The General Data Protection Regulation & The Duty to use Encryption

The General Data Protection Regulation, abbreviated to GDPR, raised a storm when it arrived. In reality, it merely tightened up on existing good practice according to digital security specialists Gemalto. The right to withhold consent and to be forgotten has always been there, for example. However, the GDPR brings a free enforcement service for consumers, thus avoiding the need for third party, paid assistance.

The GDPR Bottom Lines for Data Security
Moreover, the GDPR has penalties it can apply, of the order that might have a judge choking on his wig. Under it, data security measures such as pseudonymisation (substitution of identifying fields) and encryption (encoding including password protection) have become mandatory. Businesses must further respect their client data by:

a) Storing it in a secure environment supported by robust services and systems

b) Having proven measures to restore availability and access after a breach

c) Being able to prove frequent effectiveness testing of these measures.

The General Data Protection Regulation places an onus on businesses to report any data breaches. This places us in a difficult situation. We must either face at least a wrist slap upon reporting failures. Alternatively, pay a fine of up to ?10 million, or 2% of total worldwide annual turnover.

The Engineered Weak Link in the System
Our greatest threat of breach is probably when the data leaves our secure environment, and travels across cyberspace to an employee, stakeholder, collaborator, or the client themselves. Since email became open to attack, businesses and individuals have turned to sharing platforms like Dropbox, Google Drive, Skydrive, and so on. While these do allow an additional layer of password protection, none of these has proved foolproof. The GDPR may still fine us heavily, whether or not we are to blame for the actual breach.

How Hacking is Approaching Being a Science
We may make a mistake we may regret, if we do not take hacking seriously. The 10 worst data hacks Identity Force lists are proof positive that spending lots of money does not guarantee security (any more than having the biggest stock of nuclear weapons). We have to be smart, and start thinking the way that hackers do.

Hacker heaven is finding an Experian or a Dun & Bradstreet that may have shielded 143 million, and 33 million consumer records respectively, behind a single, flimsy cyber-security door. Ignorance is no excuse for them. They should simply have known better. They should have rendered consumer data unreadable at individual record level. The hackers could have found this too demanding to unpick, and have looked elsewhere.

How Data Encryption Can Help Prevent Hackers Succeeding
Encrypting data is dashboard driven, and businesses need not concern themselves about it works. There are, however, a few basic decisions they must take:

a) Purge the database of all information held without explicit permission

b) Challenge the need for the remaining data and purge the nice-to-haves

c) Adopt a policy of encrypting access at business and customer interfaces

d) Register with three freemium encryption services that seem acceptable

e) After experimenting, sign up for a premium service and be prepared to pay

Factors to Consider When Reaching a Decision
Life Hacker?suggests the following criteria although the list is a one-size-fits-all

a) Is the system fast, simple, and easy to operate

b) Can you encrypt hidden volumes within volumes

c) Can you mass-encrypt a batch of files easily

d) Do all other files remain encrypted when you open one

e) Do files automatically re-encrypt when you close them

f) How confident are you with the vendor, on a scale of 1 to 10

It may be wise to encrypt all the files on your system, and not just your customer data. We are always open to a hack by the competition after our strategic planning. If we leave the decision up to IT, then IT, being human may take the easy way out, and encrypt as little as possible.

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Failure Mode and Effects Analysis

 

Any business in the manufacturing industry would know that anything can happen in the development stages of the product. And while you can certainly learn from each of these failures and improve the process the next time around, doing so would entail a lot of time and money.
A widely-used procedure in operations management utilised to identify and analyse potential reliability problems while still in the early stages of production is the Failure Mode and Effects Analysis (FMEA).

FMEAs help us focus on and understand the impact of possible process or product risks.

The FMEA method for quality is based largely on the traditional practice of achieving product reliability through comprehensive testing and using techniques such as probabilistic reliability modelling. To give us a better understanding of the process, let’s break it down to its two basic components ? the failure mode and the effects analysis.

Failure mode is defined as the means by which something may fail. It essentially answers the question “What could go wrong?” Failure modes are the potential flaws in a process or product that could have an impact on the end user – the customer.

Effects analysis, on the other hand, is the process by which the consequences of these failures are studied.

With the two aspects taken together, the FMEA can help:

  • Discover the possible risks that can come with a product or process;
  • Plan out courses of action to counter these risks, particularly, those with the highest potential impact; and
  • Monitor the action plan results, with emphasis on how risk was reduced.

Find out more about our Quality Assurance services in the following pages:

The Rights of Individuals Under The General Data Protection Regulation

The General Data Protection Regulation or GDPR is a European Union law reinforcing the rights of citizens concerning the confidentiality of their information, and confirming that they own it. We thought it would be interesting to examine the GDPR effective 25 May 2018 from an Irish citizen?s perspective. This article is a summary of information on the Data Protection Commissioner?s website, but as viewed through a businessperson?s lens.

How the Office Defines Data Protection

The Office believes that organisations receiving personal details have a duty to keep them private and safe. This applies inter alia to information that individuals supply to government, financial institutions, insurance companies, medical providers, telecoms services, and lenders. It also applies to information provided when they open accounts.

This information may be on paper, on computers, or in video, voice, or photographic records. The true owners of this information, the individuals have a right:

  • To make sure that it is factually correct
  • To the assurance that it is shared responsibly
  • That all with access only use it for stated purposes

Any organisation requesting personal information must state who they are, what the information is for, why they need to have it, and to whom else they may provide it.

Consumer Rights to Access Their Personal Information

Private persons have a right under the GDPR to a copy of all their information held or processed by a business. The regulation refers to such businesses as ?data controllers? as opposed to owners, which is interesting. They have to provide both paper and digital data, and ‘related information?.

Data controller fees for this are discretionary within limits. The request may be denied under certain circumstances. The data controller may release information about children to parents and guardians, only if it considers a minor too young to understand its significance. Other third parties such as attorneys must prove they have consent.

Consumer Rights to Port Their Data to Different Services

Since the personal information belongs to the individual, they have a right not only to access it, but also to copy or move it from one digital environment to another. The GDPR requires this be ?in a safe way, without hindrance to usability?. An application could be a banking client that wants to upload their transaction history to a third party price comparison website.

However, the right to data portability only applies to data originally provided by the consumer. Moreover, an automated method must be available for porting. Data controllers must release the information in an open format, and may not charge for the porting service.

Consumer Rights to Complain About Personal Data Abuse

Individuals have a right under the General Data Protection Regulation to have their information rectified if they discover errors. This right extends to an assurance that third parties know about the changes – and who these third party entities are. Data controllers must respond within one month. If they decline the request, they must inform the complainant of their right to further remedial action.

If a data controller refuses to release personal information to the owner, or to correct errors, then the Data Protection Office has legal power to enforce the consumer?s rights. The complainant must make full disclosure of the history of their complaint, and the steps they have taken themselves to attempt to set things right.

Further Advice on Getting Things Ready for 25 May 2018

The General Data Protection Regulation has the full force of law from 25 May 2018 onward, and supersedes all applicable Irish laws, regulations, and policies from that date. We recommend incorporating rights of data owners who are also your customers into your immediate plans. We doubt that forgetting to do so will cut much sway with the Data Commissioner. Remember, you have one month to respond to consumer requests, and only one more month to close things out subject to the matter being complex.

Top 10 Disadvantages of Spreadsheets

Fraudulent manipulations in company Excel files have already resulted in Billion-Dollar losses. The main underlying reason behind this spreadsheet vulnerability is the inherent lack of controls, which makes it so easy to alter either formulas, values, or dependencies without being detected.


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1. Vulnerable to Fraud

Of all the spreadsheet disadvantages listed here, this is perhaps the most damaging. Fraudulent manipulations in company Excel files have already resulted in Billion-Dollar losses. The main underlying reason behind this spreadsheet vulnerability is the inherent lack of controls, which makes it so easy to alter either formulas, values, or dependencies without being detected.

2. Susceptible to trivial human errors

While fraud will always be a threat to spreadsheet systems, there is a more significant threat that should make you seriously consider getting rid of these outdated systems. And that is its extreme susceptibility to even trivial human errors. Missed negative signs and misaligned rows may sound harmless.

But when they damage investor confidence or cause a considerable loss of opportunity amounting to millions of dollars (Are we serious? Google up ?spreadsheet horror stories? to find out), you should understand that it?s time to move on to better alternatives.

3. Difficult to troubleshoot or test

So how about testing spreadsheets to mitigate the risks of items 1 and 2? Good luck. Spreadsheets just aren?t built for that. It?s not uncommon to have interrelated spreadsheet data scattered across different folders, workstations, offices, or even geographical locations.

Worse, even if you are able pinpoint the locations of every related file, tracing the logic of formulas from one related cell to another can take ages. It?s pretty obvious now how you?ll also encounter a similar problem when troubleshooting questionable data.

4. Obstructive to regulatory compliance

Combine items 1, 2, and 3, and what do you get? A big headache impacting regulatory compliance. There are number of regulations that have a serious impact on the use of spreadsheets.

Some of the many regulations that impact spreadsheet systems include:

And to think it looks like regulatory bodies are just getting warmed up. Over the last two decades, we’ve seen a surge in regulations that directly affect spreadsheet-based systems. Now, you tell me that you haven?t wished there was a better way to beat regulatory compliance deadlines. Well, if you?re still using spreadsheets, then there certainly is a better way.

5. Unfit for agile business practices

We’re now in an age when major changes are shaping and reshaping the business landscape. Mergers and Acquisitions, Management Buyouts, earthquakes, tsunamis, hurricanes, uprisings, climate change, new technologies, and so on. If your business is not agile enough to adapt to such changes, it could easily be left behind or even face extinction.

Spreadsheets are normally created by individuals who have not the slightest know-how regarding software documentation. In the end, spreadsheet files become highly personalised user developed applications. So when it?s time for a new person to take over as part of a large scale business change, the newcomer may have to start from scratch.

Read further about Implementing Large-Scale Business Change

 

6. Not designed for collaborative work

Planning, forecasting, budgeting, and reporting are all collaborative activities. In other words, plans, forecasts, budgets, and reports typically require information from different individuals belonging to different departments. In addition, the final documents are a result of multiple exchanges of data, ideas, and files.

Now, if your company?s offices are scattered throughout the country or if certain team members are separated by large distances, the only way to exchange data stored in spreadsheets is through email.

Experience will tell you that such a method of exchange is susceptible to duplicate and even erroneous data. Team members will tend to find it hard to keep track of similar files going back and forth, and sometimes even end up sending the wrong version.

7. Hard to consolidate

When it comes to simple data entry and quick ad hoc data analysis tasks, spreadsheets are highly favoured by end users. This has made them one of the most ubiquitous office tools on the planet. But as a consequence, data in spreadsheet-based systems are distributed throughout the organisation.

So when it’s time to generate reports, you’ll really have to go through a slow consolidation process. In most cases, end users would have to collect data from different files, summarise them, and submit the same to their department heads through emails, portable storage media (e.g. CDs or USB flash-drives), or by copying to a commonly shared network folder.

Department heads would have to undergo a similar process before submitting them to their own superiors. This has to go on until all the information reaches their organisation’s top decision makers. Throughout the entire consolidation process, data is subjected to numerous error-prone activities such as copy-pasting, cell entry, and range specification.

8. Incapable of supporting quick decision making

In a spreadsheet-based environment, extracting data from different departments, consolidating them, and summarising the information so that it could aid the company’s top brass in making sound decisions can be very time consuming.

And because we know how susceptible spreadsheets are to errors, everyone involved in the information processing has to be ultra careful to keep the integrity of the data intact. Hence it would be prudent to enforce double-checking as much as possible.

This extra but necessary exercise can further delay the process. So, when the final information arrives at the hands of the top executive, he may not have much time to work with. (Read about Business Intelligence)

9. Unsuited for business continuity

As mentioned earlier, data in spreadsheet systems are never kept in a single place. In fact, it’s the exact opposite. The worse thing about it is that they’re always in the hands of non-IT personnel, who are understandably not familiar with storage and backup best practices.

Thus, if a major disaster strikes, full data recovery can be very difficult if not impossible. As a consequence, even if the company has financial reserves, the absence of data (e.g. accounts receivable records, customer records, and inventory) to work on can prevent the company from making a quick restart.

10. Scales poorly

As an organisation grows, data in spreadsheet-based systems get more distributed; subsequently compounding the issues outlined above. It is absolutely not advisable for a large organisation to keep using spreadsheets.

 

More Spreadsheet Blogs

Spreadsheet Risks in Banks

Top 10 Disadvantages of Spreadsheets

Disadvantages of Spreadsheets – obstacles to compliance in the Healthcare Industry

How Internal Auditors can win the War against Spreadsheet Fraud

Spreadsheet Reporting – No Room in your company in an age of Business Intelligence

Still looking for a Way to Consolidate Excel Spreadsheets?

Disadvantages of Spreadsheets

Spreadsheet woes – ill equipped for an Agile Business Environment

Spreadsheet Fraud

Spreadsheet Woes – Limited features for easy adoption of a control framework

Spreadsheet woes – Burden in SOX Compliance and other Regulations

Spreadsheet Risk Issues

Server Application Solutions – Don’t let Spreadsheets hold your Business back

Why Spreadsheets can send the pillars of Solvency II crashing down

 

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