Data Protection v2
“The only truly secure system is one that is powered off, cast in a block of concrete, and sealed in a lead-lined room with armed guards. But even then, there’s no guarantee.”
Guide for Engineers, Analysts, Managers, and Auditors
In an era where data breaches make headlines almost daily, protecting sensitive information has never been more critical. The Colonial Pipeline ransomware attack in 2021, which disrupted fuel supplies across the Eastern United States, serves as a stark reminder of the potential consequences of inadequate data protection. This guide will walk you through the process of developing robust data protection measures, as outlined in the CIS Control for Data Protection.
For Engineers
As an engineer, you're on the front lines of implementing and maintaining the technical aspects of data protection. Your role is crucial in turning policies into practical, effective solutions. You're responsible for designing and building secure systems, implementing encryption and access controls, and ensuring that data is protected throughout its lifecycle.
Data protection is paramount. Your expertise is critical in safeguarding sensitive information from unauthorized access, breaches, and potential misuse.
You play a key role in maintaining the confidentiality, integrity, and availability of data, ultimately contributing to the trust and confidence that individuals and organizations have in the systems they rely on.
Data Identification
Implement automated data discovery tools to scan networks and systems.
Develop and maintain an up-to-date data inventory system.
Create data flow diagrams to visualize how data moves through your systems.
Data Classification
Implement automated data classification tools.
Develop algorithms to detect and classify sensitive data like credit card numbers or personal identifiable information (PII).
Integrate classification tags into your data storage and processing systems.
Secure Data Handling
Implement encryption for data at rest and in transit. Consider using AES-256 for sensitive data.
Develop access control mechanisms based on the principle of least privilege.
Create secure data transfer protocols, possibly utilizing secure FTP or HTTPS for web applications.
Implement data loss prevention (DLP) solutions to monitor and control data egress.
Data Retention
Implement automated data retention and archiving systems.
Develop processes for securely transferring data to long-term storage when required.
Data Disposal
Implement secure data erasure tools and processes. Consider tools that comply with standards like DoD 5220.22-M or NIST 800-88.
Develop protocols for physical destruction of storage media when necessary.
Engaging Fact: The concept of "data gravity," introduced by Dave McCrory in 2010, suggests that as data accumulates, it becomes harder to move and manipulate. This underscores the importance of implementing robust data management systems from the start.
For Analysts
As an analyst, your role involves interpreting data, identifying patterns, and providing insights that drive decision-making in data protection strategies.
Data Identification
Analyze the results of data discovery scans to identify trends and anomalies.
Conduct regular audits of the data inventory to ensure accuracy and completeness.
Develop metrics to measure the effectiveness of data identification processes.
Data Classification
Analyze the effectiveness of automated classification tools and suggest improvements.
Conduct regular reviews of classification criteria to ensure they remain relevant and effective.
Develop reports on data classification trends to inform policy decisions.
Secure Data Handling
Analyze access logs to identify potential security risks or policy violations.
Conduct risk assessments on data handling procedures and suggest improvements.
Develop dashboards to visualize data security status across the organization.
Data Retention
Analyze data usage patterns to inform retention policies.
Conduct cost-benefit analyses of different data storage and archiving solutions.
Develop reports on compliance with retention policies.
Data Disposal
Analyze disposal logs to ensure compliance and identify potential issues.
Conduct regular reviews of disposal procedures to ensure they remain effective and compliant.
Develop metrics to measure the efficiency and effectiveness of data disposal processes.
Newsworthy Snippet: In 2018, a study by IBM found that the average time to identify a data breach was 197 days, and the average time to contain it was 69 days. This highlights the crucial role of analysts in quickly identifying and responding to data security incidents.
For Managers
As a manager, your role involves overseeing the implementation of data protection strategies, ensuring compliance, and fostering a culture of data security within your organization.
Data Identification
Establish a data governance team to oversee the identification process.
Ensure regular reviews of the data inventory.
Allocate resources for data discovery and management tools.
Data Classification
Define clear data classification levels (e.g., Public, Internal, Confidential, Restricted).
Ensure all employees understand the classification system and their responsibilities.
Regularly review and update classification policies to align with business needs and regulatory requirements.
Secure Data Handling
Establish clear policies for data handling procedures.
Provide regular training on secure data handling practices.
Implement a system for reporting and managing data security incidents.
Data Retention
Define data retention periods for different types of data, considering legal and business requirements.
Regularly review and update retention policies.
Ensure compliance with data protection regulations like GDPR, which includes "the right to be forgotten."
Data Disposal
Establish clear policies for data disposal, including timelines and methods.
Ensure proper documentation of all data disposal activities.
Regularly review and update disposal procedures to align with current best practices and regulations.
Engaging Fact: According to the Ponemon Institute's 2020 Cost of a Data Breach Report, the global average cost of a data breach is $3.86 million. However, companies with fully deployed security automation (which includes many data protection measures) experienced less than half the cost compared to those without automation.
For Auditors
As an auditor, your role is to independently verify that data protection measures are being implemented effectively and that the organization is complying with relevant policies and regulations.
Data Identification
Verify the completeness and accuracy of the data inventory.
Check that data discovery processes are documented and followed.
Review the data governance structure and its effectiveness.
Data Classification
Review the data classification policy and its implementation.
Conduct spot checks to ensure data is correctly classified.
Verify that classification levels are appropriate and consistently applied.
Secure Data Handling
Verify that encryption and access controls are properly implemented.
Check compliance with data handling policies.
Review incident response procedures and their effectiveness.
Data Retention
Verify that data is being retained according to defined policies.
Check that expired data is properly archived or disposed of.
Review the process for updating retention policies and ensure it's being followed.
Data Disposal
Verify that data disposal policies are being followed.
Check disposal logs and documentation for completeness and accuracy.
Review the effectiveness of data disposal methods against current best practices.
Newsworthy Snippet: In 2020, Morgan Stanley was fined $60 million for improper disposal of computer equipment containing customer data. This incident highlights the importance of thorough audits of data disposal practices, even for physical assets.
