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Data Loss Prevention - an ICO point of view

Regulation for PETs
within the UK
The fact that the UK Information Commissioner has taken the
trouble to issue guidance on PETs renders it hardly
surprising that he has also adopted a PETs-based regulatory
strategy. This is best evidenced by his November 2007
enforcement strategy for laptop computers and portable
storage media, titled “Our Approach to Encryption”. This
strategy teaches the following:
“There have been a number of reports recently of
laptop computers, containing personal information
which have been stolen from vehicles, dwellings or
left in inappropriate places without being protected
adequately. The Information Commissioner has
formed the view that in future, where such losses
occur and where encryption software has not been
used to protect the data, enforcement action will be
pursued.
The ICO recommends that portable and mobile
devices including magnetic media, used to store and
transmit personal information, the loss of which could
cause damage or distress to individuals, should be
protected using approved encryption software which
is designed to guard against the compromise of
information.
Personal information, which is stored, transmitted or
processed in information, communication and
technical infrastructures, should also be managed
and protected in accordance with the organisation’s
security policy and using best practice methodologies
such as using the International Standard 27001.
Further information can be found at 27001-
online.com.
There are a number of different commercial options
available to protect stored information on mobile and
static devices and in transmission, such as across
the internet.
Encryption software uses a complex series of
embedded mathematical algorithms to protect and
encrypt information. This process hides the data and
prevents any inadvertent access or unauthorised
disclosure of information. Since encryption
standards are always evolving, it is recommended
that data controllers ensure that any solution which is
implemented, meets the current standard such as
the recommended FIPS 140-2 standard or
equivalent.”
We can draw many conclusions from the Commissioner’s
approach to encryption, with an important one being that it
is highly likely that the Commissioner will start to regulate
for the absence of other PETs. As such, it is possible that
the Commissioner will eventually regulate for DLP, once
he becomes aware of how DLP can increase an
organisation’s security rating by a significant order of
magnitude when compared to encryption technologies
alone.
What is DLP?
As one of the technology analyst companies puts it, a DLP
solution consists of “tools to prevent inadvertent or
accidental leak or exposure of sensitive enterprise
information using content inspection technologies”. In
general terms DLP software works as follows:
Sensitive information within a network is identified
and marked as such. Use and access policies can
be attached to this information.
Processing of sensitive information across the
network is tracked.
• Where processing of sensitive information is in breach
of policy, that processing is blocked.
• A person acting in breach of policy can be notified of
their policy violation, as part of an educational
programme.
• The data controller is informed of policy violations.
If all of this functionality is distilled down to its essence it
will be appreciated that DLP keeps sensitive data within
the network; sensitive data can only be moved from the
network, whether by TCP/IP protocol or from an endpoint
where that movement is in accordance with policy.
Consequently, DLP software has the potential to eliminate
many of the security risks that might otherwise lead to data
loss.
Conclusion
Eventually DLP will be regarded as part of the de facto
data security standard, in much the same way as
encryption nowRegulation for PETs
within the UK
The fact that the UK Information Commissioner has taken the
trouble to issue guidance on PETs renders it hardly
surprising that he has also adopted a PETs-based regulatory
strategy. This is best evidenced by his November 2007
enforcement strategy for laptop computers and portable
storage media, titled “Our Approach to Encryption”. This
strategy teaches the following:
“There have been a number of reports recently of
laptop computers, containing personal information
which have been stolen from vehicles, dwellings or
left in inappropriate places without being protected
adequately. The Information Commissioner has
formed the view that in future, where such losses
occur and where encryption software has not been
used to protect the data, enforcement action will be
pursued.
The ICO recommends that portable and mobile
devices including magnetic media, used to store and
transmit personal information, the loss of which could
cause damage or distress to individuals, should be
protected using approved encryption software which
is designed to guard against the compromise of
information.
Personal information, which is stored, transmitted or
processed in information, communication and
technical infrastructures, should also be managed
and protected in accordance with the organisation’s
security policy and using best practice methodologies
such as using the International Standard 27001.
Further information can be found at 27001-
online.com.
There are a number of different commercial options
available to protect stored information on mobile and
static devices and in transmission, such as across
the internet.
Encryption software uses a complex series of
embedded mathematical algorithms to protect and
encrypt information. This process hides the data and
prevents any inadvertent access or unauthorised
disclosure of information. Since encryption
standards are always evolving, it is recommended
that data controllers ensure that any solution which is
implemented, meets the current standard such as
the recommended FIPS 140-2 standard or
equivalent.”
We can draw many conclusions from the Commissioner’s
approach to encryption, with an important one being that it
is highly likely that the Commissioner will start to regulate
for the absence of other PETs. As such, it is possible that
the Commissioner will eventually regulate for DLP, once
he becomes aware of how DLP can increase an
organisation’s security rating by a significant order of
magnitude when compared to encryption technologies
alone.
What is DLP?
As one of the technology analyst companies puts it, a DLP
solution consists of “tools to prevent inadvertent or
accidental leak or exposure of sensitive enterprise
information using content inspection technologies”. In
general terms DLP software works as follows:
Sensitive information within a network is identified
and marked as such. Use and access policies can
be attached to this information.
Processing of sensitive information across the
network is tracked.
• Where processing of sensitive information is in breach
of policy, that processing is blocked.
• A person acting in breach of policy can be notified of
their policy violation, as part of an educational
programme.
• The data controller is informed of policy violations.
If all of this functionality is distilled down to its essence it
will be appreciated that DLP keeps sensitive data within
the network; sensitive data can only be moved from the
network, whether by TCP/IP protocol or from an endpoint
where that movement is in accordance with policy.
Consequently, DLP software has the potential to eliminate
many of the security risks that might otherwise lead to data
loss.
Conclusion
Eventually DLP will be regarded as part of the de facto
data security standard, in much the same way as
encryption now is.

Cryptic Comment

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