When it comes to data, security and compliance go hand in hand. Due to data privacy regulations such as the GDPR (the EU’s General Data Protection Regulation), CCPA (California Consumer Privacy Act), and HIPAA (Health Insurance Portability and Accountability Act), almost every business with a global presence needs to meet some sort of compliance standards. To maintain compliance, you need strong data security measures in place, which is why you should tackle data security and compliance together as integrated processes.
How to Tackle Data Security and Compliance Standards
Here are some tips for developing a successful data security and compliance program.
Prepare for Data Subject Access Requests
Both the GDPR and the CCPA deal with the right to data portability, or a consumer’s right to access any personal information a business has about them and transfer that data to another provider at any time. A consumer can do this by making a data subject access request, or DSAR. If your business handles data about any users in the EU or California, you need to prepare for potential DSARs, because you have a limited amount of time to provide the requested data (45 days in California, and 30 days in the EU).
Establishing a standardized DSAR process is vital to meeting these tight deadlines. For example, there aren’t any official DSAR forms that you must use, so you can streamline the process for yourself and your customers by creating a simple PDF or web form and putting it up on your website. You also need a plan for how to identify and locate all consumer data upon request, which will likely require some form of data discovery and classification tool. This software can help you locate, tag, and organize your data across platforms so you don’t have to rely on the (often slower and less accurate) search indexers built into your systems and applications.
You also need to take the right to data portability into account when you implement your data security controls. Under the CCPA and GDPR, consumers can request the transfer of their data to a new platform in a common format (e.g. CSV or XML). If you’re the originating provider of that data, you’re responsible for encrypting it while in transit to keep it secure.
Implement Automated Compliance Testing
Even after you’ve implemented a data privacy and compliance program, you may find it difficult to sustain compliance long-term. A new third-party dependency may introduce a vulnerability you didn’t account for with your security controls, or staff may become complacent and slip back into poor data privacy habits, for instance. One way to ensure compliance sustainability is to implement automated compliance testing.
An automated compliance testing solution continuously monitors your systems and generates automatic alerts whenever a resource falls out of compliance. This allows you to remediate the issue immediately—and often automatically—preventing the violating resource and dependent systems from continuing to drift further out of compliance. Since some of these data privacy violations may be indicators of gaps in your security controls, an automated compliance testing program can also help you improve your overall data security and prevent potential breaches.
Create a Culture of Security and Compliance
While our people are our greatest resource, they’re also our greatest security risk. Human error is the most frequent cause of data security breaches, due to things like social engineering attacks that trick staff into giving out sensitive information, and negligent employees forgoing established security policies for the sake of convenience. The only way to keep human error from sabotaging your data security and compliance program is to create a culture of security within your organization.
You need comprehensive and continuous security training for all your staff, even those who don’t deal with sensitive data. Educate everyone from the executives to the front desk on common social engineering tactics, security best practices, and the basics of your applicable regulations. This training shouldn’t just happen once, either—staff should get regular refreshers, as well as updated guidance on new systems, policies, and regulations.
In addition, you should make it clear that data privacy and security are everyone’s responsibility, while still creating an open culture that doesn’t unduly punish questions or mistakes. Think about it: if an employee accidentally clicks on a phishing link or lets an unfamiliar vendor into a restricted area, you want them to feel comfortable telling someone right away so you can resolve the problem as soon as possible. If they’re worried about repercussions, they might try to hide the mistake, which could result in a breach going undetected for much longer.
Follow the Principle of Least Privilege
Building off the last point, if one of your user accounts is compromised through social engineering (or if a disgruntled employee conducts an insider attack), how much protected data would a hacker have access to with that account? Often, through poor policy management or simple laziness, our employees, service accounts, and applications are given access privileges far beyond what they actually need to perform their functions. The more unnecessary privileges an account has, the greater your attack surface if that account is compromised. Having a well documented, and hopefully automated, process for granting and revoking user's permissions means that the sooner you can revoke access in the event of a compromise, the better.
Following the principle of least privilege (or PoLP) strengthens your data security and compliance by limiting account and application access to only the necessities. This is important for regulations like HIPAA, which require that access to personal information be limited to authorized business purposes only. If you use PoLP, you’ll know that the only staff with access to HIPAA records are the ones who absolutely need it for business purposes, so you’ll essentially be compliant with this standard by default. The principle of least privilege also minimizes your attack surface, because all your network entities are heavily restricted in what resources they can access.
Tackling Data Security and Compliance Standards for Optimum Outcomes
By addressing data security and compliance together as an integrated strategy, you can improve your regulatory posture while optimizing security at the same time. Establishing a DSAR procedure, implementing automated compliance solutions, creating a culture of security and compliance within your organization, and following the principle of least privilege will ensure the success of your data security and compliance program. This holistic approach to data security and compliance is difficult to develop and implement overnight, but you don’t have to tackle it alone.