by Bharat Mistry
One of the most important and challenging parts of the CISO’s role is to communicate complex concepts into a language the board understands. Without this crucial skill, it might be difficult to secure much-needed top level buy-in for major projects and cultural change. That is, until now. With the advent of the GDPR, data protection, privacy and cyber security became a board-level issue. This week, things kicked up a notch further, with BA and Marriott fined over £282m (€313m) collectively by the UK regulator.
If they have been stonewalled in the past, now is the time for CISOs to make the case more urgently than ever for extra investment to mitigate the clear business risk of regulatory fines.
war is over
The Information Commissioner’s Office (ICO) was instrumental in helping to draw up the GDPR, and it was acting as the lead supervisory authority on behalf of other EU Member State data protection authorities when it issued the fines this week. Marriott International was handed a penalty of just over £99m (€110) while British Airways was given a fine of over £183m (€204m). This amounts to 1.5% of its worldwide turnover in 2017, and significantly less than the possible maximum 4%. Both will appeal the size of the penalties, but one thing is clear: no board room anywhere in the world can ignore the potential impact of GDPR on their bottom line and corporate reputation.
In the case of Marriott, the firm’s woes were inherited from Starwood hotels group it acquired in 2016. But that’s no excuse, the ICO said. The hotel giant should have undertaken more effective due diligence and put in place “proper accountability measures to assess not only what personal data has been acquired, but also how it is protected”. It’s also a US firm, but 30m of the 339m guest records exposed in the massive multi-year breach belonged to EU citizens. The reach of GDPR is global.
For BA, it was a 2018 breach of 500,000 customer records, including card numbers, travel booking details and names and addresses. Attackers compromised its website with notorious digital skimming code known as Magecart, in what appears to have been a highly targeted attack in which they did their best to stay hidden. Still, the ICO said it could and should have done better. The bottom line, said information commissioner Elizabeth Denham, is this: “When you are entrusted with personal data you must look after it.” This also sends a stark message that if you use 3rd-parties for any type of service or outsource then you should take adequate steps to ensure the supply chain is secure as you are still ultimately responsible and will be fined should there be a breach.
Time to focus on security
There’s no silver bullet when it comes to GDPR compliance – just as there is no guaranteed way to remain 100% breach free. All organisations can do is to prove they have the best interests of their customers at heart, by following industry best practices and proven frameworks. As part of these best practices, we’d encourage a defence-in-depth approach to security combining a range of cross-generational threat protection techniques at server, endpoint and network layers.
Here are a few ideas:
- Conduct a thorough data audit to work out what you process, where it flows and how high-risk it is
- Apply appropriate security controls to that data. Endpoint, network, server and web/email gateway protection should ideally come from a single reputable provider. Trend Micro’s XGen approach offers a combination of connected threat defence techniques at each layer
- Apply strong encryption to high-risk data at rest and in transit
- Restrict access controls and apply multi-factor authentication (MFA)
- Implement continuous networking monitoring for threats
- Improve end-user education, with phishing simulation tools like Phish Insight
- Keep all devices and software up to date
- Follow best practice standards and frameworks, such as Cyber Essentials, BS 10012:2017 personal information management system (PIMS) and ISO 27001:2013 information security management system (ISMS)
- Audit your supply chain to mitigate third-party risk and update contracts reflect the new GDPR regime
Most importantly, European firms must remember that compliance is not a destination that can be forgotten about once you reach it. Instead, it’s an ongoing journey that will require constant attention, and investment, as technology environments, the threat landscape, and regulatory requirements change.