GDPR: 9 Steps to Implement a Security Mgmt Tool

Download the PDF Version (GDPR Get Prepared SIEM Checklist)

Background

The General Data Privacy Regulation (GDPR) officially known as REGULATION (EU) 2016/679, will come into force on 25thMay of 2018. The regulation covers the protection of natural persons with regard to the processing of personal data and on the free movement of such data. The regulation builds on existing data protection regulations such as the UK Data Protection Act 1998, the Belgian Privacywet, or the German Bundesdatenschutzgesetz (BDSG).

The regulation will affect the vast majority of businesses as most businesses today hold personal data, even if it’s only HR data. A significant change is that it will put data processors under significantly more legal liability if a breach occurs.

Breaches will need to be reported within 72 hours and must include information such as;

  • The nature of the personal data breach including, where possible:
  • A description of the likely consequences of the personal data breach; and
  • A description of the measures taken, or proposed to be taken, to deal with the personal data breach and, where appropriate, of the measures taken to mitigate any possible adverse effects.

 

If the breach is sufficiently serious to warrant notification to the public, the organisation responsible must do so without undue delay.

In light of the tight timescales for reporting a breach – it is important to have robust breach detection, investigation and internal reporting procedures in place. The following sections of this booklet outlines a checklist to implement a robust security and event management platform that will be a core component of a GDPR compliant security strategy.

 

  1. Implement a Security and Event Management Tool (SIEM)

A SIEM is a fundamental security tool for many organisations.

Implementation of a SIEM helps companies monitor all users and system activity to identify suspicious or malicious behaviour. This is achieved by centralising logs from applications, systems, and the network and correlating the events to alert where unexpected activity is detected.

You can then investigate the cause of the alarm and build up a view of what has occurred by determining if a particular attack method was utilised, looking at related events, source and destination IP address, and other details.

Article 30 of GDPR states that each controller, and where applicable, the controller’s representative, shall maintain a record of processing activities under its responsibility.

You must also take into consideration data stored or processed in cloud environments. If personal data is in the cloud, it is within the scope of GDPR, and therefore it is beneficial for the SIEM tool to maintain a record of activity across your public and private cloud infrastructure as well as on premises.

 

  1. Create a Log of Critical Assets that Store/Process Sensitive Data

GDPR covers all IT systems, network, and devices, including mobile devices, making it essential that you account for all assets across your infrastructure and understand where personal data is held.

It’s important to record all assets and locations that process or store personal data. It’s also worth noting that your company could be exposed to attacks and regulatory fines if employees process or store personal data on unapproved devices.

Without strong governance practices in place, it can be easy to lose track of assets.

It is important to sample your systems, networks, and data stores to determine if personal data is exposed outside your defined data flows and environments.

Keep in mind that this is a process. Records will need to be updated on an ongoing basis as your business and technology changes.

 

  1. Undertake Vulnerability Scanning

To identify where weaknesses exist that could be exploited

New vulnerabilities in systems and applications arise almost daily.

It is essential that your organisation stays on top of these weaknesses with regular vulnerability scanning.

These vulnerabilities may exist in software, system configuration, in business logic or processes. It is essential to consider all aspects of vulnerabilities and where they can exist.

However, simply finding a vulnerability is often not enough.

There are multiple factors that need to be considered such as whether the systems are in accordance with GDPR and what the business-criticality is, whether intrusions have been attempted, and how the vulnerability is being exploited by attackers in the wild.

Effective vulnerability assessment requires continuous scanning and monitoring of critical assets where personal data is stored or processed. It is equally as important to monitor cloud environments in addition to on-premises environments.

 

  1. Conduct Risk Assessments

To identify where weaknesses exist that could be exploited

The use of an information security framework can assist by providing a starting point for organisations to better understand the risks facing the business.

Article 35 of GDPR requires organisations to conduct a data protection impact assessment (DPIA) or similar. Whereas Article 32 of the regulation requires organisations to “implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk.”

Existing frameworks such as NIST, ISO / IEC 27001, or similar standards can assist companies in undertaking and supporting the DPIA process.

While GDPR does not specify a framework for risk assessments or threat modelling, a company’s adherence to any well-established and internationally recognised standard will make demonstrating compliance with Articles 32 and 25 much more likely in the event of a breach.

 

  1. Regularly Test

To gain assurance that security controls are working as designed, GDPR asks for a process for regularly testing, assessing, and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.

Assessing and evaluating the effectiveness of security controls is by no means an easy feat. Usually, the larger the IT environment, the more disparate the technology stack, and the more complex the environment. Thus, the harder it is to gain assurance.

Three broad techniques exist to validate the effectiveness of security controls:

  1. Manual assurance. This involves audits, assurance reviews, penetration testing and red-team activities.
  2. Consolidated and integrated security products, so that fewer point products need to be managed and reported on.
  3. The use of automated assurance technologies.

With these methods, you can gain a measure of assurance that your systems are secured as intended. However, it is worth remembering that assurance is not a one-time effort, rather an ongoing, repeatable process.

 

  1. Ensure Threat Detection Controls are in Place

To reliably inform you in a timely manner when a breach has occurred, GDPR requires organisations to report to the regulatory body within 72 hours of being aware of the breach.

For high-risk events, the controller must notify data subjects without any delay. The typical time-to-compromise continues to be measured in minutes, while time-to-discovery remains in weeks or months. In such circumstances, it’s essential to have comprehensive threat detection capabilities that can detect issues as soon as they occur.

Threats can occur internal to the company or externally and can be on-premises or in cloud environments. This makes it important to be able to collect and correlate events quickly as well as supplement the information with reliable threat intelligence to stay on top of emerging threats.

There is not one place or tool that will be suitable for all purposes. At times a threat is discovered on the endpoint, the perimeter, or by analysing internal traffic. In this case, controls should be placed accordingly in the environment to increase the chance of detecting threats as soon as they occur.

 

  1. Monitor Network and User Behaviour

To identify and investigate security incidents rapidly, GDPR is focused on ensuring that citizen data is gathered and used appropriately for the purposes it was stated.

Therefore, it is important to focus not just on external threats or malware, but also to detect whether users are accessing data appropriately. Context is critical when evaluating system and network behaviour.

For example, an abundance of Skype traffic in the network used by your inside sales team is probably a normal part of operations. However, if the database server that houses your customer list suddenly shows a burst of Skype traffic, something is likely wrong.

There are many methods that can be deployed to monitor behavioural patterns. One method is to utilize NetFlow analysis, which provides the high-level trends related to what protocols are used, which hosts use the protocol, and the bandwidth usage. When used in conjunction with a SIEM, you can generate alarms and get alerted when your NetFlow goes above or below certain thresholds.

 

  1. Have a Documented and Practiced Incident Response Plan

To comply with GDPR regulations, organisations need to have a plan in place to detect and respond to a potential data breach to minimise its impact on EU citizens. In the case of an attack or intrusion, a streamlined incident response process can help you respond quickly and effectively to limit the scope of the exposure.

If you have unified threat detection controls and processes established to alert you to an incident, your incident response plan should be able to quickly and accurately determine the scope of impact. You should investigate all related events in the context of other activity in your IT environment to establish a timeline, and the source of attack should be investigated to contain the incident.

Once you have controlled the incident, you should evaluate if a possible breach of personal data occurred and decide if reporting is required under GDPR. Then, you should prioritise and document all response and remediation tactics. Be sure to verify that your incident response activities have successfully remediated the issue. You will need to inform the regulator of all steps taken, and where necessary, inform any affected EU citizens.

 

  1. Have a Communication Plan in place to detect and respond to a potential data breach

In the event of a breach, your organization must report to the regulatory body within 72 hours of being aware of the breach.

For high-risk events, the controller must notify data subjects without undue delay (Article 31).

The notification given is required to at least:

  • Describe the nature of the breach
  • Provide the name and contact details of the organization’s data protection officer
  • Describe the likely consequences of the breach
  • Describe the measures taken or proposed to be taken by the data controller to address the breach and mitigate its adverse effects.

Ask yourself:

  • Can I identify whether systems in scope of GDPR are affected in a breach?
  • Do I have the contact details of the regulatory body that I need to notify?
  • If need be, do I have a reliable mechanism to contact affected customers

 

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