Privacy for Tech Startups: Key Principles and Practical Controls
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The document summarizes key points from a presentation on privacy for tech startups. It discusses why privacy is important for startups to consider, providing practical information security controls startups can implement, and new privacy principles from the GDPR that startups should be aware of. Some highlights include: - Privacy should be a priority from the start and can help startups win trust among users and investors. - Practical security controls include encrypting data, patching systems, training employees, and monitoring for vulnerabilities. - The GDPR introduces new principles like data protection by design, security of processing, breach notification requirements, data protection impact assessments, and data protection officers.
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Privacy for Tech Startups: Key Principles and Practical Controls
- 1. Privacy for Tech Startups Barcelona KnowledgeNet June, 18 - 2014 #iappbcn
- 2. IAPP Presentation •Marc Gallardo: Why is Privacy important for a Startup? •Jay Libove: Practical Information Security controls for Startups •Victor Roselló: New Privacy Principles for Startups PART 1: Keynotes •Marta Ruiz (Air Products) •Tiago Henrique (opscaling, gnuine) •Ferran Julià (Undertile) PART 2: Panel Q & A session Program
- 4. Founded in 2000 Over 15,000 members in 83 countries Largest privacy association in the world IAPP Europe – created to address the specific needs of European data protection professionals – counts almost 2,000 members IAPP
- 5. Members’ opportunities EDUCATE NETWORK CERTIFY
- 6. Educational resources IAPP publications keep members up to date on the latest privacy and data protection news worldwide.
- 7. Online community IAPP Privacy List Web Conferences Social Buzz Blogs and Website Resource Center Samples, Tools and Templates Privacy Research Career Center IAPP Articles and Presentations Privacy Glossary Data Protection Authorities Privacy Discussions
- 8. Connecting the industry More than a professional association, the IAPP provides a home for privacy professionals around the world to share experiences—working to promote career readiness and improve job effectiveness
- 9. Setting the industry standard IAPP certification is the global standard for privacy and data protection professionals. • Launched nearly 10 years ago, the CIPP has become the preeminent credential in the field of privacy and educates on privacy laws and regulations (variants /US, /E, /CA, /G) • The CIPM training demonstrates how to embed privacy into an organization through process and technology • The CIPT is the world’s only privacy certification designed for IT, security and engineering pros
- 10. Privacy for Tech Startups In short, think of privacy as a good opportunity to win trust among users and customers
- 11. Common attitude of startup founders Privacy and Data Security is usually not a priority from the start ! Respecting Privacy and safeguarding data is a core value and a trust enabler for your customers & investors
- 12. Privacy attitudes of consumers • The need to protect personal data online is a consumer priority against the benefits of convenient online services
- 13. EMC Privacy Index - June 12, 2014 15.000 consumers from 15 countries Three Paradoxes emerged: • “We want it all” • “Take no action” • “Social Sharing” Viewpoints on privacy vary by persona
- 14. Be proactive & go beyond compliance • Make privacy top of mind: consumers do care and investors are concerned • Know your data • Be fully transparent: - Simplify the language - Use ‘transparency statements’ - Do as your privacy notice says • Secure your data and train your people
- 16. Practical Information Security controls for Startups Or, how to get some useful Data Protection while helping your business …
- 17. Practical Approach to Privacy • We have a bad habit in Spain – DP viewed as legal exercise, not business enabler* – L.O.P.D. trailer on website is (not) enough • .. And as much as imitation is the sincerest form of flattery… • So, why would you bother? † • Focus on business: Do security and get compliance – Don’t do “compliance for compliance’s sake” – Do well with practical DP, and if/when you have a problem, you have some defence • Information Security is a part of Privacy/DP, necessary but not sufficient
- 18. Organizational • Don’t put privacy/DPO in your Legal department * • Make sure your outside counsel understands your business! ** • Do have an internal IT leader • Have department heads meet regularly, as a group, with your privacy leader (cross-pollenate disciplines) • Fund professional memberships and training/certifications (such as my CISSP, CIPP, CISM) †
- 19. Policies, Procedures* (philosophy) • Privacy by Default/ Privacy by Design (operationalize) • Privacy Impact Assessments (operationalize) • Limit your IT Footprint, & only buy what you’ll use • Re-Use, standardise – don’t reinvent † – Open source, commercial Libraries – OWASP libraries – Commercial Emailer services • Stay on Supported Versions
- 20. Policies, Procedures* (philosophy, cont’d) • Use 2-Factor/ Multi-Factor/ Strong/ Two-Step authentication wherever practical • Leverage Amazon AWS IAM and similar • Know Before You Go (learn before using, especially OAuth) • Insurance (general business, also “Cyber”)* • Procedures, Checklists for when people leave your company • Change Management
- 21. Awareness • People, Process and Technology – Acceptable Use Policy • Subscribe everyone in your company to – SANS OUCH*, and/or – CyberHeist† newsletter, and/or – Front Page of the New York Times, El Mundo, … • Test your people – Phishing email test – Not just .EXE attachments, but .PDF, even . JPG, .MP3* – USB drive left sitting around with autorun binary on it, … • Check your Credit Card & Bank statements carefully
- 22. USB phishing test • Particularly if your company is Ayatollah, Inc.
- 23. Techie Things To Do • Change default passwords! • Encrypt everywhere where it’s easy to do – Disks, Android & iOS mobile devices – Network traffic (Web SSL, VPN) – Wi-Fi infrastructure – VoIP / SIP gateways • do Backups*,** • run Anti-Virus • have Vulnerability awareness/ perform Patching
- 24. Techie Things To Do (cont’d) • UAC, sudo – Don’t compute as Root! • install Microsoft EMET • if you create Windows code, opt-in to – DEP, SEHOP, SafeSEH, ASLR • buy (and use!) a UTM appliance • enable Logging (& direct to different server)* • consider subscribing to Anti-DDoS protection • give your CFO a separate computer to do on-line banking…
- 25. Patching, Vulnerability awareness (desktop/client) • Windows – WSUS, InTune * • Secunia SmallBusiness* (beta), LANDesk Patch Manager*, BeyondTrust Retina free 256-IP edition • Deploy everything you can with auto-updating – More attacks come against apps today than against platforms – But make sure you trust the software vendor† • Choose commonly used, actively maintained products
- 26. Patching, Vulnerability awareness (server) • Canonical (ubuntu) Landscape*, RedHat Network* • Qualys free online vulnerability scan • Auto-updating may not be appropriate (but vulnerability management is still critical) • Have a Test environment – Use it for testing patches too
- 27. Some Great Free Tools • LastPass † (Freemium model) • Android, iOS Device Encryption* • WSUS • NTP • SSH, RDP • Microsoft EMET • Windows Firewall, Linux iptables
- 28. More Great Free Tools • OWASP code libraries (ESAPI) • File Vault 2, TrueCrypt, BitLocker*, Windows 8.1 Device Encryption † • Google Mobile Device Management • EFF’s “HTTPS Everywhere” (Firefox, Chrome, Opera)**
- 29. … and some Not-So-Great “Free” tools • Pirated software is NEVER a good idea – It’s illegal, and it should go without saying that you should not do illegal things – You don’t others to steal YOUR stuff – Pirated software very often comes with “extras” • Viruses, Trojan horses • Back doors, Spyware
- 30. Synergies • Use the Cloud † – AWS EC2 ELB, etc provides security front-end – Cloud SaaS (anti-virus, IT management; converged services – buy one, more available for small add-on cost) – Backup (Mozy*, Carbonite, …)
- 31. Targeted Training • Developers – to avoid common tech errors – Re-review the OWASP Top 10 every year – Send one or two top developers to SANS training • Marketing – to avoid creepy/annoying uses – Meet with people like your presenters today • Data Protection Official (IAPP CIPP, CIPM, CIPT!)
- 32. Human Things to To • Use Bookmarks/Favorites – no typos, can include https:// explicitly
- 34. New Privacy principles for Tech Startups So, what’s next?
- 35. • Data protection by design & by default (art. 23). • Security of processing (art. 30). • Data breach notification to DPA (art. 31) & to DS (art. 32). • Data Protection Impact Assessment (art. 33). • Data Protection Officer (art. 35). GDPR “new” principles
- 36. DP by design •Data controller and processor. • At the time of purposes and means determination. • Appropriate and proportionate technical and organizational measures. • Ensure data subject rights. • Entire lifecycle. • Accuracy, confidentiality, integrity, physical security and deletion of personal data. DP by default • No personal data processing beyond the minimum necessary for a predetermined purpose. Data protection by design & by default
- 37. • A level appropriate to the risks. Nature of processing and of personal data (DPIA). • Integrity, confidentiality, availability and resilience of systems. • Reliable Back up process. • Sensitive information? • PII only accessed by authorized personnel. • PII protected against accidental or unlawful destruction. Security of processing
- 38. To DPA • No undue delay. • Nature of breach (categories and number of PII affected). • DPO contact details. • Measures recommended to mitigate effects. • Consequences. • Describe measures taken to mitigate effects. • Document and public register. To DS • Notification to DS in case of adverse affect to personal data and privacy. • Comprehensive and clear plain language. Breach notification to DPA and DS
- 39. • Analyze potential risks (more than 5000 DS in 12-month period, sensitive PII). • Description of processing operations and purposes of processing. • Proportionality in relation to purposes. • Risks to DS rights. • How to minimize PII to be processed. • Security measures. • Data retention period. • DP by design and by default. • Categories and recipients of personal data. • Data transfers to third countries. • Context of data processing. Data Protection Impact Assessment
- 40. • More than 5000 DS in 12-month period. • Regular and systematic monitoring of DS. • Special categories of PD. • Inform and advise controller of processor. • Monitor and implement policies, train staff and audit. • DP by design and by default. • Data breaches. • DPIA. • Co-operate with DPA. • At least two years term. Might be reappointed. Employee or external contractor. Data Protection Officer
- 42. Panel
- 43. Presentation
- 44. 1.- Privacy as a competitive advantage
- 45. 2.- Preparing for a data breach
- 47. 4.- S.O.S. Compliance Team
- 49. Thank you!
Notas del editor
- The IAPP is the largest privacy association in the world and a leader in the privacy industry, facilitating conversations/debates and collaboration among key industry leaders and organizations. The organization provides resources to support practitioners to develop and advance their careers while helping professionals and businesses navigate the complexities of the evolving environment. Starting with just a handful of dedicated professionals, today the organization has more than 14,000 members across 83 countries Membership has tripled in the last five years and the growth rate has been over 20 percent in each of the last two years
- Daily Dashboard: The IAPP’s FREE daily e-newsletter, that summarizes the day’s top stories from around the world with links to the full articles—sent direct to your desktop each weekday! Privacy Advisor: The Privacy Advisor, the IAPP’s digital monthly member newsletter featuring news and analysis of privacy issues worldwide from leading experts. Privacy Tracker: Privacy Tracker is a member-only blog featuring the latest legislative developments and expert analysis .
- Online Community IAPP offers online educational and networking opportunities for those located in regions outside of in-person events IAPP Privacy List Connect with the IAPP community online to exchange ideas, share best practices and discuss privacy issues and concerns. The provides a friendly forum for the exchange of ideas and information related to a broad scope of subjects. Social Buzz The IAPP is active on Twitter (@DailyDashboard has 1,450 followers), LinkedIn (1,222 followers) and Facebook (1,803 Likes). Blogs Privacy Perspectives and Privacy Tracker Resource Center—members-only content on the IAPP website Tools, templates, research, articles, job board and more.
- More than a professional association, the IAPP provides a home for privacy professionals around the world to gather and share experiences - working to promote career readiness and improve job effectiveness Several global events/conferences providing education and networking opportunities including the IAPP Global Privacy Summit, annual event held for the last 13 years; the IAPP Privacy Academy; IAPP Canada Privacy Symposium; IAPP Europe Data Protection Congress, IAPP Europe Data Protection Intensive Events continue to attract industry thought leaders and policy makers, for example at the most recent Global Summit FTC Chairwoman Edith Ramirez made her first remarks in her new role Navigate event brings academics, industry thought-leaders and others together for intellectual provocation and debate to shape the future of privacy
- Launched nearly 10 years ago, the CIPP is the introductory training that educates on U.S. privacy laws and regulations and understanding of the legal requirements for the responsible transfer of sensitive personal data to/from the United States. The new CIPM training demonstrates how to embed privacy into an organization through process and technology The CIPT is the world’s only privacy certification designed for IT, security and engineering pros Proof Points: Starting with just a handful of dedicated professionals, today the organization has more than 12,000 members across 78 countries Membership has tripled in the last five years and the growth rate has been over 20 percent in each of the last two years Currently there are more than 5000 certified privacy professionals According to the latest IAPP Privacy Professionals Role, Function and Salary Survey professionals with their CIPP certification saw an increase in salary in 2013, outpacing even those with MBA’s
- Privacy and more particularly ‘Personal Data Protection’ is a growing concern at this moment in our history. Tech startups have to think of it very seriously from the beginning of their project. This can provide a huge competitive advantage and not many are taking advantage of it today. At the same time you can expect investors to seek confirmation that you are privacy-savvy from the start. Therefore, as a startup founder, think of privacy as not only a regulatory issue, which it certainly is, but as a human issue as well. People around the world are developing a real fear that they are losing control of their personal data, and politicians are reacting by increasing restrictions on what companies can do with the data they collect. To approach privacy in this context can put you in a position to become a future market leader.
- When you start up your business your main goals are signing up users and raising money … Privacy and Data Security is not top of mind !!! This is wrong … privacy and data security must be strategic.
- Understand your business model and know what data you are collecting. Don’t settle for open-ended or vague responses like ‘nothing sensitive’ or ‘no personal data’. Someone needs to understand exactly what data is being collected and why. But do not use intuition, the distinction between what is personal data and not can be very tricky and highly technical. As Jay and Victor will explain later on using tools to properly secure data and be proactive by implementing PbD and other new principles is the way to get it right, meaning not only to be compliant but also to seize the opportunity to win trust from your users or customers.
- * Spain and southern Europe in general have the bad habit of approaching privacy as a legal, checkbox, paper exercise, driven by fear of the Regulator (and how the LOPD is used by Consumer organizations to invoke the power of the Regulator), rather than as pro-business risk management for enablement. (The George Washington Law Review, Vol. 81:1529 - Privacy in Europe: Initial Data on Governance Choices and Corporate Practices, SSRN 2328877, Bamberger & Mulligan, 08/2013) Copying someone else’s privacy statement is a very bad idea. They’re probably not as good at it as you think, and your business is probably different from theirs, so your copy of their privacy statement is unlikely to represent your information practices. † You might want to get a large(r) round of investment or sell the company; then, the investors’/buyers’ due diligence will require them to look at your practical data protection posture!
- * Most people in the company try to avoid talking with Law departments and with Lawyers, but you want Privacy to be Operational and integrated, so your DPO must be somewhere and someone who people will want to talk to, and you must instill a sense of information “ownership” in your managers whose business function gets the most value from each database. ** An outside lawyer is not part of your company. He does not understand you. So he cannot be practical in helping you do Data Protection. SP Contest example. Operationalizing anything – general IT, privacy, data protection/ security, makes it more efficient and reliable. If you don’t have an IT Operations role, it will be difficult to operationalize information governance. Your HR head probably doesn’t understand IT, who thinks HR just gets in the way; they must work together to facilitate what HR needs to do with data, while allowing for compliance. † Yeah, I know, no time/money. In reality, it’s cheaper to fund this than to waste time searching for and reinventing that which is already readily available, if only your IT/privacy/developer guy knew about it from professional associations and conferences.
- * Few, simple, and really teach your people about them, and evaluate their performance. Dusty policy books on the shelf which nobody ever reads are worse-than-useless. PbD, PIA – One before, the other after, every project. Footprint - The fewer different things you have, the less time you have to waste training, patching/updating. Only custom develop that which is core to your business model. Re-use (open source, buy) everything else. Yes, even OpenSSL. † Reinventing - Almost everyone who thinks they can implement their own Widget to save money ends up with a poor quality, expensive widget. - Staray S125, S325 encrypted hard drives http://www.h-online.com/security/features/Cracking-budget-encryption-746225.html - Lexar JumpDrives (ca. CY2004) stored PIN retrievably on the drive - OWASP Enterprise Security API (ESAPI) - Session State Management – use the functions built-in to your chosen framework (ASP .NET, PHP, J2EE, …) - HTML Purifier to help avoid XSS in user-provided HTML code - Zend Framework ZendInputFilter, ZendFilter, ZendValidate - PHP PEAR - Django for Python Commercial Emailers give you functionality (who opened it) as well as unsubscription management (avoids/defends spam complaints). Unsupported software – Staying on XP or Java 1.5 or PHP 5.1 or … sounds like “If it ain’t broke, don’t fix it”. Until it breaks (or suffers a new, never-to-be-patched vulnerability).
- 2-Factor – The biggest single technical weakness is passwords. IAM, etc – reduce privilege. Also, EC2 firewall rules, instance monitoring and alerting (is that CPU or bandwidth spike just business or is it an attack?) OAuth – GREAT tool. Frequently implemented wrong, provoking risks *to others*. * When you first look at buying insurance which would help you in case of a “Cyber” incident, you probably won’t qualify! .. But the process of learning why you don’t quality will be instructive to you.
- People come first. Process helps People do right. Technology helps Process and limits People’s ability to screw up. * SANS Ouch, April 2014 “You (yes, you) Are a Target”! Not because you’re so interesting, but just because you have stuff that the attackers can use to attack others. Phishing tests are available cheaply from several security awareness vendors. Phishing plays on trust. We’re wired to trust. So we must verify, always. † KnowBe4 publishes the CyberHeist newsletter, and offers phishing tests (one free, then subscription). * In fact, almost any file attachment could be launched by a handler with a data format vulnerability, so you must mistrust all file types of learning why you don’t quality will be instructive to you.
- Stuxnet, anybody?
- VPNs help you test “From” anywhere (CDNs, latency) and also protect you against evil Wi-Fi access points and Man-in-the-Middle attacks. * Security is traditionally described as Confidentiality, Integrity and Availability. Of these business is usually most concerned with Availability. Backups keep you available (Disaster Recovery); Ransomware, Technology failure, Finger “oops”! … ** Those Finger “oops!” being actually the most common, use a (cloud) Backup solution which keeps multiple versions of files!
- * Separate management domains between core operations and supporting systems like the Logging server, so that a compromise of the core system cannot also easily destroy the log data which you would need in order to investigate the incident.
- * - commercial products/ services Auto-updating: The fear was always that an update would break something operational. In truth this happens rarely, whereas hacks of unpatched software happens daily. Anything that patches itself, you don’t have to waste your time patching. - Adobe Flash Player, Adobe Reader, Firefox, Chrome, Java, iTunes, QuickTime, KMPlayer † Mobile Apps especially. Auto-updating there gets you a constant stream of new features. Somewhat
- * - commercial products/ services
- † LastPass’ free version is excellent, including for businesses. It’s premium (personal) and enterprise (business) versions are even better. There’s no excuse to not use it! * Note that not all Android variants encrypt all data, especially removable SD cards, and iOS has different “levels” of encryption. Be sure to read the manual, so to speak!
- * BitLocker is only available on “Pro” and above Windows Vista/7 versions. † Windows 8.1 Device Encryption is completely automatic, but only on very new hardware which meets requirements. ** HTTPS Everywhere is great in theory; in practice I have found it can cause websites to malfunction, so approach with caution/ only for very technical users. But hopefully it will get better!
- † Yes, we know, the Cloud may provoke regulatory concerns. But if it’s going to do security better than you otherwise would (despite Luke Skywalker’s success – twice – against the Death Star, unless your enemy is using the Force, Señor Vader igualmente como Señor Google, Señor Amazon y Señor Microsoft will have better security on their cloud-hosted Death Star than you will in anything you run yourself!), and it’s speed and cost efficiency will let you do more business, and more secure business, that’s Practical, and more defensible than having not done it. * Some backup services, such as Mozy, allow you to control the Encryption Key.
- Tech startups and SMEs have a long list of to-dos. Data security is one of them. Tinder, the popular dating app, recently aknowledged flaws in its software that would let hackers pinpoint the exact locations of people using the service. Kickstarter, the crowdfunding site, also said that hackers had gained access to customers’ data, including passwords and phone numbers. Half joking we can add: for many companies, a security breach would almost be a nice problem to have in some cases; it means you have enough customers for someone to care. (Except that we know that many breaches are opportunistic, so you don’t have to have enough customers for someone to care, in order for someone to care…!)
- It’s a legal requirement. But more importantly, you want to maintain control over what they can do with your valuable data asset, so they don’t use it for their own gain, where you should have been getting that advantage yourself!