So You Want to be Forgotten?

There is a good write-up on discussions The Right to be Forgotten (RTBF) following the ruling at: Debate Write-Up: Rewriting History.

Christopher Graham the Information Commissioner gives a good explanation of what it really means, but unfortunately it is lost in the panicked crys of other participants in the debate.

It is very straight-forward: There is claimed to be a the conflict between the Freedom of Speech and Personal Privacy, i.e. in this case the RTBF. However there is not, it is as Graham states:

1) There are two types of parties here: a) the data controller, and b) the journalist;
2) The ruling pertains to the data controller the RTBF, not journalists, so in UK for example, this does not impact s.32 of the Data Protection Act;
3) Just that the search results are not returned by the search engine of the data controller, does not mean that the data does not exist. It is just that is is not searchable;
4) This information pertaining to an individual is still on the website of the newspapers, and should be searchable directly on the website.

So this cannot be likened to ‘burning of books’ or ‘re-writing history’ as in George Orwell’s 1984. It basically means that if, for example an individual defrauded the Inland Revenue 10 years ago:

– If you search for this person by name, it will not return this name in the result;

– However if you search for ‘Inland Revenue fraud’ it could return this person’s name in one of the related articles.

What I see is that the main challenge is from a technical perspective. At the moment the onus is on the data controllers to receive requests, to decide if the requester has a valid request for removal from their search engines. However, I believe that this should be done as default by websites of newspapers. This could be difficult because on a technical level it is only possible, that I am aware of today, to exclude whole webpages from Google, not names or specific words.

Re-thinking Information SECURITY

I love ticking boxes, makes me feel as though I’ve achieved something. Each tick-box is a step closer to completing my list of ‘things to do’. It’s kind of satisfying. It is even more so when I get paid a good hourly fee for ticking boxes 😉

Okay, so I’m joking a little. Preparing an organisation for ISO2700x certification is a little more complex than purely completing a checklist. Yet, however simple or complex it is, even when your organisation passes its audit, it does not prove it is secure. It does prove that you tried your best, i.e. demonstrated ‘due diligence’. Then if something does go terribly wrong, i.e. one of your user accounts is used to hack into the organisation, that if made public can ruin your business. Well you tried your best within the boundaries of your capabilities, so I guess that’s okay? Or is it? I guess not, if you go out of business, or end up spending the subsequent 12 months in a crisis mitigation mode!

The problem as I see it is multidimensional and not limited to this list:

1. Reactive security – We are so focused on doing the security stuff that we understand, i.e. ticking boxes, doing just enough to get compliant, that we don’t get to the core of the problem.

2. Product-focused security – Even if we think it can be solved with a product, there are so many security product vendors out there touting the ‘magic bullet’, nobody knows who or what to believe anymore.

3. Mis-alignment of security spend with LoB – Every security product implemented often does not address the fundamental business need. Evidence of this is when new security products/services come out of the IT budget, not from the Line of Business (LoB)

4. BandAid security – Due to point (3), lack of LoB ownership for security spend means no sponsorship. This can result that even if security spend is approved, e.g. security mitigation effort needed to meet compliance requirements, the effort can be likened to a ‘BandAid’ approach to fixing what needs fixing.

5. Non-contigious defense-in-depth security – Due to all of the above your security infrastructure is not contiguous. The ‘defense-in-depth’ approach to your security programme recommended by security experts maybe deep, but full of holes.

6. Information that moves – Our digitised society has changed the parameters on how we should be doing security, however in our organisations we are still thinking as though information is static and can be contained. It cannot.

Fixing all of the above is pretty daunting, and it has become generally acknowledged today that no way can it be guaranteed that the confidentiality and integrity of information assets owned by your organisation are fully protected. So what’s my view on this?

Well it is fun ticking boxes, and I’ve made a lot of money during my career in this activity. But I guess you’ve figured that I feel that it is not quite as satisfying as I made out at the beginning of this post. To try and simplify things I see roughly 2 tracks in my head. The first is business security, and the linkage from business needs right through to scoping. The second is how to do this from a technology perspective, and this I’ve grouped as: people-centric, device-centric, and information-centric.This is to reflect the fluid nature of information today, that cannot be contained by building a fortress around it.

BUSINESS Security

B1. LoB – What is the need? Firstly security needs and spend must come direct from the LoB. They know best their business, and know what needs protecting more than I do as the security expert and your IT department. The most important question to be asked is: 1) “What can ruin your business?”; 2) and, “What do you need to be compliant with?”.

Clearly security spend should be commiserate with what you want to achieve. For example if a vendor wants to sell you a DLP product across your whole company, think twice, and ask this question what is it needed for (to protect from ruin, or to be compliant)?

B2. Keep it small – Take one business process at a time and fix it using the following 3 principles.

TECHNICAL Security

T1.People-centric security – How we do identity control today is the weakest link in the security chain. I call it identity control not identity management, because it is about control and traceability. I will write more about this over the next weeks. For your organisation, and for the identity holders. Your organisation and your employees are continually a part of digital interactions, and all of those that you share together, belong to your organisation!

T2. Device-centric security – Take a look at what the Trusted Computing Group is doing with the chip. I normally refer it to putting “security at the ‘chip’ level”. This is not technically accurate, but it confers a meaning around that the security is at the microprocessor level of the device rather than at the Application layer. If you liken it to a house, it means that you have walled in all your windows (Application layer), and the only way in is through the door (ground-level) with high-level security controls linked intimately to your digital identity -that of course follows the people-centric approach to identity control 😉

T3. Information-centric security – This is all about protecting and adding traceability to your information, wherever it is stored. Examples include your mobile workforce and their mobile devices. Then where is your critical information when at rest, in a public or shared cloud? Well this information should be encrypted using a key-fragment approach. This means, 1) your cloud provider cannot see the contents of your information in the cloud, 2) you hold the key, and 3) a fragment must be collected from a key-fragment central store, that could be owned by yourself, so you have traceability on who is accessing what information in the cloud through key-access patterns.

Now that I’ve finished with my little ‘brain-dump’ on you guys, I guess I should get back to earning some money and ticking boxes 😉