100-Day Countdown to GDPR

For many of us around the world February 14th marks St. Valentine’s Day, but for those of us in Europe, this date also marks the beginning of the 100-day countdown to the upcoming enforcement of the General Data Protection Regulation (GDPR).

As most of us are already aware the EU GDPR was adopted in April 2016 and is due to be formally imposed on May 25th, 2018. In a nutshell for those who are not quite so GDPR savvy, the GDPR emphasizes transparency, security, and accountability by data controllers and introduced mandatory Data Protection Impact Assessments (DPIAs) for those organizations involved in high-risk processing. For example, where a new technology is being deployed, where a profiling operation is likely to significantly affect individuals or where there is large-scale monitoring of a publicly accessible area.

Breach Notification Requirements

A DPIA is the process of systematically considering the potential impact allowing organizations to identify potential privacy issues before they arise and come up with a way to mitigate them. In addition, and a highly important aspect for Security Operation Centers (SOCs) and Computer Security Incident Response Teams (CSIRTs) to be fully aware of and responsive to, data processors must implement an internal breach notification process and inform the supervisory authority of a breach within 72 hours. They must also communicate the breach to affected data subjects without due delay or consequently face a penalty of up to EUR 20,000.00 or 4% of worldwide annual turnover for the preceding financial year, whichever is greater.

Incident Response Processes and Best Practices

As the number of breaches has risen and cyber attacks have become more sophisticated, authorities have recognized a need for increased data protection regulation. The number of simultaneous processes required in a typical forensic or Incident Response Scenario has also grown. Processes need to cover a broad spectrum of technologies and use cases must be standardized, and must perform clearly defined, fully documented actions based upon regulatory requirements, international standards and established best practices.

Additionally, context enrichment and threat analysis capabilities must be integrated to facilitate and automate data breach reporting and notification within the timeframe specified by GDPR. Lastly, customized playbooks must be created to permit rapid response to specific incident types, aid in prioritizing tasks, assignment to individual stakeholders, and to formalize, enforce and measure specific workflows.

Incident Response Management with DFLabs IncMan

Having a platform in place to formalize and support these requirements is crucial. DFLabs IncMan provides all the necessary capabilities to facilitate this. Not only do organizations need an Incident Response plan, they must also have a repeatable and scalable process, as this is one of the steps towards compliance with the GDPR’s accountability principle, requiring that organizations demonstrate the ways in which they comply with data protection principles when transacting business. They must also be able to ensure that they will meet the 72-hour breach notification requirement or face a stiff penalty.

Find out how IncMan can help you become GDPR compliant

Organizations must establish a framework for accountability, as well as a culture of monitoring, reviewing and assessing their data processing procedures to detect, report and investigate any personal data breach. IncMan implements granular and use-case specific incident response procedures with data segregation and critical security control requirements. To enable Incident Response and breach notification in complex organizations and working across different regions, IncMan can be deployed as a multi-tenant solution with granular role-based access.

Cutting Response Time and Accelerating Incident Containment

Automated responses can be executed to save invaluable time and resources and reduce the window from discovery to containment for an incident. Organizations can easily prepare advanced reports from an automatically collected incident and forensic data, and distribute notifications based on granular rules to report a breach and notify affected customers when required to comply with GDPR and avoid a financial penalty.

Finally, the ability to gather and share intelligence from various sources by anonymizing the data to share safely with 3rd party protect the data without inhibiting the investigation. IncMan contains a Knowledge Base module to document playbooks, threat assessment, situational awareness and best practices which could be shared and transferred across the organization.

IncMan and Fulfilling GDPR Requirements

In summary, DFLabs IncMan Security Automation and Orchestration platform fulfills the requirements of GDPR by providing capabilities to automate and prioritize Incident Response through a range of advanced playbooks and runbooks, with related enrichment, containment, and threat analysis tasks. It distributes appropriate notifications and implements an Incident Response plan (IRP) in case of a potential data breach, with formalized, repeatable and enforceable incident response workflows.

IncMan handles different stages of the Incident Response and Breach Notification Process, providing advanced intelligence reporting with appropriate metrics, with the ability to gather or share intelligence with 3rd parties as required.

So, this Valentine’s Day, we hope that you are enjoying a romantic dinner for two, knowing that your SOC and CSIRT, as well as the wider organization, has the necessary incident response and incident management best practices implemented to sufficiently meet the upcoming GDPR requirements in 100 days’ time. If not, speak to one of our representatives to find out more.

Find out how IncMan can help you become GDPR compliant

GDPR & Breach Notification – Finally We Will Get Some European Breach Data

The EU GDPR will be enforced from May 25th next year. GDPR mandates a wide variety of requirements on how data processors must manage customer and 3rd party data. Although it is not primarily focused on cybersecurity, it does contain vague requirements on security monitoring. This includes that data processors must establish a breach notification procedure, that include incident identification systems, and must be able to demonstrate that they have established an incident response plan.

GDPR and Data Breach Notification

Further, there is a requirement to be able to notify the supervisory authority of a data breach within 72 hours of becoming aware of a data breach or face a stiff financial penalty. This last requirement is of special interest beyond the impact on data processors. Because it means that for the first time, we will begin having reliable data on European breaches.

Historically, European companies have had no external requirement to be transparent about being affected by a breach. This has had the consequence that we have not had good data or an awareness of how well or badly European organizations are doing when it comes to preventing or responding to security breaches.

I am sure that if like myself, you have worked in forensics and incident response in Europe over the years, you are aware of far more breaches that are publicly disclosed. The only information available is when a breach is disclosed due to the press and law enforcement, or the impact is so great that it can’t be ignored. We also have some anonymized reports from some vendors and MSSP’s, but these are really no more than samples. While not without benefit, these also do not provide a reliable indicator, as the samples are not necessarily statistically representative This provides a false sense of how European organizations are faring compared to other regions and presents a skewed image of European security in general.

The true state of European security is an unknown and has been difficult to quantify. I have seen German articles for example that have claimed that German Security is better than the rest of the world because there are less known breaches. The absence of evidence is of course not evidence of absence. Something that has not been quantified cannot be said to be good or bad. More importantly, if you do not measure something, it cannot be improved.

It will be interesting to see whether GDPR will force European organizations to place more focus on Incident Detection and Response, and give us insight into the true state of European security.