Sunday, 5 March 2017

The General Data Protection Regulation (GDPR) need to knows

In January 2012, the European Commission proposed a comprehensive reform of data protection rules in the EU. On 4 May 2016, the official texts of the Regulation and the Directive have been published in the EU Official Journal in all the official languages. While the Regulation will enter into force on 24 May 2016, it shall apply from 25 May 2018. The Directive enters into force on 5 May 2016 and EU Member States have to transpose it into their national law by 6 May 2018.




So what does the above mean for everyone? Well for every business big or small handling data on European citizens it means much stricter rules backed up by heavy fines for non compliance and carelessness around the processing, handling and storage of data. And when I say big fine I mean BIG fines 4% of your annual turnover or 20 million depending on which is greater. So if your a big offender on the data front you have approx 1 year to get your s**t together. 

So what are the key points for Business I hear you ask? Well lets go through them with this lovely breakdown from EUGDPR.

Increased Territorial Scope (extra-territorial applicability)Arguably the biggest change to the regulatory landscape of data privacy comes with the extended jurisdiction of the GDPR, as it applies to all companies processing the personal data of data subjects residing in the Union, regardless of the company’s location. Previously, territorial applicability of the directive was ambiguous and referred to data process 'in context of an establishment'. This topic has arisen in a number of high profile court cases. GPDR makes its applicability very clear - it will apply to the processing of personal data by controllers and processors in the EU, regardless of whether the processing takes place in the EU or not. The GDPR will also apply to the processing of personal data of data subjects in the EU by a controller or processor not established in the EU, where the activities relate to: offering goods or services to EU citizens (irrespective of whether payment is required) and the monitoring of behaviour that takes place within the EU. Non-Eu businesses processing the data of EU citizens will also have to appoint a representative in the EU. 

PenaltiesUnder GDPR organizations in breach of GDPR can be fined up to 4% of annual global turnover or €20 Million (whichever is greater). This is the maximum fine that can be imposed for the most serious infringements e.g.not having sufficient customer consent to process data or violating the core of Privacy by Design concepts. There is a tiered approach to fines e.g. a company can be fined 2% for not having their records in order (article 28), not notifying the supervising authority and data subject about a breach or not conducting impact assessment. It is important to note that these rules apply to both controllers and processors -- meaning 'clouds' will not be exempt from GDPR enforcement.

ConsentThe conditions for consent have been strengthened, and companies will no longer be able to use long illegible terms and conditions full of legalese, as the request for consent must be given in an intelligible and easily accessible form, with the purpose for data processing attached to that consent. Consent must be clear and distinguishable from other matters and provided in an intelligible and easily accessible form, using clear and plain language. It must be as easy to withdraw consent as it is to give it.​


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The best part of all from this new regulation is the Data subject rights which are going to become a real pain in the ass for companies. And I personally will be keen to watch how some of the more demanding requests will be processed by business especially the beautiful new "Right to be Forgotten".


Data Subject Rights
Breach Notification

Under the GDPR, breach notification will become mandatory in all member states where a data breach is likely to “result in a risk for the rights and freedoms of individuals”. This must be done within 72 hours of first having become aware of the breach. Data processors will also be required to notify their customers, the controllers, “without undue delay” after first becoming aware of a data breach. 

Right to AccessPart of the expanded rights of data subjects outlined by the GDPR is the right for data subjects to obtain from the data controller confirmation as to whether or not personal data concerning them is being processed, where and for what purpose. Further, the controller shall provide a copy of the personal data, free of charge, in an electronic fromat. This change is a dramatic shift to data transparency and empowerment of data subjects.

Right to be ForgottenAlso known as Data Erasure, the right to be forgotten entitles the data subject to have the data controller erase his/her personal data, cease further dissemination of the data, and potentially have third parties halt processing of the data. The conditions for erasure, as outlined in article 17, include the data no longer being relevant to original purposes for processing, or a data subjects withdrawing consent. It should also be noted that this right requires controllers to compare the subjects' rights to "the public interest in the availability of the data" when considering such requests.

Data Portability

GDPR introduces data portability - the right for a data subject to receive the personal data concerning them, which they have previously provided in a 'commonly use and machine readable format' and have the right to transmit that data to another controller.

Privacy by Design

Privacy by design as a concept has existed for years now, but it is only just becoming part of a legal requirement with the GDPR. At it’s core, privacy by design calls for the inclusion of data protection from the onset of the designing of systems, rather than an addition. More specifically - 'The controller shall..implement appropriate technical and organisational measures..in an effective way.. in order to meet the requirements of this Regulation and protect the rights of data subjects'. Article 23 calls for controllers to hold and process only the data absolutely necessary for the completion of its duties (data minimisation), as well as limiting the access to personal data to those needing to act out the processing.

Data Protection Officers

Currently, controllers are required to notify their data processing activities with local DPAs, which, for multinationals, can be a bureaucratic nightmare with most Member States having different notification requirements. Under GDPR it will not be necessary to submit notifications / registrations to each local DPA of data processing activities, nor will it be a requirement to notify / obtain approval for transfers based on the Model Contract Clauses (MCCs). Instead, there will be internal record keeping requirements, as further explained below, and DPO appointment will be mandatory only for those controllers and processors whose core activities consist of processing operations which require regular and systematic monitoring of data subjects on a large scale or of special categories of data or data relating to criminal convictions and offences. Importantly, the DPO:

  • Must be appointed on the basis of professional qualities and, in particular, expert knowledge on data protection law and practices
  • May be a staff member or an external service provider
  • Contact details must be provided to the relevant DPA
  • Must be provided with appropriate resources to carry out their tasks and maintain their expert knowledge
  • Must report directly to the highest level of management
  • Must not carry out any other tasks that could results in a conflict of interest.​

Thursday, 16 February 2017

Security Meets Cost

I was recently asked by a small business how could they secure their IT on a budget this made me stop to think about that tricky subject "security meets cost". It is in these terms that a business must be practical, you need to stand back and identify your actual financial loss were a cyber attack or unforeseen event to occur resulting in the loss of data. And to be quite honest if your spending thousands on perimeter controls and don't have anyone in your business who can properly configure, monitor and maintain these devices then your really just throwing money down the drain.



After going through the business I advised them to put in place a number of steps that would go a long way towards protecting them. It must be noted that the business in question did not deal with any payments card information (PCI), personally identifiable information (PII) or personal health information (PHI) if your business is dealing with the above then you will need to put more controls in place.

My plan for the business was pretty simple and I will lay it out below.

1) Education:
This is one of the fundamental roles that small businesses neglect, there are hundreds of services out there that will do training days on different areas in an easy to understand and education manner. If you can train staff to identify Phising, Smishing and other everyday threats then you are starting to win a war on the front line. Education helps get employees to think before opening an attachment or giving out "harmless" information over the phone. For the more adventures small business there are packages available for you to run harmless attacks that contain educational videos when clicked. PhishMe would be one such company that comes to mind in that regard.

2) Backups:
This one is quite simple but often forgotten, with the rise of ransomware every small business should keep daily or weekly backups. These backups should be occasionally tested to ensure that they can restore systems in the event of an emergency such as a ransomware infection.

3) Business Continuity Plan:
 Every business should have one and should test it, you can work on building this up over a period of time but you need to start somewhere. EG. if the building floods are our desktops on the floor? Maybe we should elevate them to mitigate this problem. During this flood do employee have the ability to work from home? Yes we have remote access to the building over our companies VPN.

The above are just suggestions but you get the drift if you start to disect your company and compare it to potential events you might be surprised what you come up with. Fail to prepare then prepare to fail.

4) Virus and Anti- malware protection:
Again this is simple but neglected in many small businesses, buy a good antivirus and anti-malware package and set the updates to times you know your employees wont shut them down eg lunch time or after working hours. A good antivirus and malware solution is like having a security guard in your network throwing out all the bad guys.


5) Enable Bit-locker or the equivalent:
Bit-locker encrypts your disk so if someone breaks in and robs your physical machine in theory bit-locker will keep that information safe, unless of course the thief is Homeland security or the equivalent in which case your data is the least of your worries.

6) Password Policy:
Put in place a robust password policy that includes the rotation of passwords regularly and password history check to prevent the re-use of passwords.

7) Third party checks:
If you are using a third party to store data or to provide remote support ask them to provide you with a list of controls that are in place to protect you from a security point of view. If they tell you they are super secure and you need to trust them get worried because this means they haven't got anything to give you and your cloud solution is some guy with a laptop and 15 housemates that use it to stream illegal movies.

8) Document everything!
You should document all of your procedures and workflows because if one guy has all this information and gets hit by a bus your knowledge is dead. Good documentation is key to smooth transition and helps aid security through clarity.



If you get all the above in order you will have made a decent move towards securing your business at a minimal cost, of course there is plenty of room to do more but the hardest part is always to make a start.

Wednesday, 13 July 2016

Pokemon Go grants itself "full access" to your Google account






"See and modify nearly all information in your Google Account (but it can't change your password, delete your account, or pay with Google Wallet on your behalf)."
What exactly this means is quite unclear, but Reeve claimed that the Nintendo's Pokémon GO – developed by Niantic – can now:
  • Read all your email.
  • Send email on your behalf.
  • Access your Google Drive documents (including deleting them).
  • Look at your search history as well as Maps navigation history.
  • Access your private photos stored in Google Photos.
  • And a whole lot more.
Although Reeve, who reported the issue on his Tumblr blog, said this issue appears to mostly affect iOS users, some Android users are reporting that their devices are also being affected.



  1. Head onto your Google account permission page and look for Pokémon GO.
  2. Select Pokémon GO Release and click "REMOVE" button to revoke full account access.
  3. Launch Pokémon GO on your device and confirm it still works.
This will immediately revoke the Pokémon GO app's access to your Google account, but the downside is that users may lose their game data.

Friday, 8 July 2016

Hackers can use smart watch motion sensors to steal your ATM pin

As you constantly add the latest gadgets to your daily life be it fitness trackers, smart watches, timed networked heating, networked toasters etc.. do you ever stop to think that with such convince also comes risk? Well I can safely tell you that the more connected you become the wider you make the threat surface that is your personal security.






Thursday, 30 June 2016

Find out how much Google knows about you using "My Activity" Dashboard



It is widely understood that Google as a company holds masses of information on the majority of us. If you have ever wanted to know just how much information Google knows about you this is now possible.





Tuesday, 21 June 2016

Citrix's GoToMyPc users exposed after password leak



If you are a user of Citrix's GoToMyPC unfortunately you will have to reset your passwords (use something long varied and strong, don't reuse an old password!).

The service, which lets users remotely access PCs over the internet, was hit by a "very sophisticated password attack," Citrix said Sunday in a blog post. The company is requiring users to reset their passwords using the "forgot password" link. This is just another hack in a long line that have been disclosed in the past few weeks as hackers seem to be targeting website with huge user databases in an attempt to reap the rewards of cybercrime.

"Citrix takes the safety and security of its customers very seriously, and is aware of the password attack on GoToMyPC," said John Bennett, product line director at Citrix, in a statement. "Once Citrix learned about the attack, it took immediate action to protect customers. Citrix can confirm the recent incident was a password re-use attack, where attackers used usernames and passwords leaked from other websites to access the accounts of GoToMyPC users. Further, there is no indication of compromise to any other Citrix product line."

To reset your GoToMyPC password, go to the site and click on the Log In link.
I would recommend along with resetting your password that you enable two-step verification, a process that sends a code to your phone each time you want to sign in. If you've used the same password for GoToMyPC at other websites or for other accounts, you should change it at those places as well and don't make up a new password and use it on your other sites to, not that you would do such a thing.

Wednesday, 15 June 2016

Ransomware now targets Smart TV's


And the saga continues...... just when you thought it couldn't get any worse some ass just created a strain of ransomware that can infect Smart Tv's. Lets set the mood, you come home from a stressful day at the office get some dinner and sit down to watch your favorite channel to discover a message demanding bitcoin to gain access to your Tv, now I'm guessing that will put you in great form for the evening. Thanks to a new version of the Frantic Locker (better known as FLocker) Ransomware has now the ability to infect and lock down your Smart TVs until you pay up the ransom making the above scenario much more realistic.


Researchers at Trend Micro have discovered the updated version of FLocker that is capable of locking Android smartphones as well as Smart TVs. Originally launched in May 2015, the FLocker ransomware initially targeted Android smartphones with its developers constantly updating the ransomware and adding support for new Android system changes. So what exactly does Smart Tv locking ransomware do ? is it the same as the other nasty laptop/desktop strains ? Well the answer to those questions is yes and no. 
  • FLocker locks the device's screen.
  • Displays a fake notice from United States Cyber Police or other law enforcement agency, accusing potential victims of crimes they did not commit.
  • Demands $200 worth of iTunes gift card as Ransom to unlock the infected TV.
Trend Micro says the malware is configured to deactivate itself in some regions including Russia, Bulgaria, Hungary, Ukraine, Georgia, Kazakhstan, Azerbaijan, Armenia, and Belarus.
However, if FLocker detects devices outside these countries, the malware will wait for 30 minutes before requesting admin privileges for the device. If the victim rejects the request, FLocker freezes the screen, faking a system update.