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Data Sovereignty; Qualifying Data Transactions.
Rimesh Patel CEng
What it means for Cyber Security.
Demonstrating how data processing principles effect your security controls for physical and virtual activities will give your products and services a sense of data ownership, responsibility and accountability - especially if you are using frameworks that help the mapping of security controls to regulatory concepts.
For consumers, controls should be transparent so once engaged with, they inherently satisfy confidentiality, integrity and availability functions.
For businesses, being aware of your data categories and how they are prioritised alongside core services will let you naturally satisfy confidentiality, integrity and availability considerations by making sure your security postures have the correct risk mechanisms in place letting you enterprise your data strategy with sovereignty in mind.
To be sovereign, your data strategy has to better clarify the scope of territorial data and how local governance is to be satisfied for any region. Only then can swifter indigenous transaction gateway points allow you to up sell globally - or vice versa.
Where if you are using gateway solutions, it is your responsibility to know where the data processing takes place and not only just risk assessing where server exists - you need to define why the transaction needs data to be processed by that gateway for the consumer, business and enterprise. Do your third-party specialists really need to process all that data through their international processing affiliations? How do their aggregate activities effect your data processing?
A good starting point is to define what do 'digital transactions' mean within your industry;
Hospitality.
Legal.
Accountancy.
Arts & Entertainments.
Marketing.
Logistical.
GP, Dental or Medical Services.
Once your industry trends are known, look at regional and local regulation bodies, how do they advise on data sovereignty, which data points consider functional and non-functional representation on how your data is processed within a typical defined aggregate transaction. This gives more clarity to your data categories, which will help you identify where are your sensitive data points really exist that primarily need to have risk controls applied, especially if your gateway is both your business controller or processor.
More importantly, does your DPO agree with the synthesised processing that might take place? Of course, if your DPO has taken a security by design approach then how are they assuring it works? For example, does you framework controls transcend through every local, regional, national and international transaction? How have you empowered the DPO to work with all transaction points? What options are provided for the data territory to demonstrate enforceable safeguards and adequacy decision process for effective legal adherence.
Is feeding into your risk register sufficiently going to meet the requirements for insurance mechanisms, and how will your operations team be able to promote cyber resilience activities - they need to implement the polices right ? You need to demonstrate uniform data usage across all boundaries that filter down for practical implementation i.e. backup mechanisms required for data residency, or how critical mass data needs are served through the policies.
The finance and legal executives will then want to know about how the data concepts and controls effect the international data waivers, pacts and privacy laws - what data strategy is in place for them to do their function for the business? If you are using DPIA's, BIA's and GDPR related questionnaires, how are the results assured?
SAIBER Ltd has Chartered Assurance Packages available which provide independent qualified assurance, audit and advisory services. Our other packages assist your understanding of data processing principals including data architecture and migration so that your data privacy and data security efforts can demonstrate your ability to keep your territorial data sovereign and more importantly make it easier for others to interact with your business.
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Telemetry is a concept used within communications systems, whether physical or digital that provides remote measurements. For your security staff, it means during an incident response they remain less disenfranchised on the severity of an actual incident. For the business it means during an incident the managers are less disenchanted on what factors to consider when trying to uphold a security policy, and for the industry, it allows us to share security operations data with others in a cleaner way - as we would have specified, using telemetry data, how an incident should be triaged. Combining these methods will not only keep your security operations teams better informed, but also let you increase your security posture throughout the organisation and technology estate - so as you move towards 5G, Cloud services, IoT or other Hybrid systems, you still have the ability to know what to monitor. Network Operations Centers typically use telemetry for performance and capacity bandwidth monitoring and now with the many next gen style non-perimeter-based integration points, the same concepts can be used to enhance security postures for different departmental technologies. Your organisations internal and external activities are likely to be complemented with the below business functions, and it's here that telemetry can enhance data quality ; SMART sensors and ecosystems Security Engineering Solution Design Quality Assurance Spatial Intelligence Object Orientated DevOp Methods Departmental Data Business Workflows Commonly associated with Telemetry are Metrics, Events, Logs and Traces (MELT). Your overall business process that uses technology components should be able to produce basic MELT data - it's this data that will help you gain better efficiencies, and from a security perspective, it is likely here that indicators of compromise (IOC) or indicators of attack (IOA) can be better considered for behavioural analysis and anomalous activity detection. What data will you need to validate that an IOC or IOA has affected your security operations policies, how can that data map to industry cyber categories within the Mitre Attack or Cyber Kill Chain models. These models typically feed off vendor logs; however, you can significantly enhance how these models enhance business resilience through better incident response and management activities - even automation efforts as they allow you to introduce a 'control signal' though the chain of command by a specific MELT ensemble. The combination of telemetry with your own technology platforms can let you compliment your organisations security policies, so when you get an alert, its already qualified. SAIBER Ltd's SME Solutions Package will consider vantage points like these to give you the best security posture you can have. #RUCyberReady