What is GDPR & It Influence Enhancing Data Privacy

Introduction of GDPR

The importance of the protection of private data and the business risks associated with it has increased post-GDPR. The reasons might be several, ranging from the large penalties posed for non-compliance to bringing an exclusive legal framework for data protection but it can be said that business organizations now view data protection with adequate caution.

What is GDPR?

GDPR stands for General Data Protection Regulation. It is an important legal framework for data privacy formed by the European Union. The European Commission decided to plan the data protection framework for its business organizations in 2012 and later GDPR was introduced as one of the major parts of this reform. GDPR’s applicability extends to the organizations in Europe, the organizations in all its member states across and beyond Europe.

7 Principles of GDPR

The GDPR uses 7 principles to optimize data privacy in an organization. Let us first take a look at the seven principles of GDPR:

  1. Lawfulness, fairness, and transparency- The GDPR states that processing of data must have proper reasons and the reasons can include or extend to any of the below: You have the user’s consent.
    • You need to process it for a contract.
    • It is crucial for fulfillment of any legal obligation.
    • For the protection of the vital interests of a natural person.
    • It is done in the public interest.
    • You have a legitimate interest.
  2. The data handling and reason for data processing must be transparent. The way of dealing with personal data must be fair and with the consent of the user without any withholding or misuse of data.
  3. Purpose limitation- The GDPR limits the purpose of data processing. It states that data must be collected for specified, explicit, and legitimate purposes only. The purpose for data usage must be clearly defined, communicated to relevant users, and adhered to strictly. Any purpose or need for data processing arising out of the defined scope must have updated consent.
  4. Data minimization- GDPR not only limits the purpose of the data collected but also the data itself. It restricts the amount of data collected for the specified purpose to the minimum. Collection and processing of any excess data must be avoided.
  5. Accuracy- Data collected and processed must be limited, defined to a purpose, and must be accurate. Any inaccurate data must be erased and data storage must be cleaned at regular intervals.
  6. Storage limitation- Storage of data must be specified to a fixed duration. Data retention periods must be specified and any data which is not used after a certain period must be anonymized.
  7. Integrity and confidentiality- Data stored must be protected from threats and must be confidential. Handling of confidential data must be done with complete integrity and diligence to avoid data breaches or data loss.
  8. Accountability- It is not merely enough to follow the principles prescribed by the GDPR, but also a considerable amount of accountability has been created by the need for evidence. There must be a complete documentation of all procedures followed. Adequate evidence must be produced by the organization demonstrating the compliance of the organization with the GDPR requirements.

Effects of GDPR non-compliance:

The repercussions of not being GDPR compliant depends on the severity of the data breach and how severely the organization has followed the GDPR requirements previously. It can be anything from a fine ranging from 10 million euros to four percent of the company’s annual global turnover.

For instance, an organization that has committed an infringement of rights of its data subjects or unauthorized transfer of personal data internationally, or detaining requests of subjects for access of their data will have to pay a maximum penalty of 20 million euros or four percent of worldwide turnover – whichever is greater. These kinds of losses sometimes lead to billions for big organizations.

The wholesome impact of the GDPR approach

What are the impacts of achieving  GDPR compliance  in an organization? Read through:

  • Increase in customer trust: The GDPR lays down frequent audits of data protection activities and employs a Data Protection Officer (DPO) as a mandatory requirement. Compliance with such data protection principles makes sure that necessary operational practices are in place and this increases the trust of the customers.
  • Improved data security: The access to critical data must be restricted only to necessary resources and the GDPR ensures this through its requirement of privileged identity access management. The GDPR has laid down a strong foundation for data security. It goes a step further and states that any data breach or exposure of data to unauthorized personnel must be reported within 72 hours of occurrence.
  • Cuts down maintenance costs – The GDPR lays down that any data or software or internal applications which are redundant. It requires an organization to keep all their up to date to be compliant with the GDPR requirements and this way, the costs related to storage and retention of old data is cut down.
  • Constantly evolving technology- There are multiple advantages to staying up-to-date from better management of business demands internally to offering better quality to customers externally. The GDPR pushes an organization to stay at its best and latest technology constantly, pushing it to adapt to migrating trends like cloud computing, BYOD, virtualization, etc.
  • Improved decision making- The requirements laid down by GDPR are such that the organizational data and data management will become more consistent and consolidated, which in turn makes it easier to use for automation and analysis. This decreases arbitration and improves the decision-making in the organization.

How GDPR enables optimum data privacy?

The GDPR is not merely a legal requirement, but a legislation that provides wide scope for the achievement of better data security and privacy while striking a balance between advancement in business and technology. The GDPR uses tools like pseudonymization and its seven principles to demonstrate better privacy within the organization.

Anonymization and pseudonymization of data are critical tools through which the GDPR enables optimum data security and privacy in the organization. Using the concept of  pseudonymization, data can be partially anonymized:

  • When data is collected, the user’s identity is replaced with a unique random pseudo-identity.
  • The relationship between the user’s identity and pseudo-identity is stored separately.
  • The data user can be determined with the help of the mapping data stored separately.
  • The data is regarded as pseudonymized.
  • It is crucial to keep this mapping data safely stored. On deletion of the mapping data, the data gets fully anonymized.

The GDPR enables optimization of data privacy in every step of meeting its requirements, right from understanding the purpose of data collection, defining the scope of data collection, minimizing the amount of data collected and stored, obtaining adequate consent from data users for collection, and maintenance of documentation for all the processes followed.

It is the basic requirement of the GDPR to follow lawfulness, fairness, and transparency of data irrespective of whichever process is followed. It is a continuous and evolving process to achieve the principles of the GDPR and this process enables an organization to exercise optimum privacy of personal d

Assessment process followed by QRC –

We at QRC, provide  GDPR assessment  services and can lead you through the road-map of staying GDPR compliant. Take a look at our implementation process:

  • GDPR Readiness Check Questionnaires- This is done to determine the amount of data risk present in the current situation, to check if the organization is GDPR-ready.
  • GDPR Gap Analysis – Ascertaining the position of the organization in terms of GDPR requirements and conducting a gap analysis to determine plans for reaching the standards.
  • GDPR Data Flow Audit- A data flow audit is conducted with a prepared data flow map. This is to clearly define what personal data is stored and how it is stored.
  • On-site audits- An on-site audit is conducted with a questionnaire to identify how the organization’s improved practices demonstrate readiness.

Data Protection Impact Assessment (DPIA)- All new processes introduced in time, need to undergo assessment for data protection risks associated with them and a remediation plan to mitigate those risks.

Cyber Security Firms As Certification Bodies

Year after year, several organizations report millions of dollars of loss. Recent surveys suggest that increasing vulnerabilities like data breaches, ransomware attacks are one of the leading reasons for such loss. Apart from monetary loss, the loss of reputation caused by such cyber threats is a deadlier blow for organizations to recover from.

A prime solution to these losses is opting for a Cybersecurity firm that uses their expertise like vulnerability analysis, audits to identify threats, penetration testing to protect businesses from such vulnerabilities. They also develop new technologies to guard the digital assets of organizations posed to such cyber risks. Apart from being a third-party company that provides solutions to cyber risks, can a decision to work with a cyber security firm give any value additions to the organization? Yes, it does.

Why should you look out for a cyber security firm if you want to get the ISO 27001 and the ISO 27701 certification?

Read through to find out…

Cyber security firms as  Certification bodies:

Professional expertise:  When opting for a cyber security firm as a certification body, the major advantage is the high level of expertise offered by the professionals in the team. The auditors from such an organization have a deep understanding of cyber security principles. This level of knowledge is offered exclusively for the sole purpose of making the organization compliant with the standards prescribed in the specified certification.

Advantages for various stakeholders:  The advantages of choosing a cyber security firm as a certification body do not end with the value additions provided for the chosen organization. There are several advantages to the various stakeholders of the organization. Cyber security firms not only create an impact on the data security and protection aspects but also create a wholesome impact on aspects like Risk management, governance, do and business continuity. When an organization is ISO 27701 certified by a cyber security firm, it is evident that the organization’s management has implemented all the best practices in cyber security as follow-up assessments are usually a part of the certification process.

Stay in-the-zone:  Cyber security firms offering certification services have years of experience in areas of Quality risk, Information system management, Cyber risk governance, etc. They are constantly in-the-zone and can provide updates on these aspects as and when required in the audit and certification process.

Significance of the ISO 27001 & ISO 27701 certifications

Impact on the business outcome:  International standards like the ISO 27001 and the ISO 27701 aid in improving the relationship with clients. It can even act as a tool to retain existing clients by providing opportunities to implement best practices within the organization. It provides an edge over others when compared with competitors by improving the quality of services provided.

Data breach:  Research suggest that the cost of a data breach increases 5%-6% every year. The burden of bearing the cost for a data breach can be destructive to a company’s growth. Getting ISO certified can save you from being burdened

As the accepted global benchmark for the effective management of information assets, ISO 27001 enables organizations to avoid the potentially devastating financial losses caused by data breaches. It also ensures that necessary controls are in place to protect the organization from potential threats. It is designed in a way that mandatory regulatory requirements are met for the GDPR, NIST CSF, etc.

Organization’s goodwill:  Cyber-attacks not only cause monetary loss but also cause the reputation of the organization. As the threat levels increase day by day, the risk of losing your organization’s reputation overnight is also increasing. Being ISO certified can prevent this loss.

Improvements on the internal front:  Allocation of responsibilities and a clear definition of hierarchy is crucial during the growth phase of an organization. A poorly defined hierarchy for the management of information assets can bring internal conflict and confusion. A standard like the ISO 27001 or the ISO 27701 increases productivity in the internal management of a company by clearly setting the objectives and responsibilities of risk management.

Adhering to the requirements of ISO prescribed standards also implies that the organization has effective security measures and gradually decreases the frequency of internal audits.

QRC as a certification body

QRC is a cyber security firm that offers ISO 27001 and ISO 27701 certifications as a part of its services. We are a team of passionate cybersecurity professionals providing multiple Quality, Risk, & Compliance services. We have completed over 2000 assessments with 250 clients in 25 countries with the help of our 200 man-years of experience. We truly believe in the transformative power of Quality, Risk, and Compliance Solutions. We strive to elevate customer satisfaction, engage and inspire people all around the world and increase their ability to secure business.

A brief on our methodology:

We follow a comprehensive methodology for the implementation and certification process:

Implementation Methodology

  • Developing a security policy as per the business requirement for information security.
  • Defining the scope of the ISMS, PIMS, and all aspects of people, processes, and technology are included.
  • Conducting a risk assessment.
  • Identification of risks post the risk assessment and undertaking adequate steps and changes in the management.
  • Selection of control objectives and end-to-end implementation in the organization.
  • Drawing up a statement of applicability.
  • Defining policies, procedures, MRM and awareness training, etc.

Certification Methodology

  • Preparation & Documentation
  • Stage 1 Audit
  • ISMS Implementation
  • Stage 2 Audit
  • Issuance of Certificate
  • ISMS Maintenance And Improvement
  • Annual Assessment

Additional benefits:

There are multiple value additions apart from our unique methodology, by choosing QRC to complete the ISO 27001 or ISO 27701 certification:

  • An increase in brand value, as a result, facilitates agreements with business partners where the processing of PII is mutually relevant.
  • An increase in internal competence as our processes encourage the internal management to prescribe a clearly defined set of roles and responsibilities.
  • Build a clear set of roles and responsibilities for PII controllers and PII processors holding responsibility and accountability for personal data processing.
  • Our methodology integrates easily with any certification recognized globally and supports one-stop some compliance with GDPR and other applicable privacy regulations.
  • Helps to strengthen relationships with existing customers and stakeholders, proving your seriousness of information privacy.
  • Minimize any risk of disruptions of crucial processes and financial losses in association with a breach.

PCI Awareness training and how to go about it

The Payment Card Industry Security Standards Council (PCI SSC) which was formed in the year 2004 for the sole purpose of addressing these risks associated with data security, has set a standard to be followed by organizations that deal with sensitive data or otherwise known as authentication information. The PCI DSS strives to protect sensitive data, but a recent survey suggests that most PCI DSS compliant organizations are viewing this standard as a certification process rather than as an opportunity to improve their resilience. In order to emphasize the importance of the PCI DSS standard and to gain a wholesome perspective, PCI awareness training is required in every organization.

Let us look into the “Who, Why What and How?” of PCI awareness training.

Who must take the PCI awareness training?

The PCI awareness training is aimed at the employees of any organization in the payment card industry, but it can be taken by anyone who would be interested in learning about the payment card industry or any organization which must stay compliant with the PCI DSS standard.

The  12.6  of PCI DSS standards states that it is mandatory for an organization that obtains, processes, and retains payment card data to provide annual training for its staff members.

Why does an organization need PCI awareness training?

Let us take a look at the benefits of undergoing PCI awareness training:

1. We are already aware of how being PCI certified can provide a deep understanding of compliance. A PCI awareness training provides important insights way before the organization actually undergoes the assessment and certification process.

2. Through such extended insights, the employees of the organization can gain an understanding of better operational efficiency, aiding in cost management and asset management.

3. Access to know best practices across the industry in advance.

4. Eases in driving compliance and efficiency across the business organization.

What is PCI DSS Standard 12.6?

The PCI DSS 12.6 consists of a Security Awareness Program and Employee Training Requirements. It requires the organization to set up a formal security awareness program to ensure that all the employees are aware of the significance of data security. Below are the requirements of 12.6 PCI DSS :
1) 12.6.1  – Provide data security training for the employees at least annually.
2) 12.6.1.a  – Arrange training through various modes and multiple methods like corporate mailers, web module-based training, training meetings, etc.
3) 12.6.1.b  – Ensure that all the employees attend the training arranged twice, once during onboarding and regularly on an annual basis.
4) 12.6.2  – Take confirmation and acknowledgment from all the staff members that the security policies and guidelines have been communicated and understood by them.

Additionally, the PCI DSS 12.6 also suggests that the training conducted demonstrates the below points :

1. The effect of compliance of PCI DSS and the training requirements are fulfilled annually.

2. To keep implementing better understanding amongst the employees through training to ensure card data is constantly being protected.

3. Make sure that all the staff knows the requirements, roles, and procedures as given by PCI DSS.

4. Ensure that the training provided includes awareness about the financial implications caused by data breaches.

5. Security updates received every month are being communicated in a timely manner through security mailers and tips.

6. The training material includes important documents and policies which have company-specific guidelines on cyber security.

How to implement PCI awareness training?

While implementing a PCI awareness training program, it is to be given utmost importance as it can prove to be a make or break of an organization’s network and cyber governance. The most important task is to decide on a security awareness team as the PCI council has stated that a security awareness team will be responsible for “the development, delivery, and maintenance of the security awareness program”. One quick tip while taking the first and foremost step of determining a security awareness team is to choose people from a different team with different responsibilities as that way the inputs provided will be diverse and various needs of different teams will be taken care of. Once a security awareness team is determined, roles must be determined within the team.

Below are a few important things to consider while arranging a PCI awareness training :

1. Primary emphasis must be given to internal security. When internal security is emphasized, the best practices are demonstrated in a well-defined manner, and this aids while tackling the external threats.

2. Every team in the organization must be given equal awareness about the threats, vulnerabilities present within the organization so that every employee maintains the same state of mind towards cyber risk while at work.

3. The prerequisite to a good training program is well-prepared process guidelines and process documents. Compliance with security standards, certifications, existing threat levels need to be analyzed and reported. Important reports and documents need to be easily and readily available for illustrating the importance of cyber risk within the organization to the employees.

4. The arranged training sessions must be in a timely manner as vulnerabilities are constantly evolving in nature. Planning the training sessions in regular intervals and in accordance with the organization’s important milestones is important. Timing is key when it comes to training.

5. From the very first day of training, make sure that employees take initiative from their end voluntarily to protect the data security of the organization. Cyber risk security tips and awareness must be included in the day-to-day activities of the employees.

6. Holding monthly awareness campaigns with a monthly theme is a good way to implement training without affecting day-to-day productivity. Cyber risk themes like password protection, social network security, etc. can be chosen as a monthly topic for special features.

7. Sending reminder emails with cyber security tips is also an efficient way of implementing cyber security amongst employees. Email newsletters can be sent if any new guidelines are implemented.

8. Intranet portals must be actively used to access the important reports and documents used during the annual training sessions. This way, employees will always have sufficient access to cyber security guidelines.

Cyber Security Governance: Pathway to a Cyber Risk

In an organisation which does not have an exclusive cyber security governance program, the management of an organisation must emphasise on the risk assessment primarily as any mistakes in the primary risk assessment process can increase the chances of the risk exposure due to decreased readiness to deal with the consequences. This is the reason a cyber security governance program is essential to any organisation. A cyber security governance program makes sure that there is a continuous process of risk assessment and change in policies.

Cyber Risk and the need for Cyber Security

When an organisation is exposed to certain risk, it means that it is constantly anticipating an event which poses the organisation to certain vulnerabilities and also it means that it must face the consequences or after effects of that anticipated event. Probability is the only saving grace for an organisation exposed to any risk, as it measures the chance of the anticipated event occurring and affecting the organisation. So, when there is an absence of probability, it can be said that the organisation is not exposed to the particular risk and this decreases the chances of dealing with the after effects also. This can be stated as the basis of the relationship between any risk and risk management. Cyber risk and management of cyber risk is known as cyber security governance in an organisation.

A cyber security governance program defines the objectives of cyber risk management taking into view the business objectives simultaneously. With the help of these objectives, a clearly defined plan of action is made and implemented into the processes. This way, it achieves the purpose of strategic management of risks. Information security framework is an integral part of corporate governance and cyber security governance goes hand in hand with it.

Pre-requisites for a Cyber security governance program

If you are thinking of developing a full-fledged cyber security governance program for your organisation, what are the things that must be in your check-list? There are few steps which can be a prerequisite to aid for developing a complete cyber security governance program:

  • Identify the current security posture: The first thought before developing a strategy is to determine where the organisation is in its current security position. While determining the current security posture of the organisation, its level of risk exposure and the policies to risk protection which are currently in practice, needs to be clearly defined and documented. This is crucial for understanding the nature of risks and the gaps in existing policies and processes.
  • Reviewing the basics: In an organisation, cyber security policies and standards need to be implemented at process level. Existing cyber security policies must be reviewed and updated. Policies and standards must be created in case they are not currently documented.
  • Altering the view point: The view-point in which the risk is assessed also makes a difference. Cyber security risks must be approached from an enterprise point of view. This way it is possible to clearly identify the organisation’s critical information and data that needs protection and align with the organisation’s risk appetite.
  • Being risk aware: Training is the key to be risk aware. Information security awareness training must be conducted frequently  as the nature of the organisation’s risks evolves from time to time. It is important to ensure all the resources of the organisation understand the importance of cyber security.
  • Verifying completeness: During the formation of cyber security policies, it is important to consider all the risks that an organisation is exposed to. Internal risks, external risks, risks associated with third parties, constant risks and volatile risks are to be considered.
  • Continuous improvement: This step is an integral part of cyber security governance. It is achieved with regular assessments, analysis of data and updating risk management plans.

Steps to improve cyber security & ways to ease Cyber security governance:

What are the steps to be followed by an organisation to improve its existing cyber security governance program?

  • Constant review of internal cybersecurity policies: This is a strategic step towards dynamic cybersecurity governance. The top level management of an organisation must be aligned with the cybersecurity practices and policies. Cyber security strategies and policies must be given due importance and discussed in board meetings and considered during important decision making discussions. This way, the policies are regularly updated and the status of these plans are available to important decision makers.
  • Gap analysis: It is best to continuously measure where we stand when we want to attain wholesome and secure governance. According to the results from such assessments, a process must be implemented to internally strengthen the cyber security policies in practice. Apart from being aware of the organisation’s procedure, opting to be at par with specified best practices is a smart move to attain good governance.
  • Staying up-to-date: Just as risks evolve from time to time, so do the statutory requirements. Updates regarding cyber risk and compliance must be discussed with the specific advisory opted by the organisation’s management. It is always wise to opt for exclusive advisory services when it comes to cyber risk governance.
  • Cyber security as an investment: Cyber security governance and management of cyber risk must be considered as an important factor during the budgeting. With the increasing cyber risk and growing exposure to data threats, attention and financial assistance becomes a mandate. Cyber security governance is not to be considered as an expense but investment, as it improves the business and its output in many ways dynamically.
  • Keeping business continuity in mind: When we say business continuity, the key factor is incident response. Preparing for incident response is a proactive approach to risk management but is a primary step to good governance. This way, business continuity is ensured and the importance of cybersecurity is reiterated to all stakeholders of the organisation.
  • Awareness training: Awareness training is not just for the internal resources of the organisation but also important to customers and third parties. The training must provide a set of guidelines to be followed by all stakeholders to ensure security practices and security governance is followed.
  • Read more about this: A Go To Guide For Cybersecurity Technique

Cyber Security governance- key to strong risk management

It is of utmost importance to understand the need for compliance and the significance of security as they both are completely different aspects. Both security and compliance are two challenges faced by any organisation, irrespective of its size and the kind of risk management policies adopted. A common mistake done by organisations are, viewing compliance as a tool for risk management, while it is actually just the bare minimum amongst the risk management policies that an organisation is expected to maintain. When basic guidelines are used as a strategy, the objective of cyber risk governance goes for a toss. It is important to understand that compliance is not a standard to be followed, but just a basic threshold to be adhered to.

Cyber risk governance is an aspect of risk management which is to be taken to the very core of an organisation’s business objectives and operations, to achieve a strategy. Vulnerabilities involved in cyber risk and the magnitude of loss caused by data breach improves risk awareness within the organisation. Security and Cyber risk management must be inculcated into the policies, procedures and people to develop a culture of being risk-aware and resilient at business operations.

It is evident that cyber-crime evolves as time and technology evolves. And as business grows, cyber risk also grows. If you have not given cyber security governance a thought, it is high time to bring it as a topic of discussion. Due to statutory requirements, risk management and compliance have been part of organisations since decades now. But cyber security governance is the one thing which can give you that edge over other organisations. We at QRC, are pioneers in Cyber risk and cyber security governance offering cyber security compliance certifications.