contact.
So what do I need to do?
If you're just beginning in your GDPR compliance quest, I'd recommend you take a look at this guide which will get you started in your considerations. Additionally, having folks attend training so that they can understand and learn how to implement GDPR is highly recommended – spending a few pounds/euros/dollars, etc on training now can save you from the costly infringement fines later on down the line. There are many courses available – in the UK I recently took this foundation course, but do hunt around to find the best classroom or virtual courses that make sense for your location and teams.
Understanding where Personal Data physically resides, the categories of Personal Data you control and/or process, how and by whom it is accessed, and how it is secured are all areas that you have to deal with when complying with GDPR. Completing Privacy Impact Assessments are a good step here. Processes for access control, incident detection and response, breach notification and more will also need review or implementation. Being hit with a €20million fine is not something any organisation will want to be subject to. Depending on the size of your organisation, a fine of this magnitude could easily be a terminal moment.
There is some good news, demonstrating compliance, mitigating risk, and ensuring a high level of security are factors that are considered if you are unfortunate to experience a data breach. But ideally, not being breached in the first place is best, as I'm sure you‘d agree, so this is where your security posture comes in.
Article 5, which lists the six principles of processing personal data, states that personal data must be processed in an appropriate manner as to maintain security. This principal is covered in more detail by Article 32 which you can read more about here.
Ten Recommendations for Securing Your Environment
- Encrypt data – both at rest and in transit. If you are breached, but the Personal Data is in a render unintelligible to the attacker then you do not have to notify the Data Subjects (See Article 34 for more on this). There are lots of solutions on the market today – have a chat to your channel partner to see what options are best for you.
- Have a solid vulnerability management process in place, across the entire ecosystem. If you're looking for best practices recommendations, do take a look at this post. Ensuring ongoing confidentiality, integrity and availability of systems is part of Article 32 – if you read Microsoft's definition of a software vulnerability it talks to these three aspects.
- Backups. Backups. Backups. Please make backups. Not just in case of a dreaded ransomware attack; they are a good housekeeping facet anyway in case of things like storage failure, asset loss, natural disaster, even a full cup of coffee over the laptop. If you don't currently have a backup vendor in place, Code42 have some great offerings for endpoints, and there are a plethora of server and database options available on the market today. Disaster recovery should always be high on your list regardless of which regulations you are required to meet.
- Secure your web applications. Privacy-by-design needs to be built in to processes and systems – if you're collecting Personal Data via a web app and still using http/clear text then you're already going to have a problem.
- Pen tests are your friend. Attacking your systems and environment to understand your weak spots will tell you where you need to focus, and it's better to go through this exercise as a real-world scenario now than wait for a ‘real' attacker to get in to your systems. You could do this internally using tools like Metasploit Pro, and you could employ a professional team to perform regular external tests too. Article 32 says that you need to have a process for regularly testing, assessing, & evaluating the effectiveness of security measures. Read more about Penetration testing in this toolkit.
- Detect attackers quickly and early. Finding out that you've been breached ~5 months after it first happened is an all too common scenario (current stats from Mandiant say that the average is 146 days after the event). Almost 2/3s of organisations told us that they have no way of detecting compromised credentials, which has topped the list of leading attack vectors in the Verizon DBIR for the last few years. User Behaviour Analytics provide you with the capabilities to detect anomalous user account activity within your environment, so you can investigate and remediate fast.
- Lay traps. Deploying deception technologies, like honey pots and honey credentials, are a proven way to spot attackers as they start to poke around in your environment and look for methods to access valuable Personal Data.
- Don't forget about cloud-based applications. You might have some approved cloud services deployed already, and unless you've switched off the internet it's highly likely that there is a degree of shadow IT (a.k.a. unsanctioned services) happening too. Making sure you have visibility across sanctioned and unsanctioned services is a vital step to securing them, and the data contained within them.
- Know how to prioritise and respond to the myriad of alerts your security products generate on a daily basis. If you have a SIEM in place that's great, providing you're not getting swamped by alerts from the SIEM, and that you have the capability to respond 24x7 (attackers work evenings and weekends too). If you don't have a current SIEM (or the time or budget to take on a traditional SIEM deployment project), or you are finding it hard to keep up with the number of alerts you're currently getting, take a look at InsightIDR – it covers a multitude of bases (SIEM, UBA and EDR), is up and running quickly, and generates alert volumes that are reasonable for even the smallest teams to handle. Alternatively, if you want 24x7 coverage, we also have a Managed Detection and Response offering which takes the burden away, and is your eyes and ears regardless of the time of day or night.
- Engage with an incident response team immediately if you think you are in the midst of an attack. Accelerating containment and limiting damage requires fast action. Rapid7 can have an incident response engagement manager on the phone with you within an hour.
Security is just one aspect of the GDPR, for sure, but it's very much key to compliance. Rapid7 can help you ready your organisation, please don't hesitate to contact us or one of our partners if you are interested in learning more about our solutions and services.
GDPR doesn't have to be GDP-argh!