Post Safe Harbor ... Next Steps for EU Organisations

Over the last few weeks, you’ve probably seen ongoing discussions about the European
Court of Justice (ECJ) declaring that the US “Safe Harbor” agreement used by more than 4,000 companies is now invalid.

If you are based in the EU, why might this be relevant to you and your Information Security Management System? In the increasingly “cloudy” world which we work within, many companies are likely to have at least some exposure to software or a solution provided by a US-based provider, whether for financial, data storage, telecoms, HR or some other purpose. This also includes most of the common social media platforms, including Facebook, Twitter and LinkedIn, which may be used for marketing or customer service activities. Such providers self-certify themselves against the US Safe Harbor agreement, which was designed to provide reassurance about data transfers between the European Union and the USA.

But not anymore. The ECJ highlighted a number of concerns in its judgement, including the lack of an acceptable complaints mechanism for EU citizens, and the potential interference in EU citizen data by the US intelligence services.

Now is a timely moment for EU organisations to review and understand where their data is. Once you understand the suppliers involved, seek to identify where their physical data centres and support locations are, and from there understand the data protection frameworks. It may be that your data is non-personal or of low sensitivity in which case you may not be too concerned about understanding these characteristics, but if it does include personal, financial or commercially confidential information then your organisation should take an informed decision on where this data should reside.

We expect that the number of US Corporations opening up EU-based data centres in the near future is likely to increase as a direct result of this judgement.

If you have (or are working towards) ISO27001 certification for information security, this news should have you reaching for your risk assessments to ensure that they remain an accurate representation of your post-Safe Harbor decisions. The recently introduced ISO27018 risk framework for personal data in the cloud presents organisations with a sensible means to understand and record the relevant outputs of this discussion, from the location of physical data centres and support locations to the data protection framework and legislative frameworks that apply. 

The InfoSaaS IT risk management solution is already aligned to ISO27001:2013 and additionally includes relevant threats and controls from the cloud personal data framework ISO27018:2014. If you’re seeking a more effective method to keep your organisation’s valuable data assets safe – including ensuring that they are not being unwittingly exposed to unacceptable international data protection or surveillance – take a look at our software demo at www.infosaas.uk.

And, before anyone asks, we’re a UK-registered company using UK-based data centres!
For our international customers, they can choose between our UK solutions or request an in-territory installation which may better align with the specific regulatory requirements of the countries in which they operate.

Perfect Password Practice

Using strong passwords is one of the most effective ways to increase your online security
and protect your data. It’s also very straightforward, so you’d expect it to be something that
almost everyone does. Unfortunately this is not the case … it is less convenient than using
weak and easily remembered passwords, and people are just too busy.

However, if you imagine the potential repercussions of an information security breach it
very quickly becomes evident that it is worth the effort to use strong passwords. Also, it
doesn’t have to be inconvenient – once you have a system in place to manage your
passwords it can actually save you a lot of time.

What is a Strong Password?

A strong password should be:

• unique – never use the same password for multiple websites or accounts. If one website is compromised then attackers will quickly and easily have access to all your on-line accounts using the same password.
• mixed – a strong password should contain a mix of letters, numbers and special characters.
• long - the longer the password the harder it is to crack using brute force and computing power. The exact length that is ‘safe’ changes with time as computing power improves but at present a password of at least 12 characters length can be considered an absolute minimum.
• random – passwords shouldn’t contain dictionary words, names, birthdays or other personal information. They also shouldn’t be made up of patterns on the keyboard such as ‘qwerty’ or ‘12345’. ‘Dictionary attacks’ render even very long passwords weak if they contain easily identifiable dictionary words and phrases.
• secret – it’s obviously a bad idea to write a password on a post-it note and pin it to your computer (yes we have seen it!). Avoid sharing login details too – these days most websites allow for separate login details to be used by different users of the same account.
• changed – regularly changing passwords is very good practice. Change important passwords every 3 months, making sure not to re-use your old passwords. If you suspect that one or more of your accounts has been compromised change the password immediately; this simple step will often be enough to deny access to an attacker.

Whilst many individuals struggle with choosing and remembering complex passwords, there are several tried and tested means of achieving an acceptable level of protection. Consider the nursery rhyme ‘Old MacDonald had a farm ….’ and you should be able to
work out how that could help you to generate (and remember) the strong password
‘OMDhafe!e!o’ – there are many other rhymes, phrases and saying for you to choose from.

Managing Passwords

It is near impossible to memorise a selection of random, 12-character passwords and
recall them every time you need to log in to a web app.

The old-school method of writing all your passwords in a little black book is inconvenient:
its also easily compromised if you lose your little black book.

The modern solution to this modern problem is a dedicated password manager. These
usually work by letting you use one very strong password to access the manager where all
your passwords are stored. There are now a good range of password managers available
with a variety of convenient features such as random password generators and
automatically log in to websites.

However, before you sign up for a password manager, take a moment to understand that if
your password manager becomes compromised then all your web apps and accounts will
be vulnerable. For this reason it is very important to think carefully when choosing a
password manager.

A good password manager should be:

• zero knowledge - ‘zero knowledge’ also known as ‘TNO’ (trust no one) means that no-one has access to your passwords or data... not even the software developers or cloud storage managers can see your passwords. The down side of this is that if you forget your ‘master password’ there is no-one to help you retrieve it – but that is the price to be paid for the highest possible levels of security.
• open source – ‘open source’ means that the code that the software is written in can
  be viewed by anyone. This means that the software is less likely to have
  weaknesses built into it and that it can be scrutinised to check that it does what is
  claimed. It’s important not to assume that because software is open source that is it
  bug free – there are many cases of open source software containing vulnerabilities.
  However, software where the code is freely available is a strong positive for
  security.
• user friendly – a good password manager should be convenient and easy to use. If it isn’t you probably won’t want to use it.
• reputable – look for a widely used password manager with a good reputation that is up-to-date and with a team currently working on it.
• two-factor authentication enabled – ‘two factor authentication’ means that you’ll need more than just a ‘master password’ to access your passwords. It markedly improves the security of the password manager – we’ll talk more on 2-factor authentication in the next post.