Below is a short overview of the #Hexnode webinar, presented 2022-04-07 about data compliance.
The webinar recording is published at the Hexnode website (and embedded below). And the PDF version of the slide deck is published in full color and B/W print version on Slideshare, see links below.
Company and user data, and personal data is an important target and leverage in cybercrime lik
Phishing
Ransomware
not only encryption
data leak extortion
Reconnaissance & Hacking
Data breaches
Biometric data
Digital & Economical war
…
Now the question is… How do YOU get in control?
You can’t simply lock up your data… because data needs to flow. (You want to use it…)
Data management essentials to get grip
Ask yourself: how much €$ can you spend to protect your data? To answer that question, you’ll need to get grip of some basic data management principles, in relation to security:
You can only protect what you know you have
Without an owner there is no protection
Nothing is stable, everything has a lifecycle
Data lifecycle
Data lifecycle
The start of the cycle is mostly
short,
easy to manage,
low security risk. (if the creation fails… you have no data to keep under control)
The end of the cycle is mostly
long, (there are various reasons why you need to keep the data for a while, eg in archive before you dispose of it..)
difficult to manage (if the process fails, it’s difficult to track or keep under control)
high security risk. (risk of losing ownership, risk of leakages, …)
What is risk?
Assets have
Vulnerabilities (weaknesses/properties)
that can be exploited by
Threats (activities)
with impact ($$ cost).
You need to balance the protection against the impact. You don’t want to over-spend or under-protect.
Your boss (or insurance, of CFO ) needs a budget, spreading cost over a year, or 2..3..4..5.
[Risk management is calculating impact over the rate of occurrence/frequency…]
How to get started
Know the external context
International regulations (GDPR, …)
National regulations (SOC, …)
Sector regulations (PCI-DSS, ..)
Contractual obligations
Enterprise vs PII/personal data requirements
Know the internal context
Know your business (what)
Know your organization (organigram)
Make an inventory of processes and interfaces
Assign business ownership
For each process
For each asset
Know the processes
Know the data flow
Know your sources (IN)
Know the data processing
Know your receivers (OUT)
Know the data in the processes
Categorize your data – data types
Enterprise data
PII / Personal data (GDPR !)
Other ?
Categorization (define data classes)
Sensitivity = linked to business impact
Ask the owner : “What if data is …”
unavailable,
changed,
destroyed,
leaked,
accessed unauthorized, illegally, unlawfully,
…
Categorize your data sensitivity
Enterprise data, for example
Unclassified, Official, Restricted, Confidential, Secret, Top Secret (NATO)
Public, Company internal, Confidential, Strictly confidential
TLP RED, TLP Amber, TLB Green, TLP White (public)
Classification (apply the labels)
Responsibility of owner
Label all data
Label containers if you can’t label the data
Folder or File share
Database
mailbox
…
Mind the lifecycle
Get started
Keep going
Start over again
Think about security when
creating new processes
changing processes
removing processes
recheck on a regular schedule (even when nothing changes)
Set a default label for archived data that doesn’t change
DO NOT set “public” as default
Think about the support processes
Incident management (ISO 27035 & NIST)
Data breach management (GDPR & other …)
Business continuity (ISO22301)
Disaster recovery
Questions
How to identify regulations you should follow?
know and analyse the services you’re offering,
where is your data stored?
what kind of data you have (enterprise data, personal data, financial, …)
identify the local, national, regional, international regulations of sector legislations that apply to your business (check partners/competition, sector representatives, …)
…
Is there difference in regulation for small or large business?
very limited impact of size of company…
very likely some impact on financial and tax reporting,
some legislation only apply in large scale operations (eg GDPR only requires a DPO for certain type of operations, …)
Just in case you get into SOC2 and want to know how to map it to existing information security implementation, whatever it may be, GDPR, ISO27001, NIST, … check this page
“ SOC reports refer to an audit of internal controls to ensure data security, minimal waste, and shareholder confidence; SOX relates to government-issued record keeping and financial information disclosure standards law. In other words, one is about keeping information safe, and the other is about keeping corporations in check.“
The main title of the (ISC)² article on CCSP vs CCAK is “CCSP Certification vs. CCAK Certificate: What Are the Distinctions?”
That’s exactly what you get. A list of technical differentiators between CCSP and CCAK, but according to (ISC)².
But if you hope to get an actual answer to what the right certification is, for you… they forget to ask …you.
What do you think would be the conclusion, if you ask that question to either one of the contestants while you compare 2 certifications? Of course each party will simply draw the conclusion that their own certification is the best choice.
To answer the most important question, the dilemma CCSP or CCAK, is simple: do you need technical or audit skills for cloud security?
The answer
In essence, the answer is simple:
if you need cloud audit skills, dive in to the Cloud Security Alliance (CSA) and ISACA Certificate CCAK.
if you want to have architect level technical cloud expertise and knowledge, choose CCSP
if you want cloud security knowledge, in basic or advanced hands-on, there are other choices to start with (more about it below)
So, if you ask the question “what is the right certification for you”, you immediately know that there is no right answer, but there are many options. Options for a multi level expertise roadmap in cloud security, based on your current skills and your future goals.
If you like a tough challenge: why not jump into the CCAK or CCSP, CCSP or CCAK, whatever, right away.
But if you would like to boost your chance of success… take a deep breath and better plan smartly.
And don’t start with CCSP/CCAK, but prepare your track towards CCSP/CCAK first.
First some background to plan your roadmap
Setting expectations
Just to set expectations, this article only focuses on the personal education and certification options, offered by (ISC)², ISACA and CSA. Including other education provider would lead us too far. There are way more other (cyber)security certifications available, but we focus on the cloud security track, which limits the options…
Feel free to comment with other options for cloud security training. I’ll update the article where relevant.
CSA CCSK
The Cloud Security Alliance launched the CCSK in 2011. And as they explained here, “the CCSK was quite literally the industry’s first examination of cloud security knowledge when it was released back in 2011. “
The CCSK is an easy entry, high level introduction to Cloud Security, and it doesn’t require you to have deep technical cloud security expertise.
But it still is a nice baseline for the cloud security essential knowledge.
You need at least five years of cumulative, paid work experience
CCSP is pretty much the same level of difficulty as CISSP, but has focus on cloud security.
The CCSP was launched in 2015, as a cooperation between (ISC)² and CSA. (see CSA press release here), a couple years after the CCSK launch in 2011. The CCSP is the bigger brother of the CCSK, more advanced, and as CSA rightfully mentions in there CCSK-CCSP comparison blog, the CCSP is on the level of CISSP with a major cloud flavor.
That’s where the dummy math description comes from…
CCAK (Certificate of Cloud Auditing Knowledge) is cohosted by ISACA and CSA. And then you immediately know the approach is different than the approach of (ISC)².
As ISACA mentions on their product page: “The Industry’s First Global Cloud Auditing Credential”.
CISSP
For completeness, I mentioned the CISSP ( Certified Information Systems Security Professional). I don’t think it needs a lot of explanation, it’s pretty much the reference standard for IT Systems security. (ISC)² references it as “The World’s Premier Cybersecurity Certification”.
It’s a pretty heavy exam, and it does require at least 5 years professional security experience. This is not an entry level exam.
Due to the experience requirements, CISSP might be a tough credential to start with, although you can pass the exam, and continue to build your experience to grab the CISSP title…
If you want the plan your credentials the smart way, or you’re fresh in cyber-, information or IT-security, you better start with SSCP.
You can buy a double-try access ticket for the CCSK online exam (60 questions, 90 minutes), so if you would fail the first attempt, study again and retry the exam.
Then plan your track: only technical (no interest for audit) or audit, or both
Only technical
If you focus on technical expertise in cloud security, CCSP is a reference standard (at least, on of them…) .
As mentioned: CCSP = CISSP + CCSK.
So the track is clear
After passing the CCSK exam,
Take the CISSP exam
then take the CCSP
This is the easier route if you already have 5yr+ experience. It’s not the cheapest route, as you pass the CISSP first, but it’s worth the effort. (you only need to pay 1 yearly fee at (ISC)², so after 1 certification, … no extra cost in yearly membership fee) For junior, less experienced, security engineers, start with SSCP before jumping into CISSP, and then CCSP.
Audit
When you target IT security audits, you need to take a different route depending your background. Having the CCSP/CISSP background is extremely useful to boost your career in audit.
But for the CCAK, the core audit baseline is CISA.
Keep in mind, similar to CISSP and CCSP, CISA has the same requirements regards professional experience, 5 years.
But if you’re a ISACA CISA, you can add CCSK to the track and land on the CCAK.
Both?
Then it’s obvious, first tech, then audit, meaning a smart combination of
CCSK
(SSCP > ) CISSP
CCSP
CISA (or alternative)
CCAK
Alternative routes
ISO27001 Implementer & Auditor
And alternative route to the auditing experience is ISO27001 auditing, but you’ll need some implementation experience before you can audit.
CISM
Within the ISACA portfolio, the CISM (Certified Information Security Manager), covers the same areas as most ISO27001 (lead) implementer courses.
Which can be helpful to ramp up for the CISA audit part, to gain some hands-on in IT & Infosec governance.
Visualizing your cloud security education roadmap
Lots of blah for a simple choice?
Allow me to visualize the options…
The difference between “certification” and “certificate”, does it really matter?
In it’s blog post (ISC)² tries to put CCSP above CCAK by saying “CCSP is a certification; CCAK is a certificate.”
And they continue “A certification recognizes a candidate’s knowledge, skills, and abilities, typically framed by a job role, while a certificate’s scope is narrower and only documents training course completion. A certification often requires continuing professional education (CPE) to stay in front of trends, while a certificate’s body of knowledge does not evolve over time or require CPE credits to maintain.“
And their explanation is at least flawed and cutting corners to benefit CCSP.
There are many explanations and interpretations of “certification”, depending the context. But in essence, “certification” is a process and a certificate is a document (the result).
When you certify for “CCSP” at (ISC)², you need to comply with the CCSP condition and then get a document, your CCSP certificate. Idem for CCAK, you need to comply with their conditions.
Both the certification process for CCSP as the process for the CCAK are used by other similar education providers.
Eg, PECB, ISACA, EC-COUNCIL, … and others require to pay a yearly fee, keep CPE/CPD (continous professional education or development). Some yearly fees are cheaper as others.
Like CSA, Microsoft and others ask for a 1 time exam fee, and then update the exam on longer term, not yearly, and do not require a yearly maintenance fee.
It’s a choice of the certificate owner, how the evaluation and exams are done.
Some of them comply to the ISO17024, and education standard. There are huge benefits to comply (like increased credibility, compatibility with other certifications, …). But it’s not mandatory.
(ISC)² uses an exam, with experience requirement and continuous education once you pass the exam, but you do not need to pass the exam again, unless it’s upgraded to a new build or major version.
But CSA does exactly the same, for example when CCSK was upgraded from v3 to v4, you needed to pass the exam again.
Not on a yearly basis, but the program is updated, the exam is updated… on a regular basis, without yearly fee.
It’s rather a (small) financial effort, not of significance for most companies paying the bill. (Although as an individual, the cost of certification can become a serious burden…)
And it’s certainly not relevant when choosing between CCSP and CCAK. CCAK is cheaper, as referenced in the (ISC)² comparison chart.
References
(ISC)²: CCSP Certification vs. CCAK Certificate: What Are the Distinctions?
End 2020 IDG published a study on Security priorities, and it provides important guidelines to the priorities of securing yourself and your company
Protection of confidential and sensitive data
End-user awareness
Corporate resilience
Enhance access control
Understand external threats
Application security
Plan for unexpected risks
This pretty much confirms that your customers, stakeholder’s and staff interest in protecting personal data is driving security from business perspective.
If you see the increase of cyberattacks and ransomware hitting the business, it’s pretty obvious that Business Continuity Management and Disaster recovery must be on top of your priority list. You need to have a tested plan against successful cyberattacks and ransomware, to avoid extended business damage and massive (ransom) costs … afterwards.
To put a plan together, you need to understand who is your adversary and what the current state of cybersecurity is. And this study is a simple but smart guide to define your priorities.
The better you prepare, the less it will cost. But you’ll only be able to tell when it goes wrong.
The CIS (Center for Information Security) Controls list is a very well known list of security measures to protect your environment against cyberattacks. The Center for Information Security provides a handy XLS sheet for download to assist in your exercise.
Security note for the security freaks, apparently the document is hosted on the pardot(dot)com Salesforce website, which might be blocked by Adlist domain blockers as it’s used for marketing campaigns, you might need to unblock it, or use Tor browser…)
FYI, the previous version (2019, v1) of the mapping had quite some gaps. Therefor I’ve submitted a suggestion for an updated CIS-ISO27001 mapping. And after review, a new version (1.1) with updates has been published on the CIS workbench.
You’ll notice that the update (1.1) version has still some gaps. And I’ll leave to the discretion of the CIS review work group to argument these gaps.
But I’m convinced you can map the CIS controls for 100% to ISO27001, in one way or another, meaning use ALL ISO27001 controls in certain extent (sometimes a subset, equally or a superset of it, combining controls.)
But the license for use of the CIS controls mapping does not allow redistribution of modified materials…
To further clarify the Creative Commons license related to the CIS ControlsTM content, you are authorized to copy and redistribute the content as a framework for use by you, within your organization and outside of your organization for non-commercial purposes only, provided that (i) appropriate credit is given to CIS, and (ii) a link to the license is provided. Additionally, if you remix, transform or build upon the CIS Controls, you may not distribute the modified materials. Users of the CIS Controls framework are also required to refer to (http://www.cisecurity.org/controls/) when referring to the CIS Controls in order to ensure that users are employing the most up-to-date guidance. Commercial use of the CIS Controls is subject to the prior approval of CIS® (Center for Internet Security, Inc.).”
So I CANNOT distribute the XLS as modified material (Why not?).
Extending the mapping
If you still want to build an extended version of the mapping on your own, you download the 1.1 version and add these items to the list:
CIS section
Coverage
ISO27001 Control
2.2
=
A.12.5.1
2.5
=
A.8.1.1
2.8
small subset
A.12.5.1
2.10
small superset
A.9.4.1/A.8.2
3.1
small subset
A.12.6.1
3.2
small subset
A.12.6.1
3.4
small subset
A.12.6.1
3.5
small subset
A.12.6.1
3.6
small subset
A.12.6.1
4.1
small superset
A.8.1.1/A.9.2.3
6.5
small subset
A.12.4.1
6.6
small subset
A.12.4.1
6.8
small subset
A.12.4.1
7.3
small subset
A.12.2.1
7.5
small superset
A.8./A.13.1.1
7.6
small subset
A.13.1.1
8.3
small subset
A12.2.1
9.5
small subset
A.13.1.1
10.2
small subset
A.12.3.1
10.5
=
A.12.3.1
11.1
small subset
A.13.1.1
11.2
small subset
A.13.1.1
11.6
small subset
A.13.1.1
12.1
small subset
A.13.1.1
12.5
small subset
A.13.1.1
12.10
small subset
A.13.1.1
13.2
small subset
A.11.2.5
14.7
small subset
A.8.2.3
16.2
small subset
A.9.3.1
16.3
small subset
A.9.3.1
16.9
small subset
A.9.2.1
16.10
small subset
A.9.2.1
16.12
=
A.12.4.1
16.13
=
A.12.4.1
17.1
=
Clause 7.2
18.3
=
A.12.5.1
18.4
=
A.12.5.1
18.7
=
A.14.2.9
18.10
small subset
A.14.2.5
18.11
small subset
A.14.2.5
19.3
small subset
A16.1.1
19.6
small subset
A16.1.2
19.7
small subset
A16.1.1
19.8
small subset
A16.1.4
20.1
small subset
A18.2.3
20.2
small subset
A18.2.3
20.3
small subset
A18.2.3
20.4
small subset
A18.2.3
20.5
small subset
A18.2.3
20.6
small subset
A18.2.3
20.7
small subset
A18.2.3
20.8
small subset
A18.2.3
Planning for ISO Certification using CIS Controls?
When you look at it from a different angle and you would like to build a plan to certify your ISO27001 implementation, we need to turn around the mapping, and look for the gaps in the ISO27001 security controls AND CLAUSES, when doing the CIS control mapping.
And then you’ll notice the explicit difference in approach between CIS controls and ISO27001 controls. CIS controls are focusing on technical implementation to harden your cybersecurity, while ISO27001 is a management system that needs these controls, but requires a management layer to support these technical controls. CIS controls are lacking this management layer. If you compare both systems in a table the story gets clear:
The “red” areas require extra work to make it ISO27001 compliant.
And as always, if you have suggestions of feedback to improve this article, let me know, I’ll fix it on the fly.
With the publication of the GDPR in 2016, it quickly became clear that it would massively impact the direct marketing sector, simply because direct marketing runs on personal data.
On 25 may 2018, the GDPR came into force, changing the global mindset on data protection (and privacy by extension).
Anno 2020, 2 years after the publication, many enterprises, large and small still struggle to apply the data protection regulation and best practices.
And for the direct marketing companies, this is a particular difficult topic, after 4 years.
So, maybe, the newly (june 2020) published standard can provide a practical help to implement consent management. Please remind that the GDPR is a regulation/law… not a best practice with hints and tips.
While there has been a lot of guidance, communication & education on implementing a direct marketing that is compliant with GDPR and ePrivacy/eCommunication regulation and directives.
Even, for other markets than direct marketing where managing personal data is optional (meaning, not part of core business), you can use this guide to manage privacy or data protection notices for your newsletters and website.
Side note
The ISO 29184 is strictly and only about privacy notices and consent, it’s not an in depth guide for direct marketing, but it’s an essential part of it.
After the mandatory basic chapters (Foreword, 1. Scope), the document hints to ISO 29100 in chapter 2 (Normative References) and 3. (Terms and definitions.
Important note here is that the definition of “explicit consent” has been updated to match the GDPR requirement for unambiguous affirmative consent.
Chapter 5 contains the “general requirements and recommendations”.
A major requirement (and typical for ISO compliance like in ISO9001 and ISO27001) is that you need to document the implementation of each control in this standard.
The content is structured in 5 chapters (Level 2)
Overall objective
Notice
Contents of notice
Consent
Change of conditions
To read the full details, you know what to do,…
But it’s interesting to see the technical/operations controls required in this standard
General conditions on privacy notice
Provide information to all interested parties about your privacy practices, including
the identity and registered address of the data controller, and
contact points where the subject (in this standard the subject is called “PII principal”)
Provide clear and easy to understand information
with regards the target audience,
which are usually NOT lawyers or data protection specialists),
taking care of the expected language of your audience
You must determine and document the appropriate time for providing notice
Remember the Art. 13 and Art 14 definitions in GDPR
By preference, you should notify the subject immediately before collecting PII (and/or consent)
You must provide notices in a appropriate way
by preference in more than 1 way,
to make sure the subject can find and consult the notices,
digitally and in a easy accessible method
also after initial contact
As also defined in many GDPR guidelines, the consent standard refers to a multilayer approach (avoiding to provide too much information at the same time, but provide the details when needed)
Make sure that the privacy notice is accessible all the time.
Notice content
make sure you’re absolutely clear, honest and transparent about your personal data processing
Define, document and describe clearly
the processing purpose
each element of the processing (remember the processing definitions defined in Art. 4 of GDPR)
the identification of the data controller
the data collection details, incl
methods used
details of data collected
type of collection (direct, indirect, observation, inference…)
timing and location of collection
use of data, including
direct use without data transformation
reprocessing data
combining, like enrichment
automated decision making
transfer of data to 3rd party
data retention (incl backup)
data subject rights
access request
authentication to provide access
timelines
any fees that apply
how to revoke consent
how to file a compliant
how to submit a inquiry
Evidence about consent provided (and changed) by the subject
the legal basis for processing PII/personal data
the risks related with the data and the plausible impact to the subject privacy
Consent management
Identify if whether consent is appropriate
Remember that there are other purposes and reasons for processing data, which usually have a more stable, more solid background, like
contracts
compliance with legal obligations and regulations
vital interest,
public interest
(legitimate interest, which is usually way more difficult to enforce or to convince the subject)
Informed and freely given consent
how do you guarantee that the subject is providing consent without any feeling of coercing, force, conditions, …
Independence from other processing or consent
Remember the GDPR guidelines where you CANNOT force consent as
Inform the subject which account this processing is related to
provide a clear description of the identifier (userID, mail, login, …)
ISO29184 also introduces the consent lifecycle, meaning that is it’s not sufficient to provide notice at first contact with the subject, but you also need to maintain, to update and to renew it on a regular basis, taking into account that the conditions of consent might change (or might have changed after initial consent).
The last part of the ISO 29184 are annexes with interesting user interface examples.
The perfect document set
To make the online privacy and consent management work, this ISO/IEC 29184 will not do on itself as the standard links to the following documents:
If not available for free download, then you’ll need to purchase the ISO standards documents from the ISO e-shop or from the national standards organisation (like NBN for Belgium, NEN for Netherlands, …)
“PDCA (plan–do–check–act or plan–do–check–adjust) is an iterative four-step management method used in business for the control and continuous improvement of processes and products.[1] It is also known as the Deming circle/cycle/wheel, the Shewhart cycle, the control circle/cycle, or plan–do–study–act (PDSA). Another version of this PDCA cycle is OPDCA.[2] The added “O” stands for observation or as some versions say: “Observe the current condition.” This emphasis on observation and current condition has currency with the literature on lean manufacturing and the Toyota Production System.[3] The PDCA cycle, with Ishikawa’s changes, can be traced back to S. Mizuno of the Tokyo Institute of Technology in 1959.[4]”
OP 6 feb jongstleden, presenteerde ik een sessie bij Privatum, voor hun avondsessies van “Privacy After Work”.
Dat is een lichte, interessante aanpak om mensen bij elkaar te brengen ivm privacy en gegevensbescherming, dus ideaal voor netwerking en interessante dingen te leren.
Microsoft heeft een open-source mapping gepubliceerd tussen de controles in ISO / IEC 27701 (de nieuwe uitbreiding van de gegevensbescherming van ISO 27001 en 27002) en verschillende wettelijke regels, waaronder de GDPR (Europese Unie).
Het project bevat een Excel-bestand met de onbewerkte gegevens: zie https://github.com/microsoft/data-protection-mapping-project/raw/master/src/assets/database.xlsx
Identity Underground 
You must be logged in to post a comment.