GDPR: The Day After. Pierre-Luc REFALO
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1 GDPR: The Day After Pierre-Luc REFALO
2 The speaker: Pierre-Luc REFALO Global Head of Strategic Cybersecurity Consulting 25+ years in Information & Cyber Security consultancy CISO for SFR & Vivendi Universal ( ) Author 2013 Award Teacher Speaker 2
3 «Success consists of going from failure to failure without loss of enthusiasm!» Sir Winston Churchill 3
4 You ve been breached: just a question of time 201 days average time to detect a cyber incident. (1) 70 days average time to recover after a targeted attack. (1) The processing of personal data should be designed to serve mankind. The right to the protection of personal data is not an absolute right; it must be considered in relation to its function in society and be balanced against other fundamental rights, in accordance with the principle of proportionality. GDPR Recital #4 27 April 2016 $445bn estimated annual cost to the global economy from cyber crime. (2) 89% of breaches had a financial or espionage motive. (3) 90% of cyberespionage breaches capture trade secrets or proprietary information. (3) (1) Ponemon Institute - Research Report (2) Hiscox - Cyber Readiness Report 2017 (3) Verizon - DBIR
5 You ve been breached: impacts are real and maybe huge What? Operational impact Disrupted process, stress, etc. Reputation impact The nightly news, market brand, etc. Legal impact Contractual clauses, Law suits, Class actions, etc. Economic impact Loss of revenue, fines, additional costs, etc... 5
6 You ve been breached: you have to understand How? When? 6
7 You ve been breached: real life 40 millions of financial data stolen 70 millions of personal data stolen Target Corporation suffered one of the largest cyber breaches to date.. $252 millions: loss of revenue (Q4 2013) $57 millions: reduced taxes $90 millions: Insurance reimbursement John Mulligan (Target CFO) had to face a Senate judiciary committee for almost 3 hours. Net loss = $105 millions (0,1% of 2014 sales) Source: Columbia University, Benjamin Dean 7
8 Extracts from GDPR: Section 2 Security of Personal Data Article 32 8
9 Did you monitor your Systems and Crown Jewels? 9
10 Did you protected your data and assets (enough)? 10
11 Did you perform a Privacy Impact Assessment? 11
12 Did you perform a Privacy Impact Assessment? Three different PIA approaches 1. PIA on organization - scope: privacy governance & policies The organizational privacy impact assessment reviews basically all GDPR articles and gives insight to define the organizations privacy governance and policy framework. 2. PIA on operations scope: business processes, systems & people The operational privacy impact assessment is very much related to the responsibility of the controller (art.24, GDPR). It reviews the technical & organizational measures of the existing operations to be compliant with the GDPR. 3. PIA on new business initiatives scope: new product & service development, marketing programs, campaigns, etc. Data protection impact assessment (as described in art.35, GDPR) are required, where the usage of new technologies is likely to result in a high risk to the rights and freedoms of natural persons. Risk mitigating measures have to be designed into products by default (art.25, GDPR). It is not a one off exercise; privacy is here to stay! 12
13 Did you implement Data Discovery and Classification? 13
14 Did you implement Data Discovery and Classification? The new Digital Landscape IT & IoT Public Cloud App Private Cloud App Data Center Internet Data analysis Big Data Gateway Gateway Data aggregation Connected Objects (IoT Products) Sensors Object Hub of sensors Hub of sensors Object Data Acquisition 14
15 Did you implement Data Discovery and Classification? Collect Classify Connect to all relevant DB and systems Identify Profile data to get a structure and format overview Identify Personal Data, in DB, tables and fields Start looking at deduplication Catalogue findings on fields, table and DB level According to risks - the nature - The scope - the volume - the users - the access - the location - the process itself 15
16 Do you plan a Journey to the Cloud? Cloud services provide better security than many on premise infrastructures. 3 topics remain under data owner / controller accountability: Governance, Risk & Compliance Identity and Access Management Information & Data Protection Two key challenges: Internet of Things and connected objects Geo-strategy & Sovereignty 16
17 Customer Manages Customer Manages Customer Manages Customer Manages The type of cloud service drives how shared responsibility is assigned between the Cloud Service Provider and the organisation On-Premises Infrastructure (as a Service) Platform (as a Service) Software (as a Service) Governance Risk & Compliance Governance Risk & Compliance Governance Risk & Compliance Governance Risk & Compliance Identity & Access Management Identity & Access Management Identity & Access Management Identity & Access Management Information and Data Protection Information and Data Protection Information and Data Protection Information and Data Protection Applications Applications Applications Applications Data Data Data Data Runtime Middleware O/S Virtualization Servers Storage Networking Runtime Middleware O/S Virtualization Servers Storage Networking Cloud Supplier Manages Runtime Middleware O/S Virtualization Servers Storage Networking Cloud Supplier Manages Runtime Middleware O/S Virtualization Servers Storage Networking.while Governance, Risk and Compliance, Identity & Access Management and Information & Data Protection will always be the responsibility of the customer Cloud Supplier Manages 17
18 Data Protection is a long term challenge that Capgemini handles globally since : 2 key Group Initiatives Binding Corporate Rules 18
19 Low Strength of Security Framework High We release a new survey on Cybersecurity & Privacy for Financial Institutions The Currency of Trust: Why Banks and Insurers Must Make Customer Data Safer and More Secure Strength of data privacy policies vs. strength of security framework Privacy-passives Pace-setters 20% 29% 31% 20% Laggards Low Source: Capgemini s Digital Transformation Institute Cybersecurity and Privacy Survey Strength of Data Privacy Policies Banking Insurance Security-sloths High 19
20 We provide 12 «end to end services» to help our clients to comply with GDPR Capgemini is a trusted partner from a strategic / tactical / operational perspective Organize Privacy Impact Assessment 4 3 Strategic Organization Transformation & Professionalization Data Discovery 5 6 Operational Data Automatic Classification Data Protection Maturity Assessment & Roadmap 1 2 Awareness & Change Management Compliance Tracking 8 7 IAM Fast Track 1 2 Monitor 4 3 Protect SOC & SOCaaS Data Leak Prevention Data & Data Base Security * + Anonymization 10 9 IDaaS * Incl. Key Management System 20
21 Data Privacy & Protection is at the heart of our internal CySIP program Win More Become a leader in Cyber Security and Data Privacy by being exemplary within our organization Provide best-in-class cybersecurity, alongside technology solutions BUSINESS RISK COMPLIANCE Be Secure Protect digital assets within Capgemini Protect the personal data of Capgemini employees and customers Secure our delivery to clients Be Trusted Comply with the law Provide solid cyber security and data privacy solutions to our clients The CySIP Program aims at leveraging the Capgemini Cybersecurity Unit to protect Capgemini s digital assets and reputation; to secure delivery management; and to develop business 21
22 Takeaways: Challenges The last stretch: Data Privacy / Protection Transformation Program Make sure a proper Data Protection Governance is in place including a Data Protection Officer when required - working with CISO and DRO 1 Establish accountability (Controller and Processor) for Personal Data Processing Implement encryption and enhance IAM within Database Translate GDPR to make it understandable to IT Staff: Developers, architects, project managers, etc. Business Lines (Marketing, Sales, Supply chain, etc.) and central functions (HR, Purchase, etc.) Cloud services stakeholders Implement a «security AND privacy by design» process Set up or revise privacy impact assessment procedures and privacy-by-design methods Handle increased requirements for security of processing taking into account the risk profile of data processed (pseudonimization in particular) Think about a specific «Design Authority» (decision making body) for critical processes On a case by case basis, prepare or develop a «DLP 2» initiative Shadow IT controls Threat Hunting Deep / Dark Web monitoring 1- Digital Risk Officer 2- Data Leak Prevention 22
23 Takeaways: Data and People are structuring Digital Risk Management 23
24 Takeaways: Privacy vs Security is still a challenge «Those who would give up essential liberty to purchase a little temporary safety deserve neither liberty nor safety. Benjamin Franklin
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