The security processes and controls you put in place must meet the compliance standards required for your industry. Whether it’s GDPR, CCPA, or any other state, federal, or industry specific regulation, there are at least three things you need to do to meet the minimum requirements. Of course, each regulation comes with its unique conditions, but these are the first steps to take when moving toward a more secure and compliant environment.
1. Data discovery and data mapping
Most of the compliance standards today surround the data an organization collects from consumers. The first step to understanding your data, for both compliance and to inform decision making, is to collect and analyze all of your data from the various sources it originates. In addition to data discovery, you need to have a process for data mapping as well. Data mapping matches the data fields of data from one database to another.
It’s important to have data flows so you know how your data gets to you, how it’s entered into various systems, what resources it hits, and where it finally ends up. Knowing, at every point, were your data lives is the key first step, regardless of which law you need to comply with.
A strict tagging strategy that is uniform and specific across departments aids in ongoing data mapping. Review your strategy regularly to make sure your teams are following it and it still works as expected with any advancements made in the data you’re collecting. You can also use the tools available through cloud providers to help with these governance tasks. Some recommended tools include Amazon Macie and AWS Config, as well as Azure Security Center.
2. Notification and purge mechanisms with identity validation and an audit trail
A person’s data belongs to them, regardless of which company holds it. In order to field data requests from consumers, you need to have some sort of notification mechanism that allows you to understand and deliver what the consumer wants. They may want to know what data you have and how it is being used. People may want to update inaccurate data or, depending on the regulations in your area, they may request that it be deleted.
In order to fulfil a consumer’s request to delete or update data, you need a purge mechanism. A purge mechanism clears data once such action has been approved. In order to complete any data request, you must first validate the identity of the requesting consumer.
While this step is necessary, there is not yet an industry gold standard on how best to verify data without threatening the personal information provided. Additionally, data requests need to be checked against any compliance exceptions that may complicate your ability to do what the consumer wants. You may need the data because the person is still using your services, or, depending on the compliance standards you adhere to, you may be required to maintain certain pieces of data for a set period of time.
Meeting consumer requests for data management can be tricky depending on the compliance standards in your location and industry. A proper audit trail that proves your best attempt at compliance is critical, should a lawsuit or formal complaint ever come your way. Hopefully all of these processes will be automated through machine learning one day, but for now, notification and purge mechanisms, identity validation, and a comprehensive audit trail are the most important factors in proving compliance.
Data is the life blood of most organizations and it needs to be protected. Simply put, encrypt everything! Additionally, make sure your identity and access management (IAM) policies are up to date. The most common vulnerabilities are problems with an organization’s IAM. There might be an abundance of keys spread across the business or keys might not have been rotated regularly. Unauthorized employees might have admin credentials, or there’s no incident response policy in place.
If your data is breached, either by cyber attack or human error, you need a process to get servers back up and running again as soon as possible. You also need to preserve the evidence of the attack, or accidental deletion, in order to prevent a recurrence. Don’t assume your data is safe, instead, be ready to quickly recover from data loss.
While these three necessities are required for most compliance standards, there are certainly more you need to be following. Let 2nd Watch provide a prescriptive security roadmap to ensure compliance no matter where your business is going. You can also take advantage of our four-phased security assessment that runs an automatic skim of your environment to identify vulnerabilities. Contact Us to make sure the next step you take in your cloud journey is a compliant one.
-Chris Garvey, EVP of Product