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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Which Services to Share?

It often makes sense to pool resources. Farmers have been doing so for decades by collectively owning expensive combine harvesters. France, Germany, the United Kingdom and Spain have successfully pooled their manufacturing power to take on Boeing with their Airbus. But does this mean that shared services are right in every situation?

The Main Reasons for Sharing

The primary argument is economies of scale. If the Airbus partners each made 25% of the engines their production lines would be shorter and they would collectively need more technicians and tools. The second line of reasoning is that shared processes are more efficient, because there are greater opportunities for standardisation.

Is This the Same as Outsourcing?

Definitely not! If France, Germany, the United Kingdom and Spain has decided to form a collective airline and asked Boeing to build their fleet of aircraft, then they would have outsourced airplane manufacture and lost a strategic industry. This is where the bigger picture comes into play.

The Downside of Sharing

Centralising activities can cause havoc with workflow, and implode decentralised structures that have evolved over time. The Airbus technology called for creative ways to move aircraft fuselages around. In the case of farmers, they had to learn to be patient and accept that they would not always harvest at the optimum time.

Things Best Not Shared

Core business is what brings in the money, and this should be tailor-made to its market. It is also what keeps the company afloat and therefore best kept on board. The core business of the French, German, United Kingdom and Spanish civilian aircraft industry is transporting passengers. This is why they are able to share an aircraft supply chain that spun off into a commercial success story.

Things Best Shared

It follows that activities that are neither core nor place bound – and can therefore happen anywhere ? are the best targets for sharing. Anything processed on a computer can be processed on a remote computer. This is why automated accounting, stock control and human resources are the perfect services to share.

So Case Closed Then?

No, not quite. ?Technology has yet to overtake our humanity, our desire to feel part of the process and our need to feel valued. When an employee, supplier or customer has a problem with our administration it’s just not good enough to abdicate and say ?Oh, you have to speak to Dublin, they do it there?.

Call centres are a good example of abdication from stakeholder care. To an extent, these have ?confiscated? the right of customers to speak to speak directly to their providers. This has cost businesses more customers that they may wish to measure. Sharing services is not about relinquishing the duty to remain in touch. It is simply a more efficient way of managing routine matters.

Energy Savings Opportunity Scheme (ESOS): An Overview

Energy management is crucial to most businesses in the UK. This is primarily because energy usage substantially affects all organizations, whether large or small. The good news is that, energy costs can be controlled through improved energy efficiency. And this is exactly why Energy Savings Opportunity Scheme (ESOS) came into being ? to promote competitiveness among businesses.

Energy Savings Opportunity Scheme is the realisation of the UK Government’s ambition towards achieving the maximum potential of cost-effective energy in the economy. ESOS aims to stimulate innovation and growth, cut emissions and support a sustainable energy system.

ESOS at a Glance – Legal Perspective

The EU Energy Efficiency Directive took a major step forward on November 14, 2012 and headed towards establishing a framework to promote energy efficiency across various economic sectors. To interpret Article 8 of the Directive, the government has given birth to ESOS; requiring large enterprises to undergo mandatory energy audits and energy management systems by December 5, 2015 and at least every 4 years thereafter.

Large enterprises include UK companies that have more than 250 employees or those businesses whose annual turnover exceeds ?50 million and whose statement of financial position totals more than ?43 million. With this, over 7000 of the biggest companies in Britain will need to comply with ESOS as an approach to review their total energy use in buildings, business operations, transport and industrial processes.

Generally, ESOS is both an obligation and an opportunity. It is an obligation for the indicated target companies since they need to submit to additional regimes; focus on audit evidences; act in accordance to group structures and compliance; and observe limited penalties and note retention periods. Moreover, it is also an opportunity for companies to strive for more savings on energy projects; attempt to standardise their potential market; and effectively lower debt and legal costs.

ESOS Audits ? Looking Beyond

According to the Department of Energy and Climate Change (DECC), average first audit costs would be estimated at about ?17,000 and subsequent ones at around ?10,000. As expected, these audits will result in energy saving recommendations, of which companies need not proceed for a follow up; and substantially improve businesses in their energy management issues. DECC further states that every business that complies with ESOS could save an average of ?56,400 each year from an initial investment of ?17,000 only.

Currently, up to 6,000 UK businesses are already subject to existing CRC Carbon Reduction Scheme, Mandatory Carbon Reporting, Climate Change Levy and other compliance. This signifies that ESOS may overlap with prevailing energy efficiency legislation and may put additional pressure on energy administration. While this is true, however, ESOS holds extensive benefits. Although the scheme can be viewed as another costly compliance to environmental standards, ESOS goes straight to the bottom line and provides the organisation with competitive advantage. If large businesses act now and comply with it, they will be able to enjoy maximised payback in the long run.

Indeed, Energy Savings Opportunity Scheme is already here. It is mandatory with minimal investment. And all you have to do is act quickly, implement new improvements and earn more.

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User-Friendly RASCI Accountability Matrices

Right now, you’re probably thinking that’s a statement of opposites. Something dreamed up by a consultant to impress, or just to fill a blog page. But wait. What if I taught you to create order in procedural chaos in five minutes flat? ?Would you be interested then?

The first step is to create a story line ?

Let’s imagine five friends decide to row a boat across a river to an island. Mary is in charge and responsible for steering in the right direction. John on the other hand is going to do the rowing, while Sue who once watched a rowing competition will be on hand to give advice. James will sit up front so he can tell Mary when they have arrived. Finally Kevin is going to have a snooze but wants James to wake him up just before they reach the island.

That’s kind of hard to follow, isn’t it ?

Let’s see if we can make some sense of it with a basic RASCI diagram ?

Responsibility Matrix: Rowing to the Island
Activity Responsible Accountable Supportive Consulted Informed
Person John Mary Sue James Kevin
Role Oarsman Captain Consultant Navigator Sleeper

?

Now let’s add a simple timeline ?

Responsibility Matrix: Rowing to the Island
? Sue John Mary James Kevin
Gives Direction ? ? A ? ?
Rows the Boat ? R ? ? ?
Provides Advice S ? ? ? ?
Announces Arrival ? ? A C ?
Surfaces From Sleep ? ? ? C I
Ties Boat to Tree ? ? A ? ?

?

Things are more complicated in reality ?

Quite correct. Although if I had jumped in at the detail end I might have lost you. Here?s a more serious example.

rasci

?

There?s absolutely no necessity for you so examine the diagram in any detail, other to note the method is even more valuable in large, corporate environments. This one is actually a RACI diagram because there are no supportive roles (which is the way the system was originally configured).

Other varieties you may come across include PACSI (perform, accountable, control, suggest, inform), and RACI-VS that adds verifier and signatory to the original mix. There are several more you can look at Wikipedia if you like.

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