Trillium Insights

Thoughts and Insights from Trillium's Practice Leaders

How do you obtain and maintain GDPR consent?

How do you obtain and maintain GDPR consent?

General Data Protection Regulation (GDPR) is the legal set of guidelines for the collection and processing of personally identifiable information (PII) by organizations within the European Union (EU.)  GDPR also applies if personal data of an EU resident is maintained, regardless of where the organization is located, so it’s impacts are far-reaching.  The deadline for implementation (May 25, 2018) is quickly approaching (or may have passed, depending on when you’re reading this) so if your organization are impacted by GDPR regulations, your preparations should be well underway.  One of the rules surrounding GDPR relates to obtaining explicit consent to retain PII, as well as for opting out.  What are some ways to deal with collecting permission to maintain PII?

  • Setting up a method for obtaining explicit permission to maintain PII depends on how the data will be used.  You could use electronic forms, emails, or scanned documents with customers’ signatures.
  • Maintaining consent information as an integral part of your compliance records in the event of an audit by regulators.  However, any method of consent must be provable with a clear audit trail in the event proof must be required.  Oral consent is NOT considered proof.
  • Providing a method for your customers to provide permission or opt out, and maintain that information as well.  This is especially important as data can be used “behind the scenes” for profiling purposes.
  • Noticing that there are some similarities between GDPR and the United States’ Health Insurance Portability and Accountability Act (HIPAA) data rules for Protected Health Information (PHI.)  If your organization already deals with HIPAA, you undoubtedly already have some procedures for handling PII.  However, GDPR is much more far-reaching so your existing processes will require review and revision.      

More specific guidelines are contained within the GDPR articles.  As you obtain consent and add controls in your systems to secure data, be proactive and contact your mailing list to indicate your organization’s commitment to and compliance with GDPR. 

Trillium has significant experience in privacy, cybersecurity, as well as process and procedure mapping and implementation.  We can assist your organization in determining your level of risk related to GDPR consent, what you can do to obtain and prove consent, and what your path forward should be.

GDPR is here – are you compliant?

GDPR is here – are you compliant?

General Data Protection Regulation (GDPR) is a legal set of guidelines for the collection and processing of personal information within the European Union (EU,) and is scheduled to come into effect on May 25, 2018.  GDPR rules impact companies, government agencies, non-profits, and any other organizations that offer goods and services to people in the European Union (EU), or collect and analyze personal data tied to EU residents, and failure to comply can result in financial penalties or prohibition on data collection.  One way to view GDPR is like the Health Insurance Portability and Accountability Act (HIPAA) data rules for Protected Health Information (PHI), only for other organizations that collect personally identifiable information (PII.)    GDPR is applicable regardless of where your company is located – including the United States.    

If your organization does business with the EU and collects or uses personal data in an automated manner, here are some of the key issues/ concerns you need to be aware of.  They include:

  • PII must be protected prior to being processed, so that PII can’t readily be attributable to an individual
  • Where PII is routinely used, such as in human resource records, it must be protected so that it cannot be identified
  • Where data is aggregated for warehousing, that data must be protected from identification, which may minimize the amount of data that organizations collect to only that which is pertinent to complete a specific transaction  
  • Organizations must keep records of their compliance and demonstrate such compliance to regulators
  • Organizations are required to notify supervising authorities about data breaches and must document the incident, its impacts, and actions taken to remediate the breach
  • Depending on the type and size of the organization, a Data Protection Officer may be required

While GDPR was passed in 2016, it is still a work in progress, and regulations and processes will likely be clarified to meet the demands of the regulations.  However, it does mean that your organization needs to be vigilant and ready to minimize any penalties.

Trillium has significant experience in privacy and cybersecurity, and can assist your organization in determining whether GDPR impacts your organization, and what may be required to bring you into compliance.  

How do I Secure my Cloud Services?

How do I Secure my Cloud Services?

With the growth of Cloud Services, including Software-as-a-Service (SaaS), Platform-as-a-Service (PaaS), and Infrastructure-as-a-Service (IaaS) solutions, your organization needs to be cognizant of what is involved with their use and what security in these environments means.  

SaaS is the Cloud-based service that consumes the entire operation – specific application(s) that are hosted by a third-party provider, available over the Internet.    PaaS provides the platform, allowing customers to develop, run, and manage applications without having to build and maintain the attendant infrastructure.  IaaS typically only provides infrastructure, including hardware, storage, and data center space to support the enterprise, with the customer directing the applications and operations.  

IDC estimates that in 2018 Cloud computing will be at least 50% of all IT spending, with additional growth to 60-70% by 2020.   However, with that growth additional security vulnerabilities will be uncovered, potentially exposing your organization.  Recently, a survey of security professionals indicated that one-third (1/3) of breaches affected more than one-half (1/2) of systems.  You simply cannot dismiss security concerns once you make the decision to go with a cloud-based solution. 

So, what is being done?  Cloud providers are beginning to be work directly with security solution providers to address customer concerns and implement end-to-end measures, such as Rackspace’s recent partnership with Cisco to deploy next-generation firewalls directly into its services.  Further, according to Cisco, in addition to traditional security tools, tools such as Machine Learning (ML) and Artificial Intelligence (AI) are maturing.  Tools like AWS Guardduty and AWS Macie are now being used within the enterprise.  It is imperative that as you develop relationships with Cloud providers, you understand their security roadmaps so you can make informed security decisions for your company. 

Also, there is a major security skills shortage and using an ‘automation first’ agile approach to security reduces the operational load on security, leverages automation learnings across multiple environments and provides economies of scale savings by utilizing scarce resources in a shared model.

Being acutely aware of your Cloud-based security risks, issues, and potential mitigation strategies will help your company to protect your data and electronic assets.

How do Artificial Intelligence (AI) and Machine Learning (ML) help in Cybersecurity?

How do Artificial Intelligence (AI) and Machine Learning (ML) help in Cybersecurity?

If you are running a business or an Information Technology operation, one of the biggest and most pervasive issues you deal with daily is cybersecurity.  In conjunction with security systems, Artificial Intelligence (AI) and Machine Learning (ML) are being used to protect against cyber-attacks.  A simple definition of AI in the cybersecurity context is the ability to program the identification and mitigation of attacks, alerting security staff to issues as needed.  This can help “free up” your employees for more fruitful and less repetitive security activities.  ML, a type of AI, in the cybersecurity context allows systems to identify anomalies. There are 2 types of ML – Supervised ML uses a pre-defined set of data examples to reach a conclusion, whereas Unsupervised ML finds patterns and relationships without examples from which to draw conclusions. 

It is projected that AI algorithms using ML will make it simpler to respond to cybersecurity risks, because these solutions will use ML data from prior cyber-attacks to adapt and identify similar risks, effectively “learning” behaviors in a standardized way.  Additionally, as attacks become more sophisticated, conventional cybersecurity protocols will be less and less effective. 

However, since security tools are only as good as the last successful attack, intrusions and intruders will continue to become more sophisticated.  To further complicate the issue, it is anticipated that AI and ML will also be used to conduct attacks, or “adversarial machine learning,” versus only being used as protection against attacks. 

Considering the current cybersecurity workforce shortage, estimated to grow to 3.5 million worldwide by 2021, your business will have to rely more on AI and ML solutions in conjunction with your own staff.

It is critical that your business stays vigilant in efforts to identify and mitigate cyber-attacks so your systems, data, and infrastructure remain as secure as possible.  Keeping your eyes open about both the benefits and issues surrounding AI and ML will allow you to view these emerging technologies in the cybersecurity space realistically.