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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How to carry out an Operational Review

A mobile workforce management software is key to managing an efficient field workforce.? Managing a staff of people can be tricky in any industry. Try keeping track of employees on shifting jobsites, many whom are paid hourly or temporary workers. The added pressure of ensuring the right workers get to the right sites at the right times, but they also need to track hours, parts used, vehicles and equipment assets.

In a previous post, we defined what is an operational review and why they play a key process in the continual evolution of successful businesses.?

Operational reviews allow the organization members to evaluate their performance, according to the procedures, resources properly, timescales and budgets.

Denizon – Operational Reviews Defined

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In this post, we’ll take a closer look at how to implement an operational review and the steps typically undertaken to help you and your organisation to implement an operational review.

What the steps in a Operational Review Process

There are typically six steps in an operational review that range from preparatory work conducting interviews and collecting documents to the presentation of the final written report.

An audit should be customized to meet a organisatons specific needs, so standard steps can and should only serve as a guideline.? Management and internal and external auditors should adjust the process to address the company’s particular goals and objectives.

Initial Management Meeting

Understanding the problem is the first crucial step of an operational review. This is one of major areas of discussions when the audit team meets with the management, and department heads will be asked to identify any specific areas of concern. Once the problem is identified, it would be easier to come up with workable solutions.

Conduct Interviews

The next step in the evaluation is carried out with experienced teams doing interviews and keeping close observation. Each team essentially watches how employees carry out their responsibilities. This is considered a key part of the process.

When doing the interview, it is also vital that the observing team gains the employees? trust and confidence. Likewise, the staff must be assured that whatever transpires between the team and the employee will be kept confidential. Management must therefore guarantee anonymity to anyone who offers critical information, lest employees withhold vital information and render the data gathered inaccurate.

Systems Review

Employees and management practices will be reviewed by the assessing team according to the standard policies and guidelines of the company. The effectiveness of the controls in place as well as their appropriateness to the current operating conditions will also be evaluated.

Reporting

A documentation of the data gathered and the assessment of the evaluating team, will be submitted to the management after the review process. Flow charts and written narratives of departmental activities are usually part of this report. This is also where observations and recommendations of the team will be presented to the department heads concerned.

Review Results

While the operational review is being conducted, it is important to take into account the vital factors that affect the company: the people, processes, procedures, and strategies. These four factors can determine the company?s progress in the future.

Key Areas of focus in operation reviews

At a minimum an operational review should include the following key ares of assessment

Management Control

Responsibilities, authority, and the scope in which an employee has the freedom to act must be clearly defined and documented. A complete and specific job description for instance, would give the employee a clear perspective on how he acts and functions within the company.

Boundaries should be set not only to benefit the employer but more so the employee as well.

Moral and Ethical Guidelines

Moral and ethical guidelines are just as important to ensure for a smoother employer?employee relationship. Otherwise, personal issues such as work ethics, work attitude and personal values may post problems in the long run if such guidelines are not drawn properly before relationships are established.

Processes and procedures

Evaluating processes is only beneficial if the company itself updates its processes and procedural manuals regularly, or at least when needed. Such protocols may need revision and some steps may be obsolete already. Improving a company?s processes and procedures doesn’t always entail cost. In fact, improvised procedures may even be cost-effective and could make the processes more manageable.

Communication and reporting standards

Gaps in communication could result in serious lapses in internal controls, putting the company and/or its assets at risk. This is where the importance of timely and clear communication comes in. Likewise, reports must be useful, and the flow of information and how it is processed must keep pace with the company?s growth.

Information technology (IT) and security controls can also be included under the communication clause. Proper IT security policies must be in place, state-of-the-art protection techniques employed, and everything be documented, periodically updated, and continually monitored.

Strategic planning and tactics

No company can ever be complete without its strategies. It would unwise for any organization to proceed without first knowing where it stands and what direction it wants to take. Strategic planning draws such a map. It must be aligned to the mission and vision of the company, and should also coincide with the organizational goals set. Strategic planning deals with these three key questions:

  • What do we do now
  • Whom do we do it for?
  • How can we overcome competition

Without clear strategic direction, expectations would likely differ between ownership and management.

Contingency planning, testing and recovery

Contingency plans must be up-to-date, and are essential to the organization. If one course of action fails, the company should have plan B, C and so on. In addition, an organization should be prepared to respond to interference’s.

This includes establishing a formal process to review transactions processing during both disruption and recovery.

Presentation of Report

Based on your objectives and our findings, we will develop detailed recommendations to improve your company?s performance and productivity. Our written report will include a list of both short-term and long-term projected improvements and courses of action, to be mutually agreed upon by both parties.

To ensure the achievement of the improvements we outlined, our team will also assist in the implementation of these modifications.

The plan has three levels of recommendations: one for executives, another for management, and a third one for staff.

The executive summary concentrates on your company?s strengths, weaknesses, opportunities and threats to its entirety. It includes recommendations for any needed changes in policy or governance.

The management plan is based on employee feedback and includes areas of immediate improvement as well as identification of potential problem areas. Concerns from the bottom level management can now be forwarded to the top level management in formal writing. Better working relationships may evolve from this, thereby setting the work environment for a higher productivity ratio.

Lastly, the staff report deals with topics like charting the hierarchy of the organization, and discussing in detail specific control objectives that are critical to the company?s mission. Part of our goal is to encourage personnel to pay close attentions to such changes, if any, as these efforts are essential if they want to bring about both organizational and personal success.

If you would like to further discuss how our operational review services can benefit your company, please feel free to contact us at your convenience to schedule an initial consultation. We?ll be more than happy to assist you.

More Operational Review Blogs


Carrying out an Operational Review


Operational Reviews


Operational Efficiency Initiatives


Operational Review Defined

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2015 ESOS Guidelines Chapter 2 – Deadlines and Status Changes

The ESOS process is deadline driven and meeting key dates is a non-negotiable. The penalties for not complying / providing false or misleading information are ?50,000 each. Simply not maintaining adequate records could cost you ?5,000. The carrot on the end of the stick is the financial benefits you stand to gain.

Qualifying for inclusion under the ESOS umbrella depends on the status of your company in terms of employee numbers, turnover and balance sheet on 31 December 2014. Regardless of whether you meet the 2014 threshold or not, you must reconsider your situation on 31 December 2018, 2022 and 2026.

Compliance Period Qualification Date Compliance Period Compliance Date
1 31 December 2014 From 17 July 2014* to 5 December 2015 5 December 2015
2 31 December 2018 From 6 December 2015 to 5 December 2019 5 December 2019
3 31 December 2022 From 6 December 2019 to 5 December 2023 5 December 2023
4 31 December 2026 From 6 December 2023 to 5 December 2027 5 December 2027

Notes:

1. The first compliance period begins on the date the regulations became effective

2. Energy audits from 6 December 2011 onward may go towards the first compliance report

Changes in Organisation Status

If your organisation status changes after a qualification date when you met compliance thresholds, you are still bound to complete your ESOS assessment for that compliance period. This is regardless of any change in size or structure. Your qualification status then remains in force until the next qualification date when you must reconsider it.

Choosing Routes for ESOS Compliance

Along the introduction of Energy Savings Opportunity Scheme in UK is the quick emergence of various companies that offer ESOS compliant services. While some energy audit providers can help, qualified businesses should understand what their compliance options are, how these routes work and learn both the pros and cons in order to carefully take their pick.

Independent ISO 50001 Certification

ISO 50001 comprises the integration and application of processes geared to motivate energy saving and overall improvement. Simply stated, it is a framework that drives the organisation’s governance to realise energy saving strategies by allocating resources and participating in energy management. The good thing about ISO 50001 is that it includes an energy review that documents ideas and opportunities to save more energy.

However, ISO 50001 does not obligate organisations to cover 90% of their overall energy consumption. In case of partial coverage, the company needs to undergo additional energy assessments to evaluate all the significant energy consumption areas.

In order for an ISO 50001 certification to be valid, it must be certified by the United Kingdom Accreditation Service (UKAS), by an accreditation body which is a member of the International Accreditation Forum, or by a body accredited by another EU member state?s national accreditation body.

Display Energy Certificates and Green Deal Assessments

These two kinds of energy assessment reports can also contribute to ESOS compliance. Both of them are carried out by qualified lead assessors and valid for 10 years. However, they are only based on the building structures and services. They do not cover the overall significant areas in energy consumption. Since these reports are valid for 10 years, they would be used for two ESOS reporting periods. Thus, they would not be as current as the ISO 50001 certification. Aside from that, the assessments are purely based on energy efficiency and anyone can qualify to use the software that produce the certifications after taking the accreditation course.

Energy Audits

A successful energy audit leads to better understanding of the company?s energy consumption, identify alternatives, determine cost-effective energy saving opportunities and stimulate energy efficiency. Energy audits are beneficial to the organisation. What makes it complex is that the organisation applying it, needs to clearly define the scope and type of energy audit to use in order to comply with ESOS. Furthermore, the organisation also has to identify the teams that would be competent enough to do the audit work for the building, transport and industrial area, respectively.

Each route is not formed equal. Thus, organisations have the option to either choose one or combine the routes and meet their company needs. The options mentioned are different approaches to ESOS and the core value is to grab the opportunity towards acquiring more savings through efficient energy system.

How Ecovaro Can Help

Ecovaro is passionate about making a difference. We are knowledgeable when it comes to ESOS legislation and regulation, ISO 50001 energy management system, DECs and Green Deal Assessments. More than that, we recognise the great impact of efficient management system to your organisation. And with this, we provide an enthusiastic team of software engineers and expert project managers to offer you our professional help at reasonable price. Ecovaro comes to you fully equipped with services tailored to your organisation’s energy management needs.

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