: Posted 14 June 2017

General Data Protection Regulation (GDPR): Article 32

The GDPR compliance (May 2018) applies to any organization that collects, processes, or stores data on citizens of the European Union.

GDPR Explained
The aim of the regulation is to better protect the personal data and privacy of EU citizens’ by harmonizing the current data privacy laws all across Europe.

The GDPR headlines focus on the potentially huge fines “up to €20 Million, or in the case of an undertaking, up to 4 % of the total worldwide annual turnover of the preceding financial year, whichever is higher” for the worst infringements of the regulation.

Additional Info

So they really do mean business: As of May 2018, data breaches where either citizen, patient, subscriber or customer personal data is inexcusably left vulnerable will not be tolerated and the financial penalties will be painful.

As a case in point, the UK-focussed telco Talk Talk were fined a record amount of £400,000 by the UK Information Commissioners Office* following their breach in 2015, with a damning summary stating “failure to implement the most basic cyber security measures allowed hackers to penetrate TalkTalk’s systems with ease”. The company also sustained substantial losses of customers and revenues, with the value of the business also dropping by 30% subsequent to the breach. The Chief Executive also resigned within 6 months of the fine.

However, some estimates of how this would be treated once the GDPR-age arrives suggest this fine could have been up to £59M, based on the GDPR formula and the severity of the breach.

The breach at Talk Talk was attributed to the “failure to implement the most basic cyber security measures” and any breach in the future where CIS Controls/Security Best Practices have not been implemented will be seen in the same light.

What Does This Mean for my Organization?
What this means is that, while much of the GDPR requirements focus on the processes and procedures for acquiring, utilizing and handling personal data that is ‘lawful and fair’, the cybersecurity dimension is absolutely critical in order to prove that you have ensured ‘appropriate security and confidentiality of the personal data’.

ARTICLE 32: Security of Personal Data - Security of Processing

Article 32 of the GDPR, which requires ‘controller and the processor shall implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk’

(a) the pseudonymization and encryption of personal data;

(b) the ability to ensure the ongoing confidentiality, integrity, availability, and resilience of processing systems and services;

(c) the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;

(d) a process for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing.

NNT and the GDPR – Provable Compliance and Security
NNT will help in these essential areas:

Vulnerability Management
Audit and assess systems for exploitable vulnerabilities
System Hardening
Ensure systems are hardened against attack/attack surface is minimized
File Integrity Monitoring
Change control to expose and validate all changes
Automated Log Analysis
Automated analysis of user and system activity for suspicious behaviors
Least Privilege Access
Ensure data access restrictions are enforced 24/7
Data Encryption
By encrypting personal data, the damage from a breach can be limited
Host Intrusion/Breach Detection
If the unthinkable happens, make sure you can shut it down
Change Control
Maintain security at all times even when inevitable changes are implemented
Threat Intelligence
Real-time analysis of changes using continuously updated threat intelligence

For a free automated system compliance audit:

Request a free trial of NNT Change Tracker™ Gen7 R2

Additional GDPR Resources

GDPR Blog

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