The Online Trust Alliance (OTA) has release it’s 2012 Data Protection & Breach Readiness Guide, a comprehensive guide outlining key questions and recommendations to help businesses in breach prevention and incident management.

This post is a summary of their results and guidance.

Craig Spiezle, Executive Director and President of the Online Trust Alliance said

Last year, more than 125 million people were affected by data loss incidents. Combined with the increased awareness of these high visibility incidents and aggressive data collection and sharing practices, consumers’ trust and online confidence is under attack. By following the recommendations in this guide we have an opportunity to enhance online trust and promote the vitality of the internet”

Rob McKenna, Washington State Attorney General and 2011-12 President of the National Association of Attorneys General said

“Today’s consumer is often aware of when their personal data is collected and wants to ensure that businesses protect it. The Online Trust Alliance’s resources are a valuable tool for businesses committed to ensuring customers’ privacy and security”

John Roberson, Executive Director, Small Business Development Resource Center, Chicagoland Chamber of Commerce said

“Businesses need to look holistically at data privacy and ask, ‘What is the compelling business reason to keep customer data?’ When you have a data incident, the more data you have stored – and compromised – the more damaging it can be for both the individual and the company. The OTA guide gives key insights into questions that companies need to ask themselves to protect their customers and delivers information for any business developing, implementing, or updating their privacy policies and notices”

“The Internet has become the land of opportunity for scams and, unfortunately, we see thousands of them every year,” notes Genie Barton, Vice President of the Council of Better Business Bureaus and director of its Online Behavioral Advertising Program. “Consumers need assurances that they can trust the companies they do business with to secure their data, and the OTA Data Protection & Breach Readiness Guide is a great tool to help businesses protect themselves and their customers. BBB is happy to recommend it to businesses large and small, and we are delighted to help build a safer Internet for all by supporting excellent initiatives such as this guide.”

The 2012 Guide recommends that businesses need to accept three fundamental truths about data:

  1. The data they collect includes some form of Personally Identifiable Information (PII) or “covered information”
  2. If a business collects data it will experience a data loss incident at some point
  3. Data stewardship is everyone’s responsibility

2011 incidents, the highlighted statistics:

  • 558 breaches
  • 126 million records
  • 76% server exploits
  • 92% avoidable
  • $318 cost per record – an increase of over $100 per user record from 2009
  • $7.2 million average cost of each breach
  • $6.5 billion impact to U.S. businesses

The 558 incidents were recorded by the Privacy Rights Clearinghouse (PRC) and the Open Security Foundation reported and were broken into specific sectors, details below:

  • Education (schools and colleges) 13%
  • Government agencies 15%
  • Health care providers 29%
  • Business 43%

Compared to 2010, the sectors with the highest percentage change were:

  • Healthcare with an 11% increase
  • Business incidents decreased by 13%

In Verizon’s 2011 Data Breach Notification report, 50% of all data breaches were through hacking (up 10% over 2010) and 49% incorporated malware (up 11% over 2010). Most alarming is that 96% were avoidable through simple steps and internal controls.

The implications of a breach to the organization can be grave, for example:

  • An employee of Massachusetts General Hospital left 192 patient records on a subway, the hospital was fined $1M by the US Health and Human Services
  • The Massachusetts eHealth Collaborative, a 35-person non-profit, experienced a single laptop theft that cost them over $300,000 in legal, private investigation, credit monitoring and media consultancy fees. Employees also spent over 600 hours dealing with the damage that the breach caused to their brand and reputation.

The report offers the following guidance:

Data Incident Plan Framework

An effective Data Incident Plan (DIP) includes a playbook that describes the fundamentals of a plan that can be deployed on a moment’s notice. Organizations need to be able to quickly determine the nature and scope of the incident, take immediate steps to contain it, ensure that forensics evidence is not accidentally ruined and immediately initiate steps to notify regulators, law enforcement officials and the impacted users of the loss.

Risk Assessment/Prevention

To help maximize business continuity, organizations are encouraged to self-audit their level of preparedness by surveying key management leaders the following questions:

  1. Do you know what sensitive information is maintained by your company, where it is stored and how it is kept secure?
  2. Do you have an accounting of all stored data including backups and archived data?
  3. Do you have a map of data workflows both within your organization and your vendors’ organizations to identify points of vulnerability?
  4. Do you have a 24/7 incident response team in place?
  5. Is management aware of the regulatory requirements related specifically to your business?
  6. Have you conducted an audit of your data flows across your company and vendors, including a privacy and security review of all data collection and management activities?
  7.  Are you prepared to communicate to customers, partners and stockholders during an incident?
  8. Do you have access credentials in the event key staff is not available?
  9. Do you have a employee contact list to contact in the event of a breach, and is updated with contact information on a quarterly basis?
  10. Are employees trained and prepared to notify management in the case of accidental data loss or a malicious attack? Are employees reluctant to report such incidents for fear of disciplinary action or termination?
  11. Have you coordinated with all necessary departments with respect to breach readiness? (For example information technology, corporate security, marketing, governance, fraud prevention, privacy compliance, HR and regulatory teams).
  12. Do you have a privacy review and audit system in place for all data collection activities including that of third-party/cloud service providers? Have you taken necessary or reasonable steps to protect users’ confidential data?
  13. Do you review the plan on a regular basis to reflect key changes? Do key staff members

The report identifies 19 steps that are required by an organisation if they are to be effectively prepared to handle a data breach:

  1. Data Classification
  2. Audit & Validate Data Access
  3. Forensics, Intrusion Analysis & Auditing
  4. Data Loss Prevention Technologies
  5. Data Minimization
  6. Data Destruction Policies
  7. Inventory System Access & Credentials
  8. Creating an Incident Response Team
  9. Establish Vendor and Law Enforcement Relationships
  10. Create a Project Plan
  11. Determine Notification Requirements
  12. Communicate & Draft Appropriate Responses
  13. Providing Assistance & Possible Remedies
  14. Employee Awareness & Readiness Training
  15. Analyse the Legal Implications
  16. Funding & Budgeting
  17. Critique & Post Mortem Analysis
  18. Implement Steps to Help Curb Misuse of Your Brand, Domain & Email
  19. International Considerations

The complete OTA  guide is available here.

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