note-to-self

Note-to-self: Reference Articles on eID, privacy & GDPR

Following list of articles is a memory help and quick reference to interesting and useful articles from regarding the use of eID (Belgian Identity Card), related to privacy, data protection and GDPR.

This article will be updated regularlywhen interesting items are discussed or noted on workshops, discussions or other social media like LinkedIn.

eID

GBA Advisory on photocopy identity card

https://www.gegevensbeschermingsautoriteit.be/sites/privacycommission/files/documents/aanbeveling_03_2011.pdf

LinkedIN articles

Denk 2 keer na voor je een fotokopie laat maken van je identiteitskaart

(Think twice before you let someone photocopy your identity card)

https://www.linkedin.com/pulse/denk-2-keer-na-voor-je-een-fotokopie-laat-maken-van-peter-geelen-/

Het gebruik van uw identiteitskaart als waarborg? (Using your identity card as waranty. NOT.)

https://www.linkedin.com/pulse/het-gebruik-van-uw-identiteitskaart-als-waarborg-peter-geelen/

Direct Marketing

Direct marketing and protection of personal data

Interesting cases & decisions

See other post: collecting interesting cases and decisions by the Belgian DPA:

https://identityunderground.wordpress.com/2020/06/11/note-to-self-interesting-dpa-decisions-court-cases-regarding-gdpr-it-security/

€750.000 per year for some onepager PDF, you can do that too.

scam-3933004_1920

(Image Credits: mohamed Hassan via Pixabay)

Dear Annie BG Mathews,

Dear CIO Applications Europe,

(quote, feb 2020) “I am Annie from CIO Applications Europe magazine and it is my pleasure to inform you that we have pre-screened the top players who have carved a niche in the Information Security arena and have shortlisted them to be featured as one of the “Top 10 Information Security Consulting/Service Companies 2020”, <…> being one of them.”

(quote, apr 2020) “I am Annie from CIO Applications Europe magazine, and it is my pleasure to inform you that we have pre-screened the top players who have carved a niche in the GDPR arena and have shortlisted them to feature as one of the “Top 10 GDPR Consulting/Service Companies 2020”, <…> being one of them.”

Did you also get the same mail  from “CIO Applications Europe”, with their fabulous “Top 10” marketing, asking a small fee of €2500,- to be featured as top-player in the <see below> field, for which you get a fabulous … eh.. 1 single pager PDF. And using their top 10 logo in your marketing.

Top, you make me feel so special!

Just.. ehm… radio couloir says lots of my sector contacts and LinkedIn network contacts got the exact same mail.. So, top 10, my @§§.

Marvelous quick win

Just a bit of 12y-old math says: that is a smart turnover of 25.000 EUR per top 10 published. Knowing that they have published roughly 30 of their “top 10” articles for 2019, this means a quick win of €750.000 on one-pagers only.

The categories they have listed last year:

(Look it up yourself: https://www.google.be/search?q=inurl:cioapplicationseurope.com+%22Top+10%22+%22-+2019%22)

  • Agile Technology, Asset management, Automotive, Blockchain, Blockchain Solutions, Business Intelligence, CEM solution, Contact center, Cognitive consulting, ERP, FinTech Solution, GDPR Solutions, GDPR consulting, IBM Solution, Information Security, IoT solution, IT services management, Legal technology, Mar tech, Microsoft solution, Microsoft Consulting, Procurement, Proptech, Salesforce, Smart City Tech,…

Forgive me if  I forgot another €25.000,- in the 30x Top 10 of 2019 they listed.

But some important categories missing, so you can do that too, some ideas below.

If the “Top 10” on GDPR is completed, you create new categories like “GDPR consulting”, “GDPR legal advice”, “GDPR breach specialist”, “GDPR expert”, “GDPR Services”, that’s another 125K of revenue, easy deal to fill the 1 million bucket.

So, you can buy yourself a list in the Top 10.

So here’s the deal, for 2499 EUR, you can get listed in the 2020 Top 10 spam and scam companies, you get a full A6 print page (special 7pt Wingdings font) with a 3 minute made-up interview with your CSSO. (Chief Spam’n Scam Officer.)

Legit business??

For €2499,- you get an interview, a one pager and a logo for display.

I quote: “We want to work with you towards a single page article after an interview with the senior management projecting the unique story of your company. For a nominal amount of 2,500 Euros, you will own complete print and digital rights to use the pdf of profile in your process of acquiring new clients along with many other prominent benefits like rights to use the Top 10 logo in your communications, single page complimentary advertisement placement and many more which I would love to explain when we connect.

It’s not forbidden to make you a ridiculous offer, but do you really want to sponsor this scam and spam practice and keep it alive?

Fact is, this is not ‘just a spam’ campaign.. It’s setup as legitimate business, at first sight.

You can still ask yourself why CIO Applications “EUROPE” would have a phone number in the US.

#GDPR!

It’s not only about the scam, they are using personal data without notification.

And you can argue they can use “legitimate interest”. Yes, for sure. But still they need to apply article 13 and 14, when collecting personal data. Their privacy notice (https://www.cioapplicationseurope.com/privacy-policy/) is not mentioned in the mail communication, it does not mention how they collect my data and how the process it. Neither do they refer to the required legal GDRP mentions (like DPA contact and so on…).

There is no reference how to file a subject-data access request… you can always spam their marketing department as mentioned in their privacy notice.

So, this could even be a valid reason for contacting your DPA and file a complaint.

I don’t want to unsubscribe to spam mail, because I don’t want to give you just more information if you don’t respect me from the beginning.

What’s the real problem then?

What do you think of a “Top-10” ranking, that is only based on the fee you pay? The first 10 that pay, are in the top 10. Number 11, bad luck. Oh wait, we’ll setup another top 10.

This feels like bribery. And mental pressure.

They send out the requests to new companies, struggling to conquer the market. They make your feel important, but it’s only about the money.

This type of practice puts other legitimate rankings in such a bad daylight… the smell of money on a “Top 10 …something”. This destroys the reputation of other communities, value papers and IT or security sectors. It’s not isolated to this one bad apple.

Be smart

Think. If it doesn’t feel right, it is not right. For a bare €2499,- you can achieve a lot more than a single page PDF and a top 10 logo.

For the same money and the support of a real marketing specialist, and some smart channel management, you can create real impact.

But most important of all, do what you do best. Create impact. Create great stuff, create buzz, let customers tell your story…

Stay out of the pile of bad apples.

#justthinking

Note-to-self: MNM van KSZ (Minimale normen – Sociale Zekerheid)

Minimale Normen / Normes Minimales van de KSZ (Kruispuntbank van de Sociale Zekerheid) gebaseerd op de ISO27001/ISO27002

“De toepassing van de minimale normen informatieveiligheid en privacy is verplicht voor instellingen van sociale zekerheid overeenkomstig artikel 2, eerste lid, 2° van de wet van 15 januari 1990 houdende oprichting en organisatie van een Kruispuntbank van de Sociale Zekerheid (KSZ). Bovendien moeten de minimale normen informatieveiligheid en privacy eveneens toegepast worden door alle organisaties die deel uitmaken van het netwerk van de sociale zekerheid overeenkomstig artikel 18 van deze wet. Tenslotte kan het sectoraal comité van de sociale zekerheid en van de gezondheid de naleving van de minimale normen informatieveiligheid en privacy ook opleggen aan andere instanties dan de hogervermelde.  ”

Bookmark:

(NL) https://www.ksz-bcss.fgov.be/nl/gegevensbescherming/informatieveiligheidsbeleid

(FR) https://www.ksz-bcss.fgov.be/fr/protection-des-donnees/politique-de-securite-de-linformation

(edit)

Opmerking: voor alle duidelijkheid, op zich zijn deze documenten geen nieuwigheid maar buiten de SZ zijn deze normen minder gekend… vandaar dat het toch nuttig is om ze bij te houden als geheugensteun en referentie. Je komt er sneller mee in contact als je denkt…

Note-to-self: logging policy considerations

Few days ago I got a question from a security officer for guidance on event and system logging.

What I can recommend: a good guideline and indication is this from OWASP.
You know OWASP is THE reference for software security …. with their OWASP top 10 etc.

Check this: https://owasp.org/www-project-cheat-sheets/cheatsheets/Logging_Cheat_Sheet

Another reference from NIST see below, very handy.

These are fairly complete in terms of guideline.

What you should pay special attention to from a policy point of view is

Special accounts

  •  Sensitive accounts
    • Highly priviliged accounts
    • Admin accounts
    • Service accounts
  • Sensitive systems
    • Domain controllers
    • Application servers
  • Sensitive data
    • HR data
    • Finance data
    • Legal data

Regarding the classification of accounts, check these:

For the users you also have to think carefully about events

  • Large volume of failed logons from sensitive users, may indicate
    • Attack
    • Denial of service
    • Hacking
  • Attack on the password database, large volumes of password change attempts …
    •  Smart password ‘testers’ will stay just below the blocking limit ..
  • Successful logons from special accounts at abnormal places or times
  • Changing the rights of sensitive accounts
    • Promotion of regular users to admins or other sensitive accounts in AD or central database

CLASSIFICATION

Make sure you have a data, user and system classification policy.
Define roles and / or categories.
Which objects are “not important”, “not sensitive”, sensitive, important, critical.
The protection must be tailored to the category type.

STORAGE

In addition, you should also write a policy on saving data.
This often poses a logistical problem with disk space.

If you know that sometimes attacks are only detected after 200-300 days, you should be able to do a forensic investigation in that period.
But that does not have to be on live data, if it is in backup, that is also good.

In terms of operational data you have to decide how much should be available immediately, for immediate consultation.
For example, that can be 1 month. (if the system can save so much)

BACKUP

Ensure that a backup can be guaranteed for a year (combination of full / differential and / or incremental backups or virtual snapshots …)
This is not a fixed period, but depending on risk management this may be more or less.

IMPORTANT: Time synchronization

Also make sure that you require NTP time synchronization, so that the clocks are exactly matched to each other on all systems.
Log analysis is impossible without correct timing.

SECURITY

Ensure that logs on source systems cannot be deleted by administrators.
Ensure that the logs following are shielded from system owners;
Ideally, you are obliged to store logs centrally (for example in a SIEM system).

Secure backups

Consider managed encryption of data and backups (not ransomware or malware).

Healthy logging and healthy backups

Make sure to test backups and restores!

Check the logs and backup for malware.

LOG CENTRALIZATION

Store logs centrally with sufficient storage capacity, security and backup.

LOG MANAGEMENT

A good management process and regular inspection must become mandatory.
Ensure monitoring for special events or special trends (sudden growth or sudden decrease or disappearance of logs)

Arrange forensic surveillance / detention if a burglary or data breach may need to be reported to the government / DPA / police.

The NIST documentation below provides useful hints and tips about the type of systems, routers, switches, firewalls, servers …

LEGISLATION

Take into account legislation such as GDPR or ePrivacy or others that impose your obligations (legal, judicial, international, fed gov, …)

EXPERIENCE

View and learn from past incidents and known use cases or accidents, which give a clear hint of what protect first.

PDCA – plan-do-check-act

Require a regular review of the policy and the rules, ensure that the guidelines are updated to the requirements and changing situations.

It is difficult if you find out after the facts that your log is not working properly.

Other references

And this is also a reference (NIST)

Note-to-self: Word function for sample text

I’ve posted this on LinkedIn before, but I couldn’t find it right away.
So a blogpost helps as external memory and should make it easier to find.

If you want to quickly fill a word document with intelligent rubbish. Type =lorem(p,l) P is the number of paragraphs you need, and l the number of lines.

There is more, also random text is possible, but full explanation is here: https://support.microsoft.com/en-us/help/212251/how-to-insert-sample-text-into-a-document-in-word

And it still works in the O365/Office 2016 version…

Note-to-self: prepping for CSA CCSK v4 upgrade

Note-to-self: extended reprint of a LinkedIn post…

I might have mentioned it already, but if you have passed the CCSK exam before, better logon to your CCSK profile on the CSA website and check if you still have an exam token left.

By default you get 2 tokens each exam registration, so…

If you pass your exam the first time, the “second try” backup token is left unused in your profile.

And (if not yet expired) you can use it to upgrade your CCSK to v4.

Tokens stay valid for 2 years after purchase.

More info: https://ccsk.cloudsecurityalliance.org/en/faq

On that page you can also find the required study material for the exam.

You can download the CCSK v4 prep kit from : https://downloads.cloudsecurityalliance.org/ccsk/CCSKv4_Exam_Preparation_Kit.zip

It’s an online exam and thus open book exam, using the below reference guides.

But realise:  60 questions in 90 minutes still is hard work, so better do some prep work up front to maximize your chances.

Once you pass this one, you can go for the (ISC)² CCSP with more confidence…

Updated: Useful resources for GDPR starters

ICYMI: Update to Useful resources for GDPR starters

Added:

Vocabulary / Grammar

Do not get confused: European Council vs  Council of the European Union vs Council of Europe

More info at:

 

Full text at: Useful resources for GDPR starters

 

 

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.

Note-to-self: #MIM2016 & #FIM2010 Config documenter released on GitHub

Source: Announcement on MIM 2016 Group on LinkedIn by  Jef Kazimer

Source Code: https://github.com/Microsoft/MIMConfigDocumenter

Jef announced that the Identity Community Projects team has published the MIM Config Documenter tool to the Microsoft GitHub Organization as an open source community project.

The MIM configuration documenter is a very nice and easy tool to generate documentation of a MIM / FIM synchronization or service installation.

It allows to: 

  • Document deployment configuration details for the MIM / FIM solution, including MIMWAL Workflow definitions
  • Track any configuration changes you have made since a specific baseline
  • Build confidence in getting things right when making changes to the deployed solution

You can find the project code, releases, and documentation at https://github.com/Microsoft/MIMConfigDocumenter

 

Note-to-self: Hotfix rollup package (build 4.4.1459.0) is available for #MIM2016 SP1

Microsoft has released an hotfix for MIM2016 SP, with an awful lot of updates and improvements.. to much to list… but more to read:

See here: Source: https://support.microsoft.com/en-us/help/4012498/hotfix-rollup-package-build-4-4-1459-0-is-available-for-microsoft-iden