Shifting from an “outside-in” to an “inside-out” security strategy enables an organization to adapt readily to an ever-changing regulatory landscape – despite resource constraints. Optiv’s John Clark discusses.
The adoption of the General Data Protection Regulation (GDPR) in April 2016 initiated a worldwide debate over consumer data privacy rights and regulations. More than three years later and 18 months since GDPR’s enactment on May 25, 2018, and data privacy is still an issue dominating discussions at the consumer, corporate and political levels.
In the U.S., states have spearheaded the data privacy movement, but we’re starting to see activity at the federal level as well, with Congress investigating ways to implement a national data privacy standard. Perhaps the most well-known state law is the California Consumer Privacy Act (CCPA), which will go into effect in 2020. The CCPA, which adopts many of the same principles as GDPR, is on track to become the nation’s most comprehensive data privacy act. Taking California’s lead, other states (such as Nevada and Maine) have also introduced their own privacy regulation.
While new legislation is necessary to advance consumers’ privacy rights, it also adds to the already extensive list of federal, state and industry data protection laws by which companies must abide. Which begs the question: Would corporate compliance officers and security teams prefer a single, comprehensive privacy regulation rather than trying to comply with numerous more targeted regulations?
Optiv Security recently released its “State of the CISO” research report, which asked a very similar question to 100 U.S. CISOs or senior security personnel with equivalent responsibilities. When asked what impact a GDPR-like regulation would have on their business, more than half of survey respondents (57 percent) said they believe having one privacy law across industries and states would mean fewer individual regulations to track. Additionally, 19 percent of respondents stated that their company is close to being or already is GDPR compliant, so complying with a law of this nature would not be a major undertaking. Only 24 percent said they believe this kind of nationwide regulation would be too expensive and complicated to implement.
Also of note, Optiv’s State of the CISO survey asked respondents if it would be worthwhile to have a global agreement on cybersecurity, similar to the Geneva Convention, where countries agree to a set of principles governing their conduct on the internet. A whopping 88 percent said yes, it would set guardrails for acceptable online activities and decrease damaging behavior. Only 12 percent said no, because even if you could get offending countries to sign the treaty, they would break it.
While these survey results demonstrate that many security professionals would prefer to follow one comprehensive national or global data privacy law, the reality today is that organizations are on the hook to abide by a multitude of state, federal and industry data protection regulations. And, for many companies, this is a tough task – especially with today’s complex IT infrastructures and severe cybersecurity skills shortage.
Simplifying compliance despite dynamic infrastructures, limited security resources and ever-evolving regulations is possible. It just requires a change in security strategy, from “outside-in” to “inside-out.” Let me explain.
Many organizations are operating with an “outside-in” security model, which allows external threats and compliance mandates to dictate security strategy and spend. From a compliance perspective, this means companies are often treating the latest and greatest regulation as their entire security framework. In other words, companies will focus all of their efforts on making sure they are compliant with a single mandate or law while neglecting the broader risk environment. This introduces compliance gaps in other areas of the business and leaves the organization vulnerable to data breaches. Individual compliance regulations and laws are not designed to be a complete security framework and should not be treated as such (in fact, sometimes regulations do not use security best practices in their mandates, which actually puts security and compliance at odds).
Rather than letting the external threat and compliance landscape dictate security strategy and spend, organizations would be better served adopting an “inside-out” approach to security and compliance, where business-specific risk and business objectives dictate the security framework. This model starts with a comprehensive risk assessment, which includes a compliance gap analysis, along with an evaluation of the data and assets that are most likely to be targeted, who is most likely to target them and how they are likely to do it. Based on the assessment findings, security and compliance teams can develop a strategic security strategy based on their organization’s unique risk profile.
Because inside-out puts the focus on the organization’s unique business risk rather than one particular regulation or threat, security and compliance teams can prioritize risk and make intelligent decisions around infrastructure, technology and operations. This means organizations can streamline their environments, implement stronger security processes and ensure compliance with relevant regulations.
A Single Strategy for Managing Many Mandates
The data privacy issue isn’t going away anytime soon, and we’re likely to see continued legislative activity at both the state and federal levels. The beauty of adopting an inside-out security model is that it no longer matters how the compliance environment changes, because regulations will become a subset of the overall security strategy and architecture. This makes organizations more agile, secure and compliant – and that delivers tremendous benefits to companies and their customers alike.