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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Firewalls

There are two main reasons why some companies are hesitant to plug into the Internet.

  1. They know they’ll be exposing their company data to outside attacks from malicious individuals and malware.
  2. They fear their employees might get too many distractions: games, porn, chats, videos, and even social networking sites.

One vital component for your overall security strategy against such concerns? A firewall.

A firewall can block unauthorised access to certain Internet services from inside your organisation as well as prevent unauthenticated access from the outside. It is also used to monitor users’ activities while they were online.

In an enterprise setting, one may expect a collection of firewalls either for providing layered protection or segmenting off different units in the organisation. Some areas only need a standard line of defence while others require more restrictions. As such, certain firewalls may have different configurations compared to others.

Naturally, the more intricate an organisation’s defence requirements get, the more complex the task of monitoring, testing and configuring the firewalls becomes. That’s why we’re here to help.

  • We’ll evaluate your network as well as the security requirements of each department under your organisation to determine which firewall architecture is most suitable.
  • To achieve maximum efficiency, we’ll point out where each firewall should be positioned.
  • We’ll work with your key personnel to make sure all firewall configurations are set and optimised with your business rules in mind.
  • If a large number of firewalls are required, we’ll help you set up a firewall configuration management system.
  • Firewalls should be regularly tested and assessed to ensure they are in line with the organisation’s security policies. We’ll perform these routine tasks as well.

Firewalls aren’t very good at defending against sophisticated viruses. There are much better solutions for malware-related vulnerabilities, and we can help you in that regard too.

Other defences we’re capable of putting up include:

Transformation to a process based organisation

Today’s global marketplace rewards nimble organisations that learn and reinvent themselves faster than their competition. Employees at all levels of these organisations see themselves as members of teams responsible for specific business processes, with performance measures tied to the success of the enterprise. As team members, they are “owners” of the process (or processes) to which they are assigned. They are responsible for both the day to day functioning of their process(s), and also for continuously seeking sustainable process improvements.

Transforming a traditionally designed “top down control” enterprise to a process-based organisation built around empowered teams actively engaged in business process re-engineering (BPR) has proven more difficult than many corporate leaders have expected. Poorly planned transformation efforts have resulted in both serious impacts to the bottom line, and even more serious damage to the organisation’s fabric of trust and confidence in leadership.

Tomislav Hernaus, in a publication titled “Generic Process Transformation Model: Transition to Process-based Organisation” has presented an overview of existing approaches to organisational transformation. From the sources reviewed, Heraus has synthesised a set of steps that collectively represent a framework for planning a successful organisational change effort. Key elements identified by Hernaus include:

Strategic Analysis:

The essential first step in any transformation effort must be development of a clear and practical vision of a future organisation that will be able to profitably compete under anticipated market conditions. That vision must be expected to flex and adjust as understanding of future market conditions change, but it must always be stated in terms that all organisational members can understand.

Identifying Core Business Processes:

With the strategic vision for the organisation in mind, the next step is to define the core business processes necessary for the future organisation to function. These processes may exist across the legacy organisation’s organisational structures.

Designing around Core Processes:

The next step is development of a schematic representation of the “end state” company, organised around the Core Business Processes defined in the previous step.

Transitional Organisational Forms/ Developing Support Systems:

In his transformation model, Hernaus recognises that information management systems designed for the legacy organisation may not be able to meet the needs of the process management teams in the new organisation. Interim management structures (that can function with currently available IT system outputs) may be required to allow IT professionals time to redesign the organisation’s information management system to be flexible enough to meet changing team needs.

Creating Awareness, Understanding, and Acceptance of the Process-based Organisation:

Starting immediately after the completion of the Strategic Analysis process described above, management must devote sufficient resources to assure that all organisation members, especially key managers, have a full understanding of how a process-based organisation functions. In addition, data based process management skills need to be provided to future process team members. It is not enough to schedule communication and training activities, and check them off the list as they are completed. It is critical that management set behavioural criteria for communication and training efforts that allow objective evaluation of the results of these efforts. Management must commit to continuing essential communication and training efforts until success criteria are achieved. During this effort, it may be determined that some members of the organisation are unlikely to ever accept the new roles they will be required to assume in a process-based organization. Replacement of these individuals should be seen as both an organisational necessity and a kindness to the employees affected.

Implementation of Process Teams:

After the completion of required training AND the completion of required IT system changes, process teams can be formally rolled out in a planned sequence. Providing new teams with part time support by qualified facilitators during the firsts weeks after start-up can pay valuable long term dividends.

Team Skill Development and Continuous Process Improvement:

Providing resources for on-going skill development and for providing timely and meaningful recognition of process team successes are two keys for success in a process-based organisation. Qualified individuals with responsibility for providing training and recognition must be clearly identified and provided with sufficient budgetary resources.

The Hernaus model for transformation to a process based organisation is both well thought out and clear. His paper provides an ample resource of references for further study.

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Total Quality Management

Total Quality Management (TQM) is another business management approach that focuses on the involvement of all members of the organisation to participate in improving processes, products, services, and the culture in which they work in. It is important that every team member realises how each individual and each activity affects, and in turn is affected by, others.

With the use of combined quality and management tools, TQM also aims to reduce losses brought about by wasteful practices, a common concern in most companies. Using the TQM strategy, business would also be able to identify the cause of a defect, thereby preventing it from entering the final product.

Deming’s 14 Points

At the core of the Total Quality Management concept and implementation is Deming’s 14 points, a set of guidelines on quality as conceptualised by W Edwards Deming, one of the pioneers of quality. Deming’s 14 points are as follows:

  1. Create constancy of purpose for improving products and services.
  2. Adopt the new philosophy.
  3. Cease dependence on inspection to achieve quality.
  4. End the practice of awarding business on price alone; instead, minimise total cost by working with a single supplier.
  5. Improve constantly and forever every process for planning, production and service.
  6. Institute training on the job.
  7. Adopt and institute leadership.
  8. Drive out fear.
  9. Break down barriers between staff areas.
  10. Eliminate slogans, exhortations and targets for the workforce.
  11. Eliminate numerical quotas for the workforce and numerical goals for management.
  12. Remove barriers that rob people of pride of workmanship, and eliminate the annual rating or merit system.
  13. Institute a vigorous program of education and self-improvement for everyone.
  14. Put everybody in the company to work accomplishing the transformation.

But if you were to reduce to bare bones the TQM philosophy from Deming’s 14 points, it would all come down to two simple goals:

  1. To make things right the first time; and
  2. To work for continuous improvement.

As with all other quality management process, the end goal is to be able to offer products and services that meet and even exceed customer’s expectations.

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

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