Today is somewhat of a sad day for me as tomorrow I will attend Bob Hays funeral.  Bob and I started this business when we both returned from Dubai where we worked for HPE in their cyber security business, across the Middle East.  We came a long way since starting up in 2017 even though COVID happened in the middle, changing the way that business was conducted by many companies and therefore how we had to adapt and change in order to compete and provide the services needed by the new normal.  I think we did a pretty good job all told.

In honour of Bob, I thought I’d focus my blog this week on data protection, his pet subject.  He always went to great lengths to point out that we weren’t lawyers but were providing the how to, rather than the legal requirements of data protection legislation.  He always said that lawyers were great at telling us what we need to do to meet our legal obligations but were lousy at telling us how to do it.

Data Protection, a somewhat dry subject that many companies, particularly SMEs, think they can get away from by simply paying a bit of lip service.  The Data Protection Act 2018, or as it has become known, UK GDPR, is far from a toothless beast and can cause businesses to find themselves in all sorts of problems if they’re not careful.

Businesses that you might not think about, like Estate Agents, hold large amounts of personally identifiable information or PII, that is information that can identify a living individual.  Not so long ago a London estate agent was fined £80,000 by the Information Commissioner’s Office (ICO), after leaving the personal data of more than 18,000 customers exposed for almost two years.

The incident occurred when the estate agent passed the details from its own servers onto a partner company. An “Anonymous Authentication” function was not switched off, which meant there were no access restrictions to the data.

It’s surprising just how much PII estate agents hold.  Just think about what they ask for when you’re buying a house.  In this case the exposed details included bank statements, salary details, copies of passports, dates of birth and addresses of both tenants and landlords.

But in some cases that might not be the end of it.  Individuals can sue companies that release data into the wild.  In fact, there are now law firms advertising no win no fee when representing these cases.  Remember that data breaches almost always involve multiple people, sometimes hundreds if not thousands of records.

One thing that many misunderstand is the link between cyber security and data protection.  The Act requires personal data to be secured by ‘default and design’.  This means that cyber security requirements must be designed into your data protection processes which could considerably increase the number of policies and processes you require to stay safe and within the law.

Data Protection is a bit of a bureaucratic nightmare I have to admit.  Here at H2 we have a raft of templates we use, originally drafted up by Bob, that have been successfully introduced into a variety of organisations, often integrated with their company handbooks.  These include:

Of course these aren’t necessarily the only things needed, there are a whole list of cyber security policies required to complement these.  Nearly all are available online, but the problem is knowing what you need and what you don’t and not just downloading, topping and tailing, and hoping for the best.  That happens all too often.

Our approach to this has been refined over the years as not just the legislation evolves, both here and in Europe, but as working practices evolve alongside it.  We have spent many hours researching solutions and crafting them into services that meet the requirements, which in turn have evolved into a system which works, is both affordable and appropriate for all types of business, and is accreditable to standards such as cyber essentials, if that is required.  Flexibility is another key attribute that the new working practices demand.  Long gone is the old bastion security system whereby everyone works within a secure boundary, protected by firewalls and other similar technologies.  These days we need a system of protection that works regardless of where you are working, office, home, on the move, and can switch seamlessly between them.

When we are first approached by a prospective client and we begin our offer of a free trial to examine their requirements, one of the first things we find is that they don’t know what data they are holding, or where it all is.  Oh, they have a general idea; it’s on the cloud server(s), it’s not on laptops or desktops, it’s just the stuff we need to process our clients’ requirements and yes, we’ve only got one copy.  And then we install our software that first carries out a discovery exercise and we find that their laptops/desktops are holding lots of copies of the data that is on the cloud server(s).  How does that happen?  Over time, especially with many now employing the hybrid system of working, ie between the office and remote (home) locations, employees log on to the cloud, find they have a bit of shaky internet link and download the data they need, work on it and then upload it again, forgetting to delete it from their machine.  Or they need to share it and attach it to an email and send it out, forgetting, or perhaps not realising, that the data is now stored, attached to an email, on their email server.

Then comes the issue with audit trails.  If the ICO ever wanted to carry out an investigation, then having an audit trail of who created/copied/deleted/forwarded what to who, is essential.  And let’s not forget the member of the public who is fully entitled to submit a Data Subject Access Request or DSAR, which demands that you reveal what data you are holding on that person.  The law insists on it, and you can’t refuse it.  I know of a financial firm that took nearly 3 weeks to satisfy a DSAR, taking an employee off billing, for that time.

Our solution meets the requirements needed today and not only that, has a built-in encryption system, all within the same monthly cost.  It’ll cost you nothing to trial it and we’d be very surprised if once you’ve seen it and seen the ridiculously low monthly charge for the managed service, you don’t want to keep it.

So a final farewell to Bob, with thanks for all his work in the data protection arena, and for the friendship forged in 3 different company’s before we took the bull by the horns and went out on our own.