Verification of conformity
Prove that you have protected the right data in the right way
Challenges
Additional data privacy laws in the US, Europe, and other international jurisdictions have been enacted and are currently being enforced. CISOs and Data Governance teams responsible for protecting sensitive data must also demonstrate they have protected this data in the right places and in the right way.
Data Loss Prevention (DLP) systems and Data masking software can detect and de-identify personally identifiable information (PII). How well do you document your procedures? How easy is it to find and modify specific protection functions when something needs to be remade or done differently? How can the risk of re-identification based on quasi-identifying data be measured and mitigated? And even the best data masking tools for complying with one privacy law are not necessarily the best solution for another law.
Solutions
For recognition control, check the field-level protection functions in the self-documenting, human-readable job scripts of the software products. IRI FieldShield and IRI CoSort (SortCLor the data management platform IRI Voracity provided.
For verification purposes, log all jobs in the query-ready XML audit file. The audit trail contains the job script showing the protection technique(s) applied to each field in each processed table or file. For FieldShield jobs, the audit trail contains the complete contents of the script as well as the regulated and unregulated components contained within it. For more information on Operational Governance System (OGS) infrastructure for these jobs can be found in this article; additionally, there is an integrated log-wrangling tool that allows you to query and export compliance- and performance-related information from the logs. The log also contains other job metadata, such as:
- used protected library function(s)
- Encryption codes or de-identification codes
- Input and output tables or files
- User who executed the job as well as the applicable policy file
- Order start and end times
- Number of records processed per phase, in total, and per second
For prevention control, you can check your orders to verify the protection of output fields by a developer before execution.
For instance, masking the SSN field in a payroll feed is a matter of connecting to your sources (or existing orders) and clicking through a new order wizard, or modifying existing parameters in a dialog or script. Some of the functions you can apply (ad hoc or usually) include:
- Encryption and decryption
- Anonymization through pseudonymization
- Data obfuscation (blurring), hashing, deletion, or scrambling
- De-Identification and Re-Identification Using Twiddling
- Field Editing
As a Compliance Officer, you see the safeguards in every self-documenting job script. Upon approval, the job can be saved or executed on a local or remote server using the IRI program.
After execution, the order script can be isolated and protected for reuse in production.
FieldShield also includes a re-identification risk scoring module that statistically measures the likelihood that a data record can be attributed to an individual based on the unprotected quasi-identifying (demographic) attributes. Additional anonymization techniques, such as blurring and bucketing, which reduce the risk of re-identification while maintaining the utility of the data for research and marketing purposes, are also included.
At IRI DarkShield a comprehensive set of dashboard charts is generated, showing which data was found (and masked, if applicable) in structured, semi-structured, and unstructured sources. One of these charts is a bubble chart that allows you to rank the PII risk in each data source—a kind of instant vulnerability analysis (heatmap) resulting from aggregated data discovery (search) jobs.
These data can also be reviewed in machine-readable search and masking artifacts (JSON log files) in the IRI Workbench or exported to SIEM tools such as Splunk Enterprise Security, IBM QRadar, Microsoft Sentinel, Excel, and other SIEM/SOC and log visualization tools for further analysis and response.
At IRI CellShield EE Both the data discovery results and the masking audit trails are provided in Excel and can be linked for export via email, to Splunk, and to Datadog.