Just In Time For the Holidays: How The FTC Defines Reasonable Security

Reasonable Security
How The FTC Defines Reasonable Security
Recently the International Association of Privacy Professionals (IAPP, www.privacyassociation.org ) published a white paper that analyzed the Federal Trade Commission’s (FTC) data security/breach enforcement. These enforcements include organizations from the finance, retail, technology and healthcare industries within the United States.

From this analysis in “What’s Reasonable Security? A Moving Target,” IAPP extrapolated the best practices from the FTC’s enforcement actions.

While the white paper and article indicate that “reasonable security” is a moving target it does provide recommendations that will help organizations access and baseline their current data security efforts.  Interesting is the focus on data centric security, from overall enterprise assessment to the careful control of access of employees and 3rd parties.  Here some of the recommendations derived from the FTC’s enforcements that call for Data Centric Security:

  • Perform assessments to identify reasonably foreseeable risks to the security, integrity, and confidentiality of personal information collected and stored on the network, online or in paper files.
  • Limited access policies curb unnecessary security risks and minimize the number and type of network access points that an information security team must monitor for potential violations.
  • Limit employee access to (and copying of) personal information, based on employee’s role.
  • Implement and monitor compliance with policies and procedures for rendering information unreadable or otherwise secure in the course of disposal. Securely disposed information must not practicably be read or reconstructed.
  • Restrict third party access to personal information based on business need, for example, by restricting access based on IP address, granting temporary access privileges, or similar procedures.

How does Data Centric Security help organizations achieve this inferred baseline? 

  1. Data Security Intelligence (Secure@Source coming Q2 2015), provides the ability to “…identify reasonably foreseeable risks.”
  2. Data Masking (Dynamic and Persistent Data Masking)  provides the controls to limit access of information to employees and 3rd parties.
  3. Data Archiving provides the means for the secure disposal of information.

Other data centric security controls would include encryption for data at rest/motion and tokenization for securing payment card data.  All of the controls help organizations secure their data, whether a threat originates internally or externally.   And based on the never ending news of data breaches and attacks this year, it is a matter of when, not if your organization will be significantly breached.

For 2015, “Reasonable Security” will require ongoing analysis of sensitive data and the deployment of reciprocal data centric security controls to ensure that the organizations keep pace with this “Moving Target.”

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