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GDPR – Your User Database

European parliament buildings

Many companies have a website and a customer database. It is now essential that those of us who rely on consent to hold this data have the express permission of the individual concerned.

Personally Identifiable Information (PII)  includes business email addresses as they identify specific individuals.

To meet our obligations we need to have a clear opt in policy on our website and a database that we can use to audit access. Can you do these things today? If not, please contact Insperitas so that we can help.

Article 32 of GDPR clearly indicates a need to prove security of processing.

 

Please see the excerpt below taken at Feb 23rd 2018 12.25 UTC from:

 

 

Article 32

Security of processing

1.   Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, the controller and the processor shall implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate:

(a)

the pseudonymisation and encryption of personal data;

(b)

the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;

(c)

the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;

(d)

a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.

2.   In assessing the appropriate level of security account shall be taken in particular of the risks that are presented by processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed.

3.   Adherence to an approved code of conduct as referred to in Article 40 or an approved certification mechanism as referred to in Article 42 may be used as an element by which to demonstrate compliance with the requirements set out in paragraph 1 of this Article.

4.   The controller and processor shall take steps to ensure that any natural person acting under the authority of the controller or the processor who has access to personal data does not process them except on instructions from the controller, unless he or she is required to do so by Union or Member State law.

 

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Have you Cloud Costs gone Stratospheric?

Well, to be honest, that’s not at all surprising. It’s an all too common scenario.

costs-graph

Why?

Because companies choose to use Cloud Services for the following reasons.
1. To urgently replace an existing backup solution.
2. Because some new urgent project demands a Cloud based solution.
3. To speedily boost or replace on premise servers.

All of these are time based demands and often they spawn a sudden launch into Cloud without serious consideration of how resources should be managed.

The common problems this creates include:

  • No tagging
  • No one knows why a server was built or if it can be deleted
  • Lack of clear ownership
  • Bills cannot be allocated properly
  • Disagreement as to who owns the shared Cloud services
  • Insecure solutions
  • Inefficient solutions
  • Inflexible designs

Insperitas can help you by:

Evaluating your whole Cloud infrastructure
Ensuring proper systems and processes to enforce best practices
(read more…)
Remediation of existing issues

But you don’t want or need to become dependent on Insperitas. And you probably wont be able to move immediately to meet best practices. A better solution might be for a consultant can come to your site (or work remotely) for 1  day a week to teach and guide your own employees to implement success.

Together let’s bring your costs back down to earth.

earth

Call me  (+44 7932 678578) or fill in your details on our contact page and start moving towards a more cost effective Cloud engagement.

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Will I Save Money?

I have been delivering business cards to local businesses offering Cloud IT Services. Often the unspoken question is

“Are you asking me for money?’

Followed quickly by:

“Can you save me money?’

Of course the answer is:  It depends!  I would like to shout out “YOU’RE MISSING THE POINT” but that’s probably not helpful. Instead I decided to write this blog  “Saving Money with The Cloud”.

coins

Most businesses I speak to face many pressures and the last thing on their mind is IT.  They are concerned about getting new business, managing staff, their premises costs, managing their current workload effectively… the list goes on.

So here are  FIVE reasons to think about your business and Cloud IT Solutions.

Continuity

Taking the most obvious reasons for spending on IT first, we need to talk about failure. What happens when it all goes wrong? You have data saved on your laptop or a local server and it breaks. Do you have a backup? Do you know how to access your backup? Will you be reliant on someone visiting your business to fix the problem? What will that cost?

We can level this up too… what happens when the company you rely on to supply your backup solution fails to deliver?  Do you want to wait until there is a disaster to find out if your solution is effective? Most companies seem to be happy to operate with this head in the sand approach. The truth is that backing up to Cloud is likely to be either a necessary extra expense (if you have no valuable backup solution today) or a cost saving (if your current backup solution is anywhere other than in The Cloud). So the answer here is  “Yes I can save you money.”

Growth

If you need to expand for any reason you should think Cloud. If you take on staff how will you communicate and share data? Do you need more space for more data?  The Cloud might be the cheapest option and will remove your need to spend cash on new hardware.

Money Management

Maybe this should be the number 1 reason to move to Cloud? With Cloud Services you pay for what you use. Its easy to budget. There are no unexpected bills. Any Cloud support costs should be 100% transparent with no surprises.

Security

The next thing we need to discuss is “Security”.  IT Security is such a massive topic, whole books are written about it and anything I write here could only gloss over one of the most important IT topics.   Suffice it to say that lots of small companies imagine that this is not an issue for them. Until you ask them what their competitors could do with their customer list… or what they could do with their competitors list of contacts. Security IS an issue for EVERYONE.

Some imagine that the least secure place for their data is on the cloud but I suggest you look at it this way: If I were to post your data where everyone can see it, such as on a billboard, what would we need to do with that data to keep it secure. Then answer is to encrypt it. Secrecy has come a long way since you were a child. We don’t just swap the letters around or write it in lemon juice. Very complex encryption techniques are available to all of us. By utilizing this technology we can choose precisely who should see what data whilst making it available easily.

We don’t just swap the letters around
or write it in lemon juice.

Improving your business

For some companies there is a clear benefit in improving their IT. Yes you can save money by introducing efficiency to your business. Good IT choices can drive better business decisions.  Even very small businesses should be tech-aware. Whether its digital marketing, a better website or sharing data with customers YOU can improve your business by making good IT choices.

For larger customers, adopting Cloud best practices can make you reach your market faster, change quicker and allow you to become more agile. Business growth is often driven by disrupting the status quo. Will you be disrupting or disrupted?

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Cloud Security

Data breaches occur all too often. Tighter controls are imminent and will help protect Personally Identifiable Information. However, every person or business that posts or stores anything on a Cloud Platform MUST take full responsibility for that data. This includes understanding the security of the Cloud Service.

This blog is NOT a full and complete list of all security measures that could be implemented but I would like to highlight some of the measures that should be considered.

Risk Awareness

We all have data that is pretty much of very little value to anyone else. That picture of your new born baby might have massive sentimental value to you but is probably not going to be worth much in the hands of a criminal. We also have data that we intend to be publicly available: Your CV, for example, or a company’s marketing brochure.

Some data that will be stored in the Cloud could cripple or destroy  a business if it were to be compromised. Every  piece of data has a value to you and a value to others. The costs of securing data should be carefully weighed against those values.

Your CSP

Whilst a very large company investing millions in a Cloud Service might well want to spend money determining how secure a CSP’s datacentres are, for the most of us that is overkill. Cloud Service Provider’s (CSP’s) base their business case on providing a secure solution. For the most part, we can safely assume that data stored with a major player in the Cloud will be significantly more secure than storing it ourselves. (Yes, even if you keep it under your pillow … or your dog’s pillow)

dog-pillow

They will however expect you to do your part!

ENCRYPTION

Hopefully an obvious one but if you don’t intend your data to be publicly available then you should definitely encrypt it! However you have a number of options.

  1. Encrypt on premise and manage your own keys.
  2. Encrypt in transit using your own or a CSP managed key.
  3. Encrypt at rest using your own or a CSP managed key.

For the vast majority of us, trusting the keys provided by the CSP will be sufficient. If you are storing government secrets you may wish to manage your own keys.

Account Security

From when your account is first set up you should be sure that your access to your account cannot be compromised. If you allow someone else access to your account everything else becomes irrelevant. In many companies though access needs to be shared. There are a number of tools we can use such as   Multi-Factor Authentication that we can utilize to help us implement Least Privilege Access.

Least Privilege Access

It is essential that any Cloud Strategy simplifies the process for devolving access and responsibility for data. Practices that have been important in traditional computing environments for many years are even more crucial as we move to the Cloud. This includes appointing a data owner for every bit of data and managing the full life cycle of that data. Least privilege, as the name suggests, means that we only give the minimum amount of access to data that a person needs to accomplish the specific task in hand. Some CSPs allow a person (an identity) to assume a number of roles which allow differing levels of access.

Firewall Controls

All major CSPs offer a competent firewall service that can be trusted. This should be utilized to implement Least Privileged Access to the public. This would indicate that where a service has a public front end, the data behind that service is held in a place that is fire-walled off from the front end.

CI / CD

The perfect security solution lies in making security part of your release process. The most forward thinking companies have a process of Continual Improvement and Continuous Deployment. One of my favourite lines is that Etsy ask their new programmers to deploy to live on day one. It is possible to completely automate the processes that secure our data and our infrastructure in the Cloud. This is complex but will be valuable when done well. One day all code will be released this way (I hope 😉 )

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Principle 4: Security Everywhere

Seriously – Every interaction with Cloud Services should be handled in a secure fashion

  • Data should be encrypted in transit and at rest.
  • All Cloud connections should be secure.
  • Work on the principle of Least Privilege Access.
  • Consider Security as part of your CI / CD Pipeline.
  • Don’t leave security to be the responsibility of a specialized team.
  • Consider each of the Cloud Security Alliance “Treacherous 12” threats

For more detail check out this blog.