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NIS 2 Directive: cybersecurity improvement for all

The final text of the revised European Network and Information Security Directive (NIS 2 Directive) has now been published. This doesn’t formally apply in the UK, but does have some helpful comments on using data protection law to support network and information security. I’ve blogged about these previously but, since the final version significantly changes […]

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Articles

Trust or Mutual Benefit?

The theme of this year’s FIRST conference is “Strength Together”. Since I first attended the conference in 1999, we’ve always said the basis for working together was “trust”. However that’s a notoriously slippery word – lawyers, computer scientists and psychologists mean very different things from common language – and I wonder whether security and incident […]

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Information sharing, trust, and more…

Using and sharing information can create benefits, but can also cause harm. Trust can be an amplifier in both directions: with potential to increase benefit and to increase harm. If your data, purposes and systems are trusted – by individuals, partners and society – then you are likely to be offered more data. By choosing […]

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Information Sharing in Emergencies

The Information Commissioner’s new blog post explains how Data Protection law should be seen as a guide to when and how to share information in emergencies, not an obstacle to such sharing. In health emergencies three provisions are most likely to be relevant: Explicit Consent (GDPR Art.9(2)(a)): where an individual chooses to disclose information, such […]

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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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Algorithms: Explanations, Blame and Trust

“Algorithms” haven’t had the best press recently. So it’s been fascinating to hear from the ReEnTrust project, which actually started back in 2018, on Rebuilding and Enabling Trust in Algorithms. Their recent presentations have  looked at explanations, but not (mostly) the mathematical ones that are often the focus. Rather than trying to reverse engineer a […]

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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

Early in 2021 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. Incident Response and GDPR: slides Discussion at that […]

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Sandbox Tales – Information Sharing Platforms

The latest reports from the ICO sandbox provide important clarification of how data protection law applies to, and can guide, the application of novel technologies. This post looks at information sharing… FutureFlow’s Transaction Monitoring and Forensic Analysis Platform lets financial institutions such as banks upload pseudonymised transaction data to a common platform where they, regulators […]