GDPR ImplicationsThis Dixon's data breach has a few interesting and noteworthy twists for all organizations that are under GDPR compliance. Since the breach that targeted Currys PC World and Dixon’s Travel stores happened in 2017, before GDPR came into effect, it is technically not covered by the standing legislation. They do not need to follow the new rules. So, this would imply that fines, SLA’s for notification, and forensics are out of scope for the announcement. However, it does serve as precedence for any organization that identified a potential breach before 25 May 2018 looking to perform a public disclosure. Any new breach identification after 25 May must comply with the new regulations. Dixon’s would have failed the new disclosure policies.
It All Boils Down to Detection, Which Brings up an Interesting QuestionAnton Chuvakin from Gartner posted an interesting question to Twitter yesterday:
"Are you aware of any organizations that have turned off Threat Detection in order to avoid the GDPR 72 SLA for breach notification?"What is startling is that nearly 10% of security professionals confirmed in this unofficial survey, that they have heard of organizations turning off threat detection in order to avoid GDPR compliance requirements. Over 30% reported that they have seen much worse. Let that settle in for a moment. While this was unofficial, it should raise some serious concerns. If this was Dixon’s Carphone, the breach in July 2017 may not have been detected for a long time, or never at all, and a user’s personally identifiable information (PII) would potentially be all over the dark web with very little accountability. Disabling security technology, delaying breach notification, and shortcutting security best practices to avoid doing the “right” thing is just NOT acceptable. The sheer fact this breach took 11 months for disclosure and hides behind GDPR dates is almost cowardly in itself. It also raises questions about the effectiveness of GDPR required training, disclosure processes, and whether the mindset of a breach occurring before 25 May is actually not legally bound by GDPR. While the breach notification is stunning due to the linkage to GDPR, it is truly nothing new. Only 105,000 credit cards are reportedly at risk but the questions it raises are far reaching beyond this blog. As a security professional, I would encourage every user, executive, and company to do the right thing. Cybersecurity is the responsibility of everyone, regardless of the regulations and splitting of hairs on GDPR dates, and formulating diversionary tactics is just immoral in our next generation economy. Consider what you would want someone else to do with your information if it was breached before you subvert away from doing the right thing. I think it took much too long for this breach to become public and so should you. To learn more about GDPR compliance, download this guide, or contact us for a strategy session.