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Articles

Data Breaches: assessing risk

Under the GDPR’s breach notification rules, it’s essential to be able to quickly assess the level of risk that a security breach presents to individual data subjects. Any breach that is likely to result in a risk to the rights and freedoms of natural persons must be reported to the relevant data protection authority, with […]

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Articles

Attackers, CSIRTs and Individual Rights: Clarified

A few years ago I wrote a post on how the GDPR copes with situations when there was a conflict between the obligation to prevent, detect and investigate incidents and the obligation to inform all those whose personal data you process. Do you, for example, need to inform someone who is attacking your systems that […]

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ePrivacy Regulation: one step closer

[Update (Nov’21): I’ve discovered that Patrick Breyer MEP has published a “parallel text” of the three current proposals (Commission, Parliament and Council). Not exactly easy reading, but it makes it much easier to see where they are similar, and where there remain significant differences] [Original (Feb’21) post…] After four years, and nearly three years after […]

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Publications

CSIRT Information Sharing: completing the legal framework

[UPDATE: slides from my TF-CSIRT presentation are now available] Several years ago I wrote a paper on using the GDPR to decide when the benefits of sharing information among network defenders outweighed the risks. That used the Legitimate Interests balancing test to compare the expected benefits – in improving the security of accounts, systems or […]

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Articles

Information Sharing: Failing Smarter

Over the past twenty years, I’ve seen a lot of attempts to start information sharing schemes. And a lot of those have failed, some very slowly, despite huge amounts of effort. I wondered if there pointers that could be used, early on, to try to spot those. Story First, what is the story? If you […]

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Draft NIS2 Directive: security teams “should” be collaborating

Anyone who works with flows, logs and other sources of information to protect network and information security should already be familiar with Recital 49 of the GDPR, where European legislators explained why that was (subject to a risk-based design) a good thing. Now the European Commission has published its draft of the replacement Network and […]

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Presentations

Data Protection and Incident Response

Recently I was invited to give a one-hour presentation on Data Protection and Incident Response, looking at how the demands of the two fields align and support each other, and how law and guidance have come to recognise that over the past decade or so. I finished with some thoughts on areas – data collection […]

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Articles

Data Breach Shanty

To celebrate my 500th blog post, here’s another sea shanty: What shall we do with the stolen data? What shall we do with the stolen data? What shall we do with the stolen data? Early in the morning. Way-hey the fines are rising Way-hey the fines are rising Way-hey the fines are rising Early in […]

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Articles

WHOIS access and the NIS2 Directive

The European Commission’s proposed update of the Network and Information Security Directive may revive discussions about access to WHOIS data. When a domain name is registered, contact details are typically requested for various purposes, including billing, administrative and technical questions. For most of the history of the DNS this ‘WHOIS’ data – including names, postal […]

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Articles

Improving security and privacy with AI

Two talks at last week’s FIRST conference looked at how Artificial Intelligence might be used in incident response. In both cases, the use of AI improves user privacy directly – by reducing or eliminating the need for human responders to look at user data – and also indirectly, by producing faster detection and mitigation of […]