Implementing Data Protection

Our software need to enforce access control. One of those concepts is need to know:

  • Access based on business need to know
  • Restrict access to sensitive data
  • Ensure training of staff (clearance, review of access…)

Business Requirements

To implement data protection based on business requirements, one need to think about the following:

  • Operations:
    • Criticality
    • Backups
      • Proximity (where to keep the backup)
    • Response time
      • Storage type
        • Disk
        • Tape

Labeling

Labeling is there to indicate whether the data needs protection or not:

  • Indicate sensitivity (is it confidential data?)
  • Retention (how long should this data be kept?)
  • Ownership (who own and is responsible for the data?)

The labels can be electronic (headers with information) or physical, on a tape.

Codes can be used instead of names: this is a form of tokenization to prevent revealing what the data is and/or how it should be handled.

Data Protection Controls

We need controls: in all forms, in all places, at all times.

The best way is encryption.

We must also assure its deletion using crypto erasure/shredding. We also must ensure the destruction was done with defensible destruction: evidence of compliance with the proper deletion of data.

Data Retention

How long should be keep the data?

  • Legal requirements (ability to retrieve)
  • Business needs
  • Historical/cultural significance

Backups

We want to make sure we can recover the information even in case of catastrophic event: this is called disaster recovery.

Location can be tricky: we want the data to be backed up far away from our location but make sure we can legally do so (some data can’t be backed up in another country, for example).

Data must be encrypted. In that case we must make sure we keep both the key and the encryption algorithm for as long as we keep the data.

Data Recovery

In case of a disaster, we want to make sure we can recover the data at the time needed for the business to recover operations. This needs two concepts:

  • Recovery Point Objective (RPO): how much data could I lose, in time (seconds or days or weeks)
  • Recovery Time Objective (RTO): how much time to recover do we want to have (hours or days etc)

We need to know what data we need, how current they must be, and how could I access that data within the allowable time frame of the RTO.

Summary:

  • Data must be protected according to risk, legal requirements and business needs.
  • Data protection is based on the sensitivity and criticality of the data.