One of the more common myths in security is that it will always compete with functionality of a system. There is some element of truth in the idea, but it’s often touted as a reason for not putting security in place which is something we need to move past as an industry.
The problem is that it is true, to a degree. Once a system is built layering security protections on top will always have some impact on functionality and usability, whether that’s by requiring additional authentication by users, restricting connectivity, or simply by impacting performance. And there lies the problem – it’s true when layering security on top of an existing system.
If a system is designed with security considerations from the ground up, placed on an equal footing at the beginning of requirements gathering as other functional and non-functional requirements, then there is no need to have a significant impact on the functionality of a system. In fact, given that one of the best ways to apply security at design is to simplify and automate, designing for both security and function will usually result in a more secure, more robust, and more functional system.
Yes, it does involve more up-front work, and some additional expense, but in terms of the effort saved on sticking web application firewalls, additional incompatible authentication mechanisms, and external monitoring systems among many other point solutions in front of a system quickly pays back that initial effort.
So more accurately, security will always be a trade off with functionality when it is applied too late to a system. When it is incorporated into requirements and built in as a core part of the design, this idea no longer needs to apply.
Despite what the non-stop wave of e-mails, text messages, and notices popping up everywhere would have you believe, GDPR is not about consent.
In fact as a rule of thumb what the legislation suggests is that consent should only be relied on to collect, store, or process personal data if you do not have any other legitimate reason to do so.
A quick look at the lawful bases provided for under GDPR, and the rights that each provides, show this quite well.
- Consent: the subject has given clear consent to process their data for a specific purpose
- Contract: processing is necessary to fulfil a contract with the subject, or to prepare a contract that they have requested
- Legal obligation: processing is necessary to comply with the law (exception being contractual obligations)
- Vital interests: processing is necessary to protect someone’s life (not necessarily the subject)
- Public task: processing is necessary to perform a task in the public interest, or for your official functions
- Legitimate interests: processing is necessary for legitimate interests of yourself or a third party (this does not apply to public authorities carrying out official tasks)
The only reason all of these consent notices are popping up everywhere is because none of the other bases apply. Mostly it’s about getting consent to profile you in order to better target advertising. So, when ticking those consent forms, or giving consent, it’s worth remembering that it isn’t down to GDPR that you’re now seeing them everywhere – it’s down to companies being desperate to use your personal information to more effectively persuade you to buy things or think a certain way, and not having any reason in your interest for doing so.
Initiative Q is tomorrow’s payment network, an innovative combination of cryptocurrency and payment processor which will take over the world and make all of
Since they’re not asking for anything (there have been suggestions it’s an e-mail harvesting scheme, but there are much easier, cheaper and quicker ways to simply grab e-mails and social data) there’s nothing for those initial investors to lose, so why not get involved.
Well, that’s the pitch anyway. I’m not going to comment on whether or not I think Initiative Q is malicious (I don’t) or a scam (that’s a longer discussion), just on what that initial investment involves and what social engineering they’re using here to expand their initial user base. It’s also important to note that the initial investors are definitely putting a stake into the game when they sign up, especially when they start inviting friends and family, and this is something that people should be aware of before jumping in.
I can’t imagine anyone not seeing the cynical manipulation of the front page, with its estimated future value of the next spot, so won’t dwell on it other than to say it’s a rather clever way to apply a time limitation on decision-making as it ticks down (and does at least make it clear that only 10% of the future-value tokens are available after registration, the rest depending partly on inviting five friends and unspecified future tasks). I’ll be honest, this type of manipulation does tend to get my alarm bells ringing.
A false sense of urgency and/or scarcity (and this has both – urgency with the value ticking down, scarcity on the small number of invites per person) is one of the classic pillars of social engineering. It tends to help convince by short-circuiting the decision-making process, since there’s no time to consider carefully and instead you must buy NOW!
The more insidious part to me is the idea that sign ups are not committing anything, therefore are safe. I blame social media for this one. What’s being invested isn’t financial worth, but individual’s social capital as they are used to convince friends and family. This is social proof in action – large numbers of people, smaller numbers of close friends and family, again is a way to let our lazy brains off the hook on examining a proposition, so that we act on autopilot and sign up.
Worse is that once someone sees themselves as an investor, with a substantial future stake, they are much more likely to aggressively defend the system if anyone tries to cast doubts on it (there have been a few examples of this recently), and refuse to accept any evidence that it might not be everything that was promised. By encouraging people to invite five friends you’re also promoting consistency – no one wants to go back on what they said to five of their friends (or strangers in a lot of cases) in public, and so any actual evidence against the system will be ignored or discredited.
So the weights that need to be considered aren’t financial – instead by signing up you are committing your individual integrity and social capital to this system, which has explicitly stated that all they’re after at this point is growth. It’s fair to say there is nothing particularly innovative about the Initiative Q technology, despite their claims, and the particular model has been tried before with less-polished marketing. Before signing up, please think carefully, remember that they aren’t promising anything (the initiative is very careful in their language to be conditional) while you’re putting a piece of your own identity into the scheme, committing to defend it against sceptics, to carry out unspecified future tasks, and to drag your friends in using your own credibility.
Recently I came across an article which nicely put forward a point I’ve been arguing for a while, often without much success: . Unlike Babar, I’m not amazed that there’s a confusion between vulnerability scanning and pen testing. The aim of both is to find vulnerabilities, and if the report is being read by someone who is not a security specialist and knows what they’re looking for then a vulnerability scan looks awfully similar.
The difference is vital. A good penetration test will often start with a vulnerability scan, a bad one stop there (aside from replacing the logo on the output). I’ve seen plenty of reports which I could have spun out of Nessus or Qualys myself from budget pen tests. This isn’t always the fault of a pen test company (although a good one should always advise customers of the requirements for effective engagement) – if you’re given only a couple of days engagement for a black box test (one where you have minimal information about the target) then you aren’t going to get much more than a vulnerability scan out of it.
The problem comes when those short engagements, with pen testers not provided proper information, are counted as pen tests for security. They aren’t – they will not discover anything an automated scan doesn’t, and so a company is simply wasting money on security theatre. Either don’t bother pretending that a pen test has occurred, or engage a company fully and effectively to assess a system over a longer period of time, with all the information and documentation available internally. This is one of those cases where a budget solution is worse than none at all.
This isn’t intended to diminish vulnerability scanning – it’s a vital activity that everyone should carry out on a regular basis (in my perfect world near-realtime, in reality, often monthly) to assess and deal with vulnerabilities. In a perfect world, these results can simply be handed over to a penetration testing company to save you a little money – pen testers are not the enemy, they are there to help you find holes, giving them additional information means that time isn’t wasted looking for non-existent holes and everyone gets better intelligence out at the end.
A common error is to think that because a system, solution, process, company, person, or other entity is not compliant with a particular standard, it’s insecure. It’s not a grievous error, and is an understandable one to make which doesn’t cause any harm (except occasionally causing more investment in security, which is usually a good thing anyway).
The flip side of this is where the problem comes in – when the assumption is made that because an entity is compliant with a particular standard or standards it is secure.
The reason that people often fall into this error is because compliance is straight-forward (not necessarily easy): it’s a very binary set of conditions to meet in order to be compliant, and if you fail them you’re not compliant. It’s a very easy idea to understand, and quite comforting to conflate with the idea of being secure – because compliance is achievable. Security is not.
In a similar way to illness in people, compliance is the regular checkup with the doctor who confirms that you’re in a fine state of health, because you don’t have any symptoms on the checklist. A year later the heart attack hits, because not only were the predictive symptoms not on the list, but the doctor’s reassuring words convinced the patient they could be a little lazier and put less work into their fitness.
It isn’t that compliance and standards aren’t important, they are, very much so. It’s that they simply should not be the one measuring point used to determine whether or not something is secure. In fact they shouldn’t be used to determine whether something is secure at all. At most a few days after a standard is written, it’ll have sections that are out of date. Security moves fast, and standards bodies have no real way to keep up without moving to a living standards model – which would be a completely different discussion.
Security is an aspiration, not a goal that can be reached through checklists. The checklists help, but the important aspects of genuinely continuously improving security are a company culture which takes security seriously, security subject matter experts always looking to make justified improvements to reduce risk, a high value placed on using actionable threat intelligence to anticipate and prevent incidents, and instilling a culture of security knowledge, engagement and awareness throughout the entirety of an organisation.
Or to sum it all up with a nice little aphorism, we must be careful not to confuse the map for the territory.
Under GDPR a lawful basis is the justification to process personal data. While I’ve focused mainly on consent, as the easiest to understand, the others are worth looking at – and contract may be a better fit for much of the work that sole traders carry out. First, a quick examination of what the lawful bases mean and how you can apply them.
Essentially a lawful basis defines the purpose for which you’re holding the data, and provide different sets of rights for data subjects to allow for the different usage. Consent, for example, allows subjects to request erasure, to object to the storage of their data or processing for a specific purpose, and allows them to demand that any data held on them be exported and provided in a portable format. Obviously these rights are not suitable to all purposes.
The contract lawful basis allows for data subjects to object, which means that they can ask for you to stop processing their data for particular purposes. They cannot ask that you erase the data, nor that it be exported in a portable format (or rather they can ask for these things but you have a legal right to refuse). If they do ask that you stop processing their data for a specific purpose then you must comply – unless you have compelling legitimate reasons to process the data, or are doing so to establish, exercise or defend a legal claim (i.e. if a client has refused to pay, you would not have to stop processing their data in order to pursue payment).
In order to establish contract as a lawful basis you need to assess the data you are holding (most likely not much more than contact details), ensure you are only using it for that purpose (in order to negotiate or perform a contract), ensure you do not hold it longer than necessary (once the contract is complete if there are no legal reasons to hold onto it for a period of time, such as auditing or chasing payment, then you should delete it), and record that you are holding it under that basis. In most cases all you’d need would be a footer on e-mails explaining that you will hold and use contact information in order to negotiate and complete a contract, and will retain it for compliance with any applicable laws after the contract is complete.
If you want to use those contact details for any marketing either during or after the contract, then that would be a separate purpose (arguably you might be able to go for legitimate interest, but to be honest consent is far more suitable for this purpose) and you would need to inform the client and get their explicit consent for this. They would also need to be provided with a simple method to object (i.e. sign up to my mailing list for further details, followed by on each mailing an e-mail address to contact or link to click if they want to be removed).
As always, any questions please ask here, or via Twitter (I don’t mind dealing with private queries, but it’s easier to go through those two than answer the same questions several times). Also please remember if you have particular legal concerns then you should speak to an expert with insurance rather than leaning on this article for any legal opinion – I’m purely looking to clarify the available guidance and target it more appropriately at those who seem to have slipped under the ICO’s radar in terms of advice.
I am very much not a fan of software or cloud-based password vaults. While I agree with the intention of allowing people to use long, complex, unique passwords for each site it always feels like there’s a flaw in the implementation, or in the concept itself. Locking all of your highly secure passwords up behind a single (memorable) password just seems fundamentally flawed as an idea – particularly if you’re doing so online where you have to trust other’s security. Even where it’s a local vault on your machine, a lot of convenience is lost when you move to a different machine, and having copies synced to each one using OneDrive, DropBox or similar raises the same issue as sticking the vault in the cloud.
One suggestion I’ve seen, and recommended in the past goes, against some of the fundamental advice. Certainly where the password isn’t that important, write it down and stick it in your wallet, glasses case, etc. You’ll know if it goes missing and can make sure you reset it or lock the account as soon as possible – and it means that long and complex passwords are usable.
Others include generating passwords based on an algorithm involving a core string, and something about the site or system the password is for. That way it is remembered for each site. The problem here is that such algorithms are easily figured out with just a few data points, and there are enough site compromises that those data points will be out there.
So I’m using a different solution myself. To be very clear that there is no affiliate marketing here, I get no benefit whatsoever from recommending or reviewing this option, I simply think it is one of the better options out there.
I use a hardware password vault called Mooltipass (yes, the name was part of the reason I originally looked into it, for those who get the reference) Mini which is a little USB device, and a smart card. Some software integrates smoothly into browsers for most logons, and the device itself functions largely as a USB keyboard for entering passwords. Essentially if I want to store a password I click a little icon that appears in password fields, the domain is detected and saved, and the password goes into the device. If I want to retrieve a password it’s fairly automatic with websites (software detects the domain, selects the needed account and passes it to the device, device then waits for approval before entering the password), and less clunky than an average software vault for anything else (select Login on the device, scroll to the appropriate account, click the scrollwheel and the password is entered).
Yes, it does work on phones with an appropriate cable – again fairly seamlessly. Without the smartcard you can’t retrieve the passwords, and there’s also a PIN for any manual credential management (editing passwords, adding credentials manually, etc). It’s also a rather fetching little thing. There are others out there, but this is the one I have, it works smoothly, the development team are serious about their security, and I highly recommend it to anyone who suffers from professional paranoia, or just doesn’t feel comfortable sticking the keys to their house in a key safe outside.
You can also back it up to your hard drive if absolutely necessary, or to a second device if you have one, so that dropping it down the drain does not involve losing everything. Each comes with a spare smartcard (either for a backup of the encryption key, or for a second user) which can be used as your spare, to decrypt a backup, or for a second user of the device (with a different encryption key obviously). It’s also relatively cheap at $79.
It will also work nicely with VeraCrypt for entering passphrases, so is a good way to maintain solidly encrypted partitions with different passphrases for different projects.
There is a lot of advice floating around about the GDPR – for everyone from large enterprises to small business. What I haven’t seen much of (though I have seen some) is an attempt to relate it to self-employed or freelance individuals, sole traders, and small partnerships. Recently my wife came across some questions about it on one of her social media translator groups where there were concerns about how it will impact these groups.
The advice for SMEs and larger is generally very official, designed for consumption by the legal and technical teams of a company. That’s great for a company which has those, but doesn’t apply so much to a sole trader who doesn’t specialise in law and IT. So I offered to summarise as best I could, and translate things a little. Before I do that I need to make a couple of things clear:
- This post is aimed to make the GDPR understandable for sole traders and other small businesses, I do not aim to present or suggest solutions here, simply try and help to ensure that the responsibilities and duties are understood appropriately.
- This is not official advice from a lawyer or similar and you should not lean on it if you have a particularly complex situation, instead consult a professional who is willing to put official advice in writing and has liability insurance.
- This first post is a brief summary – I will be skimming over the legislation, as I don’t know which are the most pertinent questions to go into depth. If you have any questions please get in touch, or post a comment, and I’ll happy elaborate on any areas of confusion or concern.
Principles of the GDPR
The GDPR is based around a number of principles, largely building and elaborating on existing principles in data protection legislation.
- Lawfulness, fairness and transparency: treat personal data according to the law, fairly, and be open and transparent about your usage of it with the subjects of the data
- Purpose limitation: only collect and use data for clearly defined purposes, do not use it for anything outside of those purposes (transparency applies here, as the data subjects must be informed of the purposes)
- Data minimisation: you should only keep the most limited data you can which is adequate and relevant to your purposes in processing
- Accuracy: personal data you hold must be accurate, and where necessary kept up to date
- Storage limitation: this is more an extension from data minimisation – you must not hold data in a form that allows identification of subjects longer than necessary for your stated purposes, note that this permits anonymisation of data for further storage and processing
- Integrity and confidentiality: make sure that the data is secure, using (and this is the key word) appropriate technical or organisational measures
- Accountability: the data controller (different from the data processor, we’ll get to that) is responsible for and must be able to demonstrate compliance with the GDPR legislation
GDPR Data Subjects, Processors and Controllers
The other three key terms that come up in the GDPR are about who it applies to. Here we have data subjects, processors, and controllers. Subjects is fairly clear, it refers to the subjects of the data being gathered and their rights to control that data. Specifically their right to be informed of any data held on request, and their right to have it shown to them or removed on request. Processors and controllers are where some confusion comes in, but are quite simple. The controller is the one who decides what the data is to be used for, while the processor is the one who carries out those uses. For sole traders and other small businesses these are almost certain to be the same people – although there will be cases where they are not (where your business is about providing analytical resource and expertise to third parties, for example).
Contractual Basis for Processing
I’m going to end with this section, for now, as it is the area which seems to raise the most concern. As mentioned if anyone has questions around other areas, please get in touch or comment and I’ll happily expand this series to address them, but this I really wanted to cover.
One of the most common questions I have heard is whether the GDPR will interfere with normal business, in particular starting a new business relationship with someone. Do you need to e-mail them to get informed consent, keep them notified that you’ll be storing their contact details in your address book/CRM, and so on? Marketing is a bigger, separate subject, so if it’s asked about I’ll go into it in a separate post.
Essentially if you are holding and processing someone’s personal data for the purposes of fulfilling an agreed contract and/or agreeing a contract then you have a lawful basis for processing. Contract here refers to any agreement that meets the terms of contract law (not necessarily written down, but means that terms have been offered and accepted, you both intend for the terms to be binding, and there is an element of exchange).
The good news is that this will apply if you are establishing a relationship and contract with a new client. It will also apply if, as part of the contract, they are asking you to process their personal data (i.e. getting a personal document translated to another language). What is important is that when you obtain the data you ensure the client/customer/third party is informed on how you will be using it, why you will be using it, what you will be using it for and how long you intend to keep hold of it.
Basically a lot of the GDPR boils down to being transparent with people about what you are doing with their data, taking responsibility and accountability for data you hold, and acting in a reasonable manner. If you are clear and open with customers about what you will do with their data (and remember, GDPR is opt-in, not opt-out, so the consent must be informed and documented), and keep track of data assets you hold then you should be fine. There’s a lot of use in the legislation about ‘reasonable’ measures, views, expectations and so on. Essentially – if someone contacts you in order to set up a contract and do business with you, particularly if the only personal data you obtain are contact details, you will need to take reasonable security measures to secure those contact details, and not misuse them to send out marketing e-mails without the explicit consent of the data subject.
Treat other’s data as you’d expect a responsible business to treat yours, and you should be fine. If you have questions either around other aspects, or around more practical security matters for a sole trader or small business (encryption, systems to use, what counts as ‘secure’) then please do leave a comment or get in touch directly.
I’ve been advised to add a small note around some specific scenarios:
- if you are working with a document with a signature, even if there is no other personal data, then once you are finished with the document you should destroy it and/or ensure that the signature is unreadable (there may be reasons to keep the document, in which case it should be fully anonymised if you have no need of the data)
- if you keep contact details (you do) then you should ensure that people are informed you are keeping them, and make sure they have a way to ask for the data you hold on them, ask for changes, ask for it to be erased, ask you to restrict the purposes you use it for (with contact details this essentially maps to asking for it to be erased I imagine), ask for an electronic copy, and object to you holding it – this is a large area, and I suspect will involve a separate post to cover fully
- having a password on your computer is not a way to protect your data from theft unless you have also set up encryption, or are storing all data on the cloud rather than the local machine, or other circumstances which may apply – if I get some questions on this then I’ll go into more detail, but it’s fair to say that whole-disk encryption along with a password is a reasonable option, while an unencrypted disk is not
I’m currently studying for a postgrad in Cyber Security, and have had a practical assignment come up. Obviously I won’t be going into the details of the assignment here, but it’s not unreasonable to say that it involves measuring wireless network performance and throughput under a selection of different conditions.
The original labs for this were done during the lecture, and so I have a set of results which I could use, but since there were too many variables for me to feel comfortable (multiple students connecting at different times for traffic analysis, above anything else) with those results, and we only took a limited number of results for each environment, I’ve decided that I can do better on my own, and to build my own lab for the purpose. More importantly I can automate it, so that the extent of my effort in collecting the results can be reduced to kicking it off overnight and starting analysis in the morning.
So firstly there’s the shopping list, which is mercifully short and low-budget:
- A desktop or laptop PC with enough grunt to run a couple VMs, a couple of network ports, and as many USB ports as possible (that one’s important).
- Two USB wifi dongles capable of running in monitor mode – the standard in this area seems to be the TP-LINK TL-WN722N (currently around from Amazon), I keep a few of these lying around because they keep coming in handy.
- A router which can support different network and security protocols, and can run an SSH server for configuration, for routers I pretty much always go with the GL .inet range, again because I have a few lying around for different projects ( from Amazon)
- Some network and USB cables.
The aim is to minimise the amount of running around required, and the requirement to have multiple physical systems involved. The steps to create the lab were also pretty easy:
- On the physical machine, make sure the hypervisor will let you assign a wireless dongle to each of the two VMs – this one took me some headbanging to sort out, dealing with issues around how Hyper-V handles network cards, and other issues around VirtualBox’s handling of USB dongles. Final solution was to handle the networking side in the host OS, and just assign them as network connections to the guest Ubuntu machines via VirtualBox
- Create two VMs (I’m planning to add a third for management purposes, so a whole suite of tests can just be scripted to run overnight, but this is a start) and drop an OS onto them (after fun trying to get atheros drivers on Linux I ended up with an older Ubuntu distribution, which worked just fine)
- Connect the router with a network cable, and the two USB dongles with extension cables, to your host machine, for now the two VMs can share the host machine’s network connection (for software downloading purposes)
- Install iperf on each of the guest machines, and set up the wireless network as desired for testing
- Switch the network connections for the two guests over to one wifi dongle each, connect them to the access point via the host system, and check that they can talk to each other happily
- Run iperf in server mode on your server guest VM, and in client mode on the client, be stunned at the variance of wifi signals with very little change in environmental conditions
So now it’s running through the first set of tests, followed by a reconfiguration of the access point, and repeat. Next step once that’s all done is to play around with scripting until I can just give it a specification to test out for a while, and leave it running (I’m curious about things like different key lengths, window sizes, and so on and whether they’ll have an impact). I’ll put the script together and run through it next time, and after that will take a look at various methods for intercepting, cracking and spoofing wireless networks, by extending the lab capabilities.