Brandeis GPS Blog

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Tag: BrandeisInfoSec

Technology Transformation for 2019

By Matthew Rosenquist

Digital technology continues to connect and enrich the lives of people all over the globe and is transforming the tools of everyday life, but there are risks accompanying the tremendous benefits. Entire markets are committed and reliant on digital tools. The entertainment, communications, socialization, and many others sectors are heavily intertwined with digital services and devices that society is readily consuming and embracing. More importantly, the normal downstream model for information has transformed into a bi-directional channel as individuals now represent a vast source of data, both in content as well as telemetry. These and many other factors align to accelerate our adoption and mold our expectations of how technology can make a better world.

This year’s Activate Tech & Media’s Outlook 2019 presentation provides a tremendous depth of insights in their slide deck (153 slides) with a great amount of supporting data. It highlights many of the growth sectors and emerging use-cases that will have profound impacts on our daily lives.

Transforming Tech IntelligenceWomen's face being scanned

We are moving from the first epoch of digitally connecting people, to the second epoch of making intelligent decisions through technology. Artificial Intelligence research is advancing and with it the infrastructure necessary to make it scalable across a multitude of applications. Solutions are just beginning to emerge and yet showing great promise to make sense and use the massive amounts of data being generated.

Overall, devices and services continue to evolve with more awareness and functionality. We are in the ramp of adding ‘smart’ to everything. Smart: cars, cities, homes, currency, cameras, social media, advertising, online-commerce, manufacturing, logistics, education, entertainment, government, weapons, etc. It will be the buzzword for 2019-2020.

Such transformation opens the door where tools can begin to anticipate and interweave with how people want to be helped. Better interaction, more services, and tailored use-cases will all fuel a richer experience and foster a deeper embrace into our lives. Technology will be indispensable.

Risks and OpportunitiesGears and numbers

Reliance in our everyday activities means we have the luxury of forgetting how to accomplish menial tasks. Who needs to remember phone numbers, read a map, operate a car, or know how to use a complex remote control. Soon, our technology will listen, guide, watch, autonomously operate, and anticipate our needs. Life will seem easier, but there will be exceptions.

All these smart use-cases will require massive data collection, aggregation, and processing which will drive a new computing infrastructure market. Such reliance, intimate knowledge, and automation will also create new risks.

The more we value and rely on something, the more indebted we are when it fails. We must never forget that technology is just a tool. It can be used for good or for malice. There will be threats, drawn to such value and opportunity, that will exploit our dependence and misuse these tools for their gain and to our detriment. At the point people are helpless without their intelligent devices, they become easy victims for attackers. As we have seen with data breaches over the past several years, when people are victimized, their outlook changes.

In this journey of innovation and usage, public sentiment is also changing across many different domains. The desire for Security, Privacy, and Safety (the hallmarks of Cybersecurity) continues to increase but may initially be in direct conflict for our desire to rapidly embrace new innovations. This creates tension. We all want new tech toys (it is okay to admit it)! Innovation can drive prosperity and more enjoyment in our lives. But there are trade offs. Having a device listen, record and analyze every word you say in your bedroom may be convenient in turning on the lights when you ask, but it may also inadvertently share all the personal activities going-on without your knowledge. A smart car effortlessly transporting you to work while you nap or surf the internet sounds downright dreamy but what if that same car is overtaken by a malicious attacker who wants to play out their Dukes of Hazzard fantasies. Not so much fun to think about.

In the end, we all want to embrace the wonderful benefits of new technology, but will demand the right levels of security, privacy, and safety.

Trust in TechnologyMan poking padlock

Unfortunately, trust in digital technology is only now becoming truly important. In the past, if our primary computing device (PC or phone) crashed, we breathed a small curse, rebooted and went on our way. We might have a dropped call or lost part of a work document, but not much more harm than that. That is all changing.

In the future, we will heavily rely on technology for transportation, healthcare, and critical infrastructure services. That autonomous car we expect not to crash, the implanted pacemaker or defibrillator we expect to keep us alive, or the clean water and electricity we expect to flow unhindered to our homes may be at risk of failure, causing unacceptable impacts. We want tech, but very soon people will realize they also need security, privacy, and safety to go along with it.

But how will that work? We don’t typically think of trust in terms of high granularity. We naturally generalize for such abstract thoughts. We don’t contemplate how trustworthy a tire, bumper, or airbag is, as those are too piecemeal, rather we trust the manufacturer of the car to do what is right for all the components that make up the vehicle we purchase. We want the final product, tied to a brand, to be trustworthy. For those companies that we trust, we tend to believe, whether correct or not, in all their products and services. This reinforces tremendous loyalty. The reverse is true as well. One misstep can become a reputational blight affecting sentiment across all a company’s offerings.

The saying “We earn trust in drips and lose it

in buckets” perfectly exemplifies the necessary

level of commitment.

Writing the word trustedTrust may become the new differentiator for companies that can deliver secure and safe products in a timely fashion. Those who are not trustworthy may quickly fall out of favor with consumers. Privacy is the first in many problems. Consumers, government regulators, and businesses are struggling to find a balance that must be struck between gathering data necessary for better experiences, but not too much that it becomes a detriment to the user. A difficult conundrum to overcome. Security and safety aspects will follow, where the potential risks grow even higher. The challenges are great, but so will the rewards for all those who succeed. I believe those companies which master these disciplines will earn long-term loyalty from their customers and enjoy a premium for their products.

2019 might be the first year where we witness this delineation as consumers may gravitate to more responsible companies and begin to shun those who have misplaced their trust. The big story for next year may in fact be how purchasing decisions for technology are changing, thus driving greater commitment to making products and services more security, private, and safe.

Interested in more insights, rants, industry news and experiences? Follow me on Steemit and LinkedIn for insights and what is going on in cybersecurity.

Read the article as originally published here.

Matthew Rosenquist is a member of the Brandeis GPS Information Security Leadership advisory board. He is a Cybersecurity Strategist for Intel Corp and benefits from 28 years in the field of security. He specializes in strategy, measuring value, and developing cost effective capabilities and organizations which deliver optimal levels of security. Matthew helped with the formation of the Intel Security Group, an industry leading organization bringing together security across hardware, firmware, software and services. An outspoken advocate of cybersecurity, he strives to advance the industry and his guidance can be heard at conferences, and found in whitepapers, articles, and blogs.

Faces of GPS is an occasional series that profiles Brandeis University Graduate Professional Studies students, faculty and staff. Find more Faces of GPS stories here.

When the Wrong Person Leads Cybersecurity

By Matthew Rosenquist

Succeeding at managing cybersecurity risks is tremendously difficult even for seasoned professionals. To make situations worse, poorly suited people are often chosen to lead security organizations, bringing about disastrous results. This has contributed to weaker risk postures for organizations and the rapid turnover in cybersecurity leadership.

I am unhappy to report that the industry has a pervasive problem that few want to discuss: a propensity to enlist inexperienced or unsuitable professionals to lead cybersecurity. It is time to change that caustic and enabling behavior by first recognizing the problem.

As an example, recently in the news, there was criticisms for someone appointed with the responsibility to lead the cybersecurity effort for the 2020 Olympics, but had never used a computer. How does someone who has never used a computer and has difficulty answering basic questions about USB drives, be tasked with building a cybersecurity program to protect the digital security, privacy, and safety for hundreds of thousands of people?

Downward Spirals

Sadly, I have seen similar situations play-out over and over again across academia, business, and government sectors. Far too often, poorly suited people are appointed such roles and it simply does not make sense. Let’s be clear, most are truly knowledgeable and accomplished in their primary field, but a transition to security is a significantly different domain. Engineering and product management executives focus mostly on static problems where there is a solution and desired end-state. Whereas in cybersecurity, we face a highly dynamic set of threat agents, people who are creative, intelligent, motivated, and dynamic, who will adapt to any solution. There is no permanent fix for cybersecurity as it is an ongoing competition to managing risks between defenders and attackers.

Human nature, overconfidence, and a lack of understanding the challenges begins to shape a counterproductive mindset. It is common for a professional from a different discipline, transplanted and put in charge of cybersecurity, to believe their prior expertise is equally applicable to the new challenges. Somehow, magically, they think they are as proficient and insightful at an adjacent domain as their previous profession. To those experienced in adversarial challenges who have seen this unfold, it is an affront to common sense. It is no surprise that such dangerous situations most often result in momentous failure.

For years, the turnover rate in cybersecurity leadership positions across the industry has been very high, with most Chief Information Security Officers (CISO) only lasting 2 to 4 years. When surveyed, CISO’s cite a lack of executive management support or insufficient budgets were the pervasive motivators. But that is only one side of the story as many CISO’s have been let go.

I have always been curious what C-suites and board had to say. When I ask company leaders about a change in cybersecurity leadership, I often hear that an outgoing CISO was ineffective, could not communicate risks well, and demanded significant budget increases every year yet the organization did not show a commensurate benefit. Events culminated when a severe incident occurred and then the C-suite or board chose to find a new security leader.

With the shortage of CISO’s in the industry, those displaced quickly find another company and continue their ‘training’. This musical-chairs routine does not serve the company or overall industry needs very well and simply transplants problems from one organization to another.

Masters of All

This mistake occurs regularly with technical personnel, probably as cybersecurity is generally characterized as a technology problem by the unacquainted. An accomplished engineer or architect is put in charge of security and now with ‘cybersecurity’ in front of their title they truly believe they are a risk expert. They are not. Being savvy in technology vulnerabilities and exploits is far different than understanding the massive breadth involved in managing risk. Most are unwilling to admit their shortsightedness in the breadth and depth of the challenges and their arrogance simply becomes a hinderance to seeking the needed help to be successful.

Ego can be such a major hindrance when the fear, of being perceived as not understanding a problem or knowing an answer, limits your actions. It is typical for a person in such a quandary to retreat back to familiar areas they know, resulting in defining the problem and solution only in the terms of technology. This ignores the behavioral, adversarial, and process aspects that are crucial to managing risk. With blinders on, they continue to push forward regardless, thus the car wreck begins.

Cybersecurity is more than just a ‘tech’ problem and will never be ‘solved’ with technology alone (two pervasive misconceptions from engineers first joining cybersecurity). They are likely doomed. I have seen this happen countless times and can spot it a mile away. It is like an automobile accident happening in slow motion with an overconfident driver continuing to push forward as metal bends and glass shatters.

Enlarged Version of Cybersecurity Domains

Part of the issue is that people, who are experts in one field, assume they understand the entire problem set in another adjacent but ambiguous field. It is not until they are in the new role, that they then experience the unforeseen challenges of a different world.

Imagine a hospital. Would you promote the engineer who developed a defibrillation tool to be an emergency room doctor? No. Although tools and technology play a crucial role in medicine, it is not the same as predicting, preventing, detecting, and responding to health risks for patients across their lifespan. The same applies in cybersecurity. Technology is the battlefield, not the war. Understanding the terrain is important, but must be combined with a keen assessment of your opponents, and the ability to operationally maneuver in advantageous ways.

This is true in other fields as well. Aeronautical engineers aren’t promoted to fighter pilots and textbook publishers aren’t necessarily good grade school principals, so why do organizations make the mistake of a taking a software engineer or business-line product manager and expect them to be successful in leading cybersecurity?

Two Scenarios: Vastly Different Chances for Success

Now, I did say this is a recipe for failure most of the time. There are some, very rare situations, where an insightful but inexperienced person takes a cybersecurity leadership role and succeeds. It is possible. I have only seen it a handful of times and in every case that person was realistic about their knowledge and checked their ego at the door.

Guaranteed Failure:

An engineer, project manager, or business executive is put in charge of cybersecurity. They are confused or intimidated by security practitioners in their organization and respond by immediately surrounding themselves with like-minded, yet similarly security inexperienced people. They add other engineers, marketing, and legal people to their core echelon, inadvertently creating a self-reinforcing ineffective group-think team. Congratulations, an inexperienced leader has just encircled themselves with a cushion of people who don’t have the knowledge to challenge poor directives or independently deliver sustainable success. If you wonder what conversations with them are like, take a look at the Dilbert cartoon, specifically the ‘manager’ character. That is pretty close. Funny from afar, but frustrating up close.

Ineffectual organizations tend to grow fast, spend a lot of money, make hollow promises, tell a story of difficult times that are turning around, but have no real strategic plan, prioritized goals, or clearly defined scope with organizational roles and responsibilities. They seek non-existent cure-all solutions, and their long-term stratagem is to hope nothing bad happens while they battle daily issues. Even worse, the proficient security personnel, that may have been part of the team, will likely leave such a caustic environment for a better employer. That breaks my heart when I see capable people who want to make a difference, driven away. When quality employees begin jumping-ship en-masse, it is a sure warning sign.

The easiest way to detect this situation early on, is to look at their metrics, or lack thereof. If a security organization operates without the benefit of tangible metrics, it is a likely sign they have not defined or are not tracking against goals, roles, objectives, and probably aren’t measuring or tracking risk. What they are doing is responding to issues, self-marketing, rapidly growing the team, consuming significant resources, slowing down the business, and the looking for people to blame when their ineffectiveness becomes apparent. These orgs don’t last. They implode. People quickly leave and executive oversight will soon look past the whitewash to cut budgets, headcount, and eventually replace the leaders.

Potential for Success:

An engineer, project manager, or business executive is put in charge of cybersecurity. They understand they are not a security expert, so they assemble a team who has experience and talent in protecting digital assets, understanding threats, can articulate risks, and are intimate with the technology in use. They build an organization structure that is comprised of operations, engineering, and risk intelligence teams. Then listen and learn. Great leaders bring in the best people and let them excel. They quickly get clarification on the business goals and expectations from executives and customers. They then identify prioritized objectives, define a scope, derive the supporting measurable goals, identify areas in need of immediate attention, and establish the measures & metrics necessary to track progress.

Governance issues are addressed and a strategic process capability is embedded to constantly improve the organizations risk management ability to predict, prevent, detect, and respond to threats. They establish both the tactical plans necessary for immediate survival and day-to-day management, but also define a long-term directional strategy that takes into account the ever-evolving threat landscape, technology changes, and shifting expectations for security, privacy, and safety.

Proficient security workers thrive in such organizations and rarely leave. With a strong plan and capable team in place, leaders can effectively communicate and advocate across the organization. If all of these elements land in place, with the proper support, even an inexperienced security leader can have a chance at success.

Unfortunately, it rarely happens.

Failure is Expensive

Cybersecurity is difficult. It becomes exponentially more problematic when someone who lacks the necessary mentality or skills comes in and makes it profoundly worse. Cleaning up an ineffective legacy security program is painful, expensive, and time consuming. Simultaneously, a poor risk posture opens the door to more attacks and greater impacts until a capable security program is instituted.

We must understand that cybersecurity, like many other highly specialized roles, requires a depth of insight and experience to lead. I will echo Sun Tzu’s “…do what is great while it is small” and recommend putting a good leader in place the first time to build an effective and sustainable cybersecurity organization.

Let’s all break the silence and openly discuss the cycle of poor cybersecurity leadership, for everyone’s benefit.

For more insights on the challenges and required strategic deliverables, read my post Cybersecurity Fails Without Strategy.

Interested in more insights, rants, industry news and experiences? Follow me on Steemit and LinkedIn for insights and what is going on in cybersecurity.

Read the article as originally published here.

Matthew Rosenquist is a member of the Brandeis GPS Information Security Leadership advisory board. He is a Cybersecurity Strategist for Intel Corp and benefits from 28 years in the field of security. He specializes in strategy, measuring value, and developing cost effective capabilities and organizations which deliver optimal levels of security. Matthew helped with the formation of the Intel Security Group, an industry leading organization bringing together security across hardware, firmware, software and services. An outspoken advocate of cybersecurity, he strives to advance the industry and his guidance can be heard at conferences, and found in whitepapers, articles, and blogs.

Faces of GPS is an occasional series that profiles Brandeis University Graduate Professional Studies students, faculty and staff. Find more Faces of GPS stories here.

Information Security Leadership at Brandeis GPS

With rising technology usage, there has been an inevitable rise in cybersecurity threats and an increased  demand for information security professionals. There is a growing responsibility to protect information as cybersecurity risks can be catastrophic for companies, customers, and careers.

With a Brandeis GPS Master’s in Information Security Leadership, you earn the confidence to attack any cybersecurity situation with leadership and technical savvy.

Brandeis University is ranked #35 among national universities by U.S. News and World Report, so you will have earned a master’s from one of the top universities in the country to lead you through any cybersecurity challenge, and to influence decisions for risk prevention.

Our cutting-edge, industry relevant, 100% online curriculum for professionals will build your leadership abilities and skills in leveraging technical know-how. Since you will learn alongside cybersecurity leaders from many industries in small seminar-style classes with no more than 12 students, your exposure to cybersecurity threats of all kinds will be significantly expanded.

The program will equip you to:

  • Develop a business case for investing in cybersecurity and risk management
  • Inform and influence senior executives to commit to obtaining and maintaining this investment
  • Oversee the planning, acquisition and evolution of secure infrastructures
  • Assess the impact of security policies and regulatory requirements on complex systems and organizational objectives

The 30-credit part-time, online program has six required courses and four electives.

The required courses are Foundations of Information Security, Information Security Management, Principles of Computer Incident Response and Investigation, Principles of Risk Management in Information Security, Information Security and Compliance, and Leading Security in Complex Organizations.

Options for electives include Identity Management and Access Control, Cloud Security, Secure Mobile Applications and Data, Network Security, and Managing Change and Innovation. View all courses offered in Information Security Leadership here.

Those applying to the Information Security Leadership program should have an undergraduate degree with work experience and/or coursework in introduction to networking, introduction to computer science and introduction to computer security.

We hope you enjoyed our cybersecurity series as part of National Cyber Awareness Month.

Brandeis GPS offers a Master’s of Science in Information Security Leadership. The part-time, fully online program prepares graduates for leadership roles in information security with a cutting-edge, industry relevant curriculum that builds leadership savvy and skill in leveraging technical know-how. For more information, contact gps@brandeis.edu, call 781-736-8787 or visit www.brandeis.edu/gps

How to recruit and manage the best cybersecurity candidates

By Joseph Dalessandro

October is National Cyber Awareness Month, and we’ll be spotlighting cybersecurity content on the blog all month long.

People management is one of the hardest and most rewarding experiences of one’s working life. With the advent of the “gig” economy, I am curious how we are faring in hiring in the cybersecurity space.

Cybersecurity hiring has been universally difficult for some time. It’s not that there is a lack of quality candidates. The issue is that we are missing each other. This is due in large part to the “traditional” hiring approach that many mangers adopt when they have open roles. They head to HR, or pick up the phone and call HR, and ask HR to find them candidates.

This happened to an acquaintance of mine not too long ago. He was looking for a junior information security analyst: a basic role that requires entry-level experience. He received more than 600 resumes, and realized that solid candidates were getting lost in a sea of unqualified applicants who know security is hot and want in.

If you are a manager in security, it’s time to change your hiring paradigm. To find a better applicant pool, cast your net more efficiently and do the following immediately:

  1. Use your network. Get into your network and spend some time talking to your peers.  Learn how to recruit and get out and start recruiting. If you have people in your network that would be perfect, call them. If they do not want to move, find out if they have contacts looking for work.  Ask your peers where they are finding hires. Share information on candidates, someone who is not a good team fit for you may be a good team fit for a peer of yours.
  2. Set the expectation up front in postings that you are different and you are serious. Include information in job postings that candidates will be tested on role skills during the first interview. Those without skills and basic security knowledge immediately fall out. This works well for junior roles. For more senior roles, make it known up front that for technicians they will need to demonstrate skills and for managers, they will need to discuss culture, training and retention.
  3. Make candidates provide a cover letter or cover email that explains how their experience aligns to the role, or provide them a platform to do this in a structured way. This will, once again, weed out those who do not align with the expectations of the role. If I need to describe in a table how my experience and skills relate directly to the role skills, I know that the manager is serious and is looking for the right candidate, and not just “looking” for candidates. Demand that candidates communicate, and get them together to be interviewed by other managers, from other non-IT departments, to interview them more objectively.
  4. Look for skills and education that shows the candidate is more than a CISSP. CISSP’s are everywhere, but show me a CISSP with a master’s degree who can write a business case or executive memo and I’ll scoop them up.

Once you build a team, you need to cultivate it. You want to develop your employees, and yes, eventually you want them to move on, to be successful in another department or another company. However, at the outset, for all your hires, you want to retain them, develop them and let them thrive.  This will also pay when you need to hire. Some of those employees will develop into their next role with you, and if you know those employees and what they want and where they want their career to go, you can help. Do a better job of knowing your current employees and how you can develop them for that next role. Look at your team for diversity, and for diversity of thought, and make sure you employ some contrarians. Diversity in thought is especially important in cybersecurity. A diverse team will be a high performing team. For roles where you have great staff but they are taking leave or need a different structure to their job, consider altering your approach and preconceptions about the traditional working day or the traditional working role rather than replacing those employees.

There are candidates for roles, but they need to be discovered. If you’re looking for a position, differentiate yourself from the masses. Why do I want to hire you? Stop memorizing port numbers and show me you know what P&L is and that you understand budgeting, or, develop your presentation skills, or, develop data analysis or data visualization skills. Or, better yet, get a master’s in security leadership and I’ll know you can handle the role.

Joseph (Joe) Dalessandro is the program chair of the Information Security Leadership program at Brandeis University Graduate Professional Studies, and the Head of Security & Technology Audit and Audit Data Analytics, Australian Unity.

Brandeis GPS offers a Master’s of Science in Information Security Leadership. The part-time, fully online program prepares graduates for leadership roles in information security with a cutting-edge, industry relevant curriculum that builds leadership savvy and skill in leveraging technical know-how. For more information, contact gps@brandeis.edu, call 781-736-8787 or visit www.brandeis.edu/gps

Image sources:

https://www.cyberdb.co/wp-content/uploads/2017/11/LinkedIn-cybersecurity.jpg

https://image-store.slidesharecdn.com/be4eaf1a-eea6-4b97-b36e-b62dfc8dcbae-original.jpeg

Protecting privacy: securing your organization from cyber-crime

Woman standing in front of teamAs technology continues to change the way we experience sectors of our daily life, it’s not surprising that cyber-security risk and vulnerabilities are also on the rise. From popular fitness tracking apps to university data systems, there have been dozens of high profile security breaches in the first half of 2018 alone.

According to Trustwave, $600 billion is lost to cyber-crime globally every year. In 2016, 53% percent of IT security professionals felt more pressured to secure their organizations than in 2015, demonstrating a growing need for information security management of businesses, government agencies, and other enterprises. Now more than ever, companies need leaders who can establish teams, processes and policies to secure their data.

Brandeis GPS offers a course in Information Security Management that explores security concepts, infrastructures, standards, protocols, and best practices. that are necessary for today’s information security professionals. The course focuses on management and governance, assessing and communicating risk, law (compliance) and ethics, policies, planning (strategy and operations), contingency planning (disaster recovery and incident response), and testing. These concepts are applied and discussed in the context of common enterprise scenarios.

Throughout the course, students acquire an understanding of the fundamentals of information assurance solutions and learn to establish a comprehensive security strategy and execution plan. By the end of the session, students will be able to apply the concepts, principles, and vocabulary of IT and information security within the context of their own organizations.

Information Security Management is a fully online, 10-week course that will next run in October 2018.

At Brandeis GPS, you can take up to two courses before enrolling in one of our 12 online Master’s degree programs. If you’re interested in exploring the MS in Information Security Leadership, or would like to learn more about information security management as part of your own professional development, contact the  GPS office for more information or to request a syllabus: 781-736-8787, gps@brandeis.edu, or submit your information.

How has GDPR changed the world?

On May 25, 2018, the General Data Protection Regulation (GDPR) went into effect to set a new standard for the protection of European individual’s rights over their personal identity data.

If you are in Technology or Security in the US, you are aware of GDPR, and, unless you have been living under a rock, you have assessed whether or not your organization needs to comply. Now, just because this regulation is new, that is to say, just because no one has gone to jail or received a hefty fine does not mean that regulators do not know what they are doing or are lax in their enforcement.

So, how has GDPR changed the world? This new regulation replaces the outdated 1995 EU data regulation, Directive 95/46/EC, which, while sound, was written before wide-scale adoption of the Internet. Simply put, the GDPR is a directive to place the control of a person’s information in the hands of the individual. It is specific to EU citizens and applies to all those classified as either ‘controllers’ or ‘processors’ of the personal information for EU citizens. This means, yes, the GDPR does apply to you if you are a US business, without a physical presence located in the EU, but you do offer goods/services to citizens of the EU.

One of the best sources for all things GDPR is the UK Information Commissioner’s Office (ICO). The rights afforded individuals under GDPR are comprehensive, such as the right to be erased, the right to restrict data processing, or to stop direct marketing. The US does not have a comparable directive, so you will need to involve your legal team to determine your need to comply. The bottom line is that the regulation is all about accountability, transparency, control and reporting.

What do you do if you’re not sure if your organization needs to comply? If you think you need to, it will take some time, so start immediately. You want to acknowledge your requirements and get a plan in place to move toward compliance. How do you do that? You can conduct a self-assessment with an ICO tool, which can be found here. The tool will walk you through and provide a score by topic area. If you missed the deadline, the most important thing you can do is act. Get your legal team together and go.

Also, put protection in place to limit your interaction with EU citizens. This can be simple and straightforward. I found an example in the form of the LA Times website.

Screenshot of VPNIP Address Information Using a VPN

I used a Virtual Private Network (VPN) to appear to be an Internet user coming to the LA Times website from London.  When I arrived at the website, I was instructed that I would be unable to view the web content.

LA Times Unavailable Message

I cannot speak to the LA Times compliance plans for GDPR nor have I contacted them, but they have put measures in place to detect the IP address of viewers and filter those from the EU.  Obviously, LA Times needs a more comprehensive solution so as not to miss a market of approximately 518 million people, but this is a great short-term solution in that it protects LA Times and  EU citizens’ rights to control the potential collection and processing of their personal data.

So, what have the results been? The online news site DataBreachToday listed the UK privacy regulator as seeing a rise in breach reporting in June of 1,750 instances, up from just 400 reported in April.  While this sounds high, a more than 400% rise in one month is an indication of compliance management.  This is the EU; this is principles-based regulation which is focused on outcomes.  Saying you do not comply, measuring, and monitoring your progress towards compliance are important.  It means you are taking accountable steps to control and monitor how you don’t comply.

US organizations may not comply, but you need to know if you must and then start working toward it.  You had two years to comply.  Take the first step and the rest will follow.

Joseph (Joe) Dalessandro is the program chair of the Information Security Leadership program at Brandeis University Graduate Professional Studies, and the Head of Security & Technology Audit and Audit Data Analytics, Australian Unity.

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