News of cyberattacks seems constant these days. Recently, Equifax, a US-based consumer credit reporting agency, announced that a private customer data breach impacted 143 million people. Earlier this year, 1.5 million connected cameras around the world were hijacked in an unprecedented DDoS attack.

As cyber-attacks become more rampant, it’s hardly surprising that governments are stepping in to hold organisations more accountable. One of the most recent examples of this is the European Union’s General Data Protection Regulation (GDPR) which is set to come into effect on May 25, 2018.

New GDPR legislation mandates

Essentially, the GDPR mandates that businesses adhere to specific governance and accountability standards in the processing and protection of data. A big focus of this new legislation is that individuals have greater control over their personal data. Contrary to legislations in the United States, the personal data captured by organisations will remain the property of each EU citizen, entitling them to access their own data and have greater decision power over how it is used or distributed.

Should a breach occur, companies are mandated to report it to the supervisory authority within 72 hours. Failure to comply with these new regulations could result in up to $20 million euros in penalties, or 4% of the company’s global annual turnover.

Territorial scope of GDPR

So why should North American companies and security directors be concerned? The territorial scope of the GDPR is global. Any business that is collecting or storing personally identifiable information (PII) of EU citizens will be held accountable, regardless of where the organisation is based or operating from. This includes any business collecting information from EU residents, or organisations with offices, stores, warehouses or employees in the EU.

With the deadline nearing, these North American organisations are seeking strategies that will keep them compliant across all their data collection processes. With a focus on physical security sensors and solutions, below are five steps that North American companies can start taking to become GDPR-compliant.

Step 1: Conduct a data risk assessment

To better understand the implications of the GDPR, an organisation must fully assess the level of risk that its data processing operations pose to the rights of EU citizens. A business should map out how data is collected, where it is stored, how long it is kept, and who has access to it. Identifying and categorising the various types of data is also critical to this evaluation. That’s because according to the GDPR, there is a clear distinction between the high, medium and low-risk data.

Companies should add varied lines of defence such as encryption, multi-layer authentication and authorisation
Through authorisation, organisations can define how specific users or groups can use the security system

For instance, data derived from a video surveillance system that shows who a person is and where they are is considered high-risk. This could be a retailer that is monitoring video of people coming into its stores or an EU subsidiary office that is recording publicly-facing video footage.

Step 2: Hire a Data Protection Officer

In cases of high-risk data processing, organisations may need to appoint a data protection officer (DPO). This person must be independent of any IT, risk or VP-level functions and will be responsible for monitoring the organisation’s compliance with respect to their GDPR obligations. The DPO will act as the main point of contact for all communications with the GDPR supervisory body. This means that at any point in time, the DPO should also be able to show the steps taken by the organisation to protect any collected information.

Step 3: Implement privacy by design

The GDPR mandates that businesses with ‘high-risk data operations’ implement systems that protect privacy and secure data by default. It is therefore critical for these organisations to start talking to system integrators and suppliers about what they can do to harden their systems. After all, cyber security should be a shared responsibility. Organisations should work with partners and vendors to better understand cyber security risks and streamline internal processes such as outlining who has access to the data and identifying why and how long it should be kept.

With this understanding, companies can justify adding varied lines of defence such as encryption, multi-layer authentication and authorisation. For instance, through authentication, organisations can determine if an entity—user, server, or client app—is who it claims to be, and then verify if and how that entity is allowed to access a system. Through authorisation, organisations can define how specific users or groups can use the security system.

Finally, encryption protects an organisation’s information and data by using an algorithm to make text indecipherable. From device to client application, these security measures help organisations safeguard against cyber threats and unauthorised access.

Step 4: Address data transparency

At any point in time, an EU citizen has the right to request a copy of information pertaining to them from an organisation. Upon receiving this request, the company would be required to securely and remotely share video and data files with the individual. A problem could surface if other individuals are visible in this footage. Security solutions that not only facilitate information sharing but also protect privacy can help companies quickly adapt to these new laws.

Video redaction capabilities can blur out people's faces in video
Blurring out faces transfers high-risk data to the low-risk category, allowing organisations to monitor or share video while still protecting privacy

One example is having video redaction capabilities to blur out people’s faces in video. This feature transfers high-risk data to the low-risk category, allowing organisations to monitor or share video while still protecting privacy. Companies will also need to provide greater transparency by making points of contact accessible and clearly outlining data management policies.

Step 5: Engage data processors

According to the GDPR, any company that collects and controls private information is a Data Controller. To properly manage the collected data, companies may choose to outsource some of the responsibility to service providers, known as Data Processors.

For instance, a retailer could decide to implement a Video-Surveillance-as-a-Service (VSaaS) solution. Some advanced VSaaS providers offer numerous logs and, more importantly, strong reporting platforms that can help Data Controllers and DPOs monitor the state of their video surveillance systems. In some capacity, Data Processors are equally responsible for adhering to laws.

Considering the failure to report a breach in 72 hours could result in massive penalties, implementing a VSaaS is a great way to stay on top of potential breaches and decrease compliance upgrade costs. However, it is not a full transfer of risk. The retailer would still be responsible for issuing and managing system access privileges, ensuring password choices are robust, and essentially, limiting data to those who can view or extract it.

Counteracting emerging threats through GDPR compliance

With heavy fines looming, it is imperative that North American businesses collecting or processing any EU citizen data begin working on GDPR compliance immediately. Those filming in high-trafficked public spaces are at an even greater risk of penalty if compliance has been ignored.

Starting with a comprehensive risk assessment, hiring a qualified DPO, upgrading technology with built-in privacy and security mechanisms, and in some cases, working with data processors can help North American businesses get on track to full GDPR compliance. Regardless of these new laws, these practices will ultimately benefit the organisation as a whole, as new threats emerge globally.

Download PDF version

Author profile

In case you missed it

What characteristics do salespeople require in the physical security industry?
What characteristics do salespeople require in the physical security industry?

A basic tenet of sales is ABC – always be closing. But it's a principle that most professional salespeople would say oversimplifies the process. Especially in a sophisticated, high-tech market such as physical security, the required sales skills are much more involved and nuanced. We asked this week's Expert Panel Roundtable: What unique characteristics are required of salespeople in the arena of physical security systems?

Can microchip implants replace plastic cards in modern access control?
Can microchip implants replace plastic cards in modern access control?

A futuristic alternative to plastic cards for access control and other applications is being considered by some corporate users in Sweden and the United Kingdom. The idea involves using a microchip device implanted into a user’s hand. About the size of a grain of rice and provided by Swedish company Biohax, the tiny device employs passive near field communication (NFC) to interface with a user’s digital environment. Access control is just one application for the device, which can be deployed in lieu of a smart card in numerous uses. Biohax says more than 4,000 individuals have implanted the device. Using the device for corporate employees Every user is given plenty of information to make an informed decision whether they want to use the deviceCurrently Biohax is having dialogue with curious corporate customers about using the device for their employees. “It’s a dialogue, not Big Brother planning to chip every employee they have,” says Jowan Österlund, CEO at Biohax. Every user is given plenty of information to make an informed decision whether they want to use the device. Data capture form to appear here! “Proof of concept” demonstrations have been conducted at several companies, including Tui, a travel company in Sweden that uses the device for access management, ID management, printing, gym access and self-checkout in the cafeteria. Biohax is also having dialogue with some big companies in the United Kingdom, including legal and financial firms. Österlund aims to have a full working system in place in the next year or so. A Swedish rail company accepts the implanted chip in lieu of a paper train ticket. They accept existing implants but are not offering to implant the chips. Österlund says his company currently has no plans to enter the U.S. market. The device is large enough to locate easily and extract if needed, and small enough to be unobtrusive Access control credential The device is inserted/injected below the skin between the index finger and the thumb. The circuitry has a 10-year lifespan. The device is large enough to locate easily and extract if needed, and small enough to be unobtrusive. The only risk is the possibility of infection, which is true anytime the skin is pierced, and the risk is mitigated by employing health professionals to inject the chip. Use of the device as an access control credential or any other function is offered as a voluntary option; any requirement by an employer to inject the device would be illegal, says Österlund. It’s a convenient choice that is made “based on a well-informed decision by the customer.” Aversion to needles, for example, would make some users squeamish to implant the device. More education of users helps to allay any concerns: Some 10% of employees typically would agree quickly to the system, but a larger group of 50% to 60% are likely to agree over time as they get more comfortable with the idea and understand the convenience, says Österlund. Protection of information The passive device does not actively send out any signals as you walk. It is only powered up by a reader if a user has access rightsIn terms of privacy concerns, information contained on the device is in physical form and is protected. The passive device does not actively send out any signals as you walk. There is no battery. It is only powered up by a reader if a user has access rights. With use of the device being discussed in the United Kingdom, there has been some backlash. For example, Frances O’Grady, general secretary of the Trades Union Congress (TUC), has said: “Microchipping would give bosses even more power and control over their workers.” A big misconception is that the chip is a tracking device, says Österlund. It isn’t. “We love people to get informed,” says Österlund. “If they’re scared or apprehensive, they can just read up. It’s not used to control you – it’s used to give you control.”

Ethical consumption: should you buy security products ‘Made in China’?
Ethical consumption: should you buy security products ‘Made in China’?

Should ‘Made in China’ be seen as a negative in security systems and products? It’s an important and complex issue that merits a more detailed response than my recent comment in the Expert Panel Roundtable. For me, there are two sides of the answer to this question: Buying products that have certain negative attributes that are not in alignment with some part of a belief system or company mandate. Buying products that do not perform as advertised or do something that is unacceptable. For integrators and end users making the buying decisions, the drive to purchase products may not be based on either aspect and instead on the product that can do the best job for their business. But for others, a greater emphasis on the ethical implications of purchasing decisions drives decision-making. What is ethical consumption? Ethical consumption is a type of consumer activism that is based on the concept of ‘positive buying’ in that ethical products are favouredEthical consumption — often called ethical consumerism — is a type of consumer activism that is based on the concept of ‘positive buying’ in that ethical products are favoured, and products that are ethically questionable may be met with a ‘moral boycott’. This can be as simple as only buying organic produce or as complex as boycotting products made in a totalitarian regime that doesn't offer its citizens the same freedoms that we enjoy in the United States. Consider the goals of the Boston Tea Party or the National Consumers League (NCL), which was formed to protect and promote social and economic justice for consumers and workers in the United States and abroad. Some examples of considerations behind ethical consumption include fair trade, treatment of workers, genetic modification, locally made and processed goods, union-made products and services, humane animal treatment, and in general, labour issues and manufacturing practices that take these factors into account. Increase in ethical consumption The numbers show that ethical consumption is on the rise. In a 2017 study by Unilever, 33 percent of consumers reported choosing to buy and support brands that they believe are doing social or environmental good. In the same study, 53 percent of shoppers in the United Kingdom and 78 percent in the United States said they feel better when they buy products that are ‘sustainably’ produced. There’s clear evidence that products from some Chinese companies suffer from cybersecurity vulnerabilities Though the aforementioned question that sparked this conversation centres around concerns with products made in China, there are many other countries where, for example, governments/dictators are extremely repressive to all or parts of their populations, whose products, such as oil, diamonds, minerals, etc., we happily consume. There are also a number of countries that are a threat in terms of cybersecurity. It may be naive and simplistic to single out Chinese manufacturers. Impact on physical security products Product buying decisions based on factors other than product functionality, quality and price are also starting to permeate the security marketplace. While this hasn't been a large focus area from the business-to-business consumption side, it's something that should be considered for commercial security products for a variety of reasons. Hardware hacks are more difficult to pull off and potentially more devastating" There’s clear evidence that products from some Chinese companies suffer from cybersecurity vulnerabilities. Last fall, 30 U.S. companies, including Apple and Amazon, were potentially compromised when it was discovered that a tiny microchip in the motherboard of servers built in China that weren't a part of the original specification. According to a Bloomberg report, “This attack was something graver than the software-based incidents the world has grown accustomed to seeing. Hardware hacks are more difficult to pull off and potentially more devastating, promising the kind of long-term, stealth access that spy agencies are willing to invest millions of dollars and many years to get.” This, along with many other incidents, are changing the considerations behind purchasing decisions even in the physical security industry. Given that physical security products in general have been lax on cybersecurity, this is a welcome change. Combating tech-specific threats In early January, members of the U.S. Senate introduced bipartisan legislation to help combat tech-specific threats to national security posed by foreign actors and ensure U.S. technological supremacy by improving interagency coordination across the U.S. government. The bill creates the Office of Critical Technologies & Security at the White House, an indication that this issue is of critical importance to a number of players across the tech sector. Members of the U.S. Senate introduced bipartisan legislation to help combat tech-specific threats to national security posed by foreign actors To address a significant number of concerns around ethical production, there are certifications such as ISO 26000 which provides guidance on social responsibility by addressing accountability, transparency, ethical behaviour, respect for stakeholder interests, respect for rule of law, respect for international norms of behaviour and respect for human rights. While still emerging within physical security, companies that adhere to these and other standards do exist in the marketplace. Not buying products vulnerable to cyberattacks It may be counter-productive, even irresponsible, to brand all products from an entire country as unfit for purchasing. Some manufacturers’ products may be ethically questionable, or more vulnerable to cyberattacks than others; so not buying products made by those companies would make sense. The physical security industry might be playing a bit of catch up on this front, but I think we're beginning to see a shift toward this kind of responsible buying behaviour.