GDPR: direct marketing vs natural/legal persons

Just a quick hint if you want to contain legal spam under GDPR.

Recital (14) “The protection afforded by this Regulation should apply to natural persons, whatever their nationality or place of residence, in relation to the processing of their personal data. This Regulation does not cover the processing of personal data which concerns legal persons and in particular undertakings established as legal persons, including the name and the form of the legal person and the contact details of the legal person. ”

Recital (26) “The principles of data protection should apply to any information concerning an identified or identifiable natural person. ”

In short, GDPR only applies to natural persons (people breathing), not to legal person (like, the thing with a VAT number or company registration nr).

So: Companies/legal persons can be legally contacted or spammed.

Conclusion: use a general mail address (like info@ or company@) in all non-personal company registrations and contact details, white pages, yellow pages, VAT or government paperwork…

Make sure your official company registration DOES NOT refer to a personal address.

And as owner or delegate, keep your mail address for your personal professional communication, eg signature with personally identifiable contact details (mail, phone, mobile, skype, IM, …).

Because then your personal mail account is related to an identified and identifiable natural person, and covered by GDPR, protected from direct marketing violations. Should be.

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Note-to-self: MVA Learning Path – Security for the Chief Security Officer (CSO)

From a LinkedIn connection (thx Jeff and congratz on the achievement) I received an interesting pointer to a set of courses on MVA, Microsoft Virtual Academy.

An MVA ‘learning path’ is a combination of learning courses.
Just recently MVA published the ‘Security for the Chief Security Officer (CSO)’ learning path.

Check it out at : https://mva.microsoft.com/learning-path/security-for-the-chief-security-officer-cso-21

It combines 6 courses (better make sure to access them from the learning path):

  1. How to Harden Your Enterprise in Today’s Threat Landscape
  2. Cybersecurity Reference Architecture
  3. Cloud Security from the Field

BTW: have a look on the ‘security’ based content on Microsoft Virtual Academy, you’ll be surprised how much you can (continue to) learn.

See: https://mva.microsoft.com/search/SearchResults.aspx#!q=security

That alphabet of Security starts with I of “Identity”

It’s an understatement to say security is moving fast, it’s changing very rapidly and the pressure to keep up with it, increases too.

From various angles, people in IT (as in Information Technology), are under fire to keep the infrastructure secure. Cloud is getting mature, new features pop up every week.
It’s almost a contradiction, but also legislation is catching up to close the holes regarding the protection of people’s security and privacy.

In many cases, the first reaction of customers, management, ITPros, Developers, DevOps,… is to look for the ultimate and ideal tool that will help to plug the security hole.

But if you only focus on the tooling, you’ll discover rather sooner than later, it is not sufficient to get your security watertight.
One of the basic reasons is that tools can’t be implemented properly without involving people and processes. I don’t need to explain the PPT (people-proces-technology) or PPP (people-proces-products) triade, right?

Lots of security management approaches and certifications handle this triad (ISO27001, CISSP, … I’ll cover that another time.

(credits: smart picture of ITGovernance.co.uk)

Rather than diving into the search for a tool, you better take a step back and consider first.

What’s the primary function of security?
Protecting an item that you want to keep (safe), right?

[The reason (“why”) for keeping it safe = the CIA triad, Confidentiality, Integrity and Availability]

When you think about the processes (“how”) to secure  an asset (anything that is worth securing), there are 3 basics actions you need to define

  • authorization: what you can do with the asset (the CRUD stuff, create/read/update/delete)
  • identification: who needs the authorization?
  • authentication: the method to proof your identity (using passwords, passes, cards, 2FA, MFA, …)

This is essentially the foundation of my credo “no security without identity”

Just by interpreting the basic components of security, you directly hit the “PROCESS” part of the PPT triad.
Now, here’s were most technical people get into trouble… not knowing how to put this in practice.

But let me ask you a simple question: within the normal, usual businesses or companies, where does the identity process typically start?
Yes, correct, HR (Human Resources)

The second question: can you name at least 2 typical high-level HR processes (for people).
Answer: something like “hire” and “fire”, or synonyms like “onboarding/off-boarding”, “termination”, “end-of-life” (but that sounds pretty dramatic when talking about people…).

These 2 events announce the beginning and the end of a lifecycle, the identity lifecycle.
And to make it complete, you also need to define the life-in-between as people change over time.

BTW, just a small side step here: this does not apply to humans only, but any other asset in your environment has pretty much the same cycle and it does not matter if it’s considered “IT” or not… computer, certificates, smart cards, disks, tapes, … but also cars, documents, …

This idea to consider the lifecycle as universal, is a great approach to explain the “identity lifecycle” to non-techies that get involved in the identity lifecycle processes.

This is the common ground you can use to talk to HR people, business managers, Executive level, …

Now, if you look on the internet for pictures on identity lifecycle management, you’re smashed with a lot of complex schemas…

google_identitylifecycle

Many of results are variations of 3 essential processes

hire-change-fire1

Depending on your background you might name them differently, like:

1AA.png

For the sake of simplicity, when teaching IDM and security workshops I usually only keep the keywords “Hire”, “Change” and “Fire”.
Short and easy to remember for most people.

For your understanding, the circle approach  would assume you start over again after the “Fire” block, but that’s not always the case. The cycle might stop.
So, the approach below is easier to visualize for most people.

Clockwise:

  1. Starting the cycle at (1),
  2. updating the identity at (2),
  3. exiting the cycle at (3)

hire-change-fire2

As I mentioned, earlier, virtually any IT or asset related proces is basically working like this.

Now, let’s take it a step further… How does identity management control security?

A first thing to consider is the typical length of the hire-change-fire modules.

How many tasks/steps does it usually take to complete each of the 3 steps?
Keep the asset in mind and keep it simple…

Typical actions in a hire process:

  • signing contract
  • getting an network/AD account
  • getting an email address
  • getting building access
  • IT stuff (laptop, …)

Pretty straight forward…
How much time would it take, in simple cases to start working?  Hours if not days.

What about the change process? For example, you get promotion to team lead or head of department…

  • hand over your tasks to peers
  • get ramped up on new job
  • in some cases, there is segregation of duties, getting rid of existing rights permissions
  •  getting access to new environment
  • changing communications channels (notifications to stakeholders of change)

In reality, this usually takes a few weeks.

And what are the typical things your consider for the “fire” process?

  • informing stakeholders/customers
  • disabling the account
  • changing password
  • lock account
  • removing access
  • extracting documentation form personal storage
  • move documents to manager or team
  • handing over ownership
  • knowledge transfer
  • data backup/archiving
  • cleaning the mailbox
  • deleting the account (* not always allowed for various reasons)
  • sending legal / tax documents
  • and more…

As you can understand, this entire termination process might take months… In many situations the termination process must be executed in different steps, like:

  • Disabling the account till x+30 days (for example, revert in case the person gets a renewal)
  • Removing access on x+60 days
  • Kill mailbox on X+90
  • Remove the account on X+1y (or even: never)

In some cases accounts must be kept for legal reasons or tracking/cybersecurity reasons…

The further you go in the lifecycle, you need to combine more tasks, and tasks or decisions get more complex.

Overall you can distinguish 2 properties of these processes: duration and complexity. Both go up.

complexity

procesduration

Now, when considering security, why is this important?
Instead of discussing the impact of successful processes, it’s easier to find out what happens if it fails.

WHAT IF… (the process fails)??

Let’s run through the cycle again….

What if the “Hire” process fails?

  • you can’t access the building
  • you do not get an account
  • you can’t logon
  • you can’t access documents

Basically, on your first (few) day(s) you can’t work. Sorry!
But what’s the balance for security: just great, because the risk is nearly 0, except for a bad start and a bit of reputation damage..
At the end: you can’t do any harm, essentially.

In case of the “change” process, a larger part of the tasks and operations will impact the security posture.

When your “change” process fails,  for example

  • you can still access your old documents
  • you get more access (eg collecting access of your old and new role)
  • you start collection sensitive accesses over time
  • managers don’t know
  • user profiles get copied from existing colleagues in the same team (no ‘reset’ or the permissions before the new ones are assigned)

So for this second piece of the circle, the impact might be significant, over time.

But for the “end-of-life” the story is completely different, a failing “deprovisioning” scenario has major impact on the business and IT process

  • accounts stay active
  • accounts not being disabled
  • access not removed
  • active accounts not detected
  • account with highly privileged access still active
  • accounts being deleted too soon
  • unauthorized users that have access to critical resources
  • hackers go undetected for a long time, using sleeping accounts
  • hardware not returned,
  • data stolen,
  • over-use of budgets to software licenses that are not revoked
  • access badges allow unauthorized access to your building and environment
  • failure to ‘deprovision’ old hard disks properly expose your company data to interested (unauthorized) parties…
  • …,

It’s clear that a failing deprovisioning/end-of-life process has major impact on your enterprise security.

risk.png

And hackers or disgruntled employees like that.

Of course you can imagine the benefits of an efficient and effective end-of-life process. It’s the opposite.

Does that require you implement an automated identity management?
No.

That’s where ISO27001 and eg GDPR surprises a lot of people.

Once you’ve got the basic processes in place you can discuss tooling, not the other way around.

questforsecurity

You have
no security without managing your identity.

you want
no identity without security.

Did I mention  that I’ll be presenting more of this fun stuff on TechoRama 2017.
Check it out here: http://sched.co/9M94

I’m very proud to present a session on the ABC of identity: Maximizing security with 10 simple processes.

 

June 2017: @TroyHunt is back in Belgium for his workshop ‘Hack Yourself First’. Wanna join?

ZIONSECURITY will be welcoming Troy Hunt again. The 1st and 2nd of June, he will be leading a ‘Hack Yourself First’ workshop where he will teach professionals how to break into their own applications. Find out the program and register here!

#update: download the flyer with program and details here: Flyer Troy Hunt June.

I have been there the last time, it was great fun, lots of interaction. And I certainly would recommend you to join.

What if you really wanna join, but your boss is not willing to sponsor? (While he SHOULD!).
Or any other silly reason you can’t attend?

Well, you know, if you can provide me a very good, strong, original and unique argument why you MUST be at this workshop, you might be lucky.

You know the channels to reach out to me and test your luck.

Some suggestion, send me a direct message:
1. Comment on this post,

2. mail me, tweet me (direct message!), F@ceBook me, LinkedIn …

Convince me and it could be you sitting at the first row.

Note-to-self: Normalization of deviance in security: how broken practices become standard [must read]

If you would search the internet you’ll quickly find the original quote… “Normalization of deviance in software: how broken practices become standard”

All credits go to the original post: http://danluu.com/wat/

And to honor the truth completely, the hint was posted by Joe Richards at http://blog.joeware.net/2016/01/04/5683/
Joe has highlighted some important remarks in his blog post. But there is more…

What reasons do people or companies have NOT to implement best practices or ‘forget’ to implement them.
What easily becomes accepted as normal, why not speak up if you think something is wrong…

Just replace the ‘software’ in the article and title by ‘security’ …

Simply must read!
[Or actually, simply must implement, every day.]

Note-to-self: EMET 5.5 released

Source: http://blogs.technet.com/b/srd/archive/2016/02/02/enhanced-mitigation-experience-toolkit-emet-version-5-5-is-now-available.aspx

Microsoft announced “the release of EMET 5.5, which includes the following new functionality and updates:

  • Windows 10 compatibility
  • Improved configuration of various mitigations via GPO
  • Improved writing of the mitigations to the registry, making it easier to leverage existing tools to manage EMET mitigations via GPO
  • EAF/EAF+ pseudo-mitigation performance improvements
  • Support for untrusted fonts mitigation in Windows 10″

Download is available at: https://www.microsoft.com/en-us/download/details.aspx?id=50766

More interesting information at:

EMET 5.5 FAQ: https://support.microsoft.com/en-us/kb/2458544

EMET at the Security TechCenter: https://technet.microsoft.com/en-us/security/jj653751