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DLP Policies and Controls

Designing Effective Policies

After defining the strategies and technologies used to implement DLP, we need to enforce them with policies and controls. This lesson will cover the key aspects of designing effective DLP policies, implementing DLP controls, and managing exceptions and false positives.

Designing Effective Policies

Effective DLP policies are the foundation of a robust data protection strategy. Here are some key considerations when designing DLP policies:

  1. Data Classification: Clearly define and categorize sensitive data types (e.g., PII, financial data, intellectual property). For example:

    • PII (Personally Identifiable Information): This includes any information that can identify an individual, such as name, social security number, date of birth, and other similar data.
    • Financial Data: This includes any data related to financial transactions, such as bank account numbers, credit card information, and payment details.
    • Intellectual Property: This includes any data related to the company's proprietary information, such as trade secrets, patents, and copyrights.
  2. Risk Assessment: Identify potential risks and vulnerabilities associated with each data type. For example:

    • PII: Risks include identity theft, financial fraud, and privacy violations. Vulnerabilities may include weak access controls, unencrypted storage or transmission, and social engineering attacks targeting employees with access to PII.

    • Financial Data: Potential risks include financial theft, insider trading, and market manipulation. Vulnerabilities could include insufficient encryption, inadequate segregation of duties in financial systems, and compromised payment gateways.

    • Intellectual Property: Risks include loss of competitive advantage, revenue loss, and damage to company reputation. Vulnerabilities might include inadequate access controls, insecure file sharing practices, and industrial espionage attempts.

  3. Regulatory Compliance: Ensure policies align with relevant regulations (e.g., GDPR, HIPAA, PCI-DSS). For example:

    • GDPR: Requires organizations to report data breaches to the relevant authorities within 72 hours.

    • HIPAA: Mandates the use of unique user identification for all individuals accessing electronic protected health information (ePHI), such as assigning a unique username or number for identifying and tracking user identity.

    • PCI-DSS: Organizations must install and maintain a firewall configuration to protect cardholder data. PCI-DSS also requires organizations to encrypt transmission of cardholder data across open, public networks using strong cryptography. Additionally, it mandates that organizations restrict access to cardholder data by business need to know, and assign a unique ID to each person with computer access.

  4. User Awareness: Develop policies that are easy to understand and follow for all employees.

    • Clarity: The policy should be written in clear and concise language that is easy to understand.
    • Consistency: The policy should be applied consistently to all employees.
    • Communication: The policy should be communicated to all employees in a clear and concise manner.
    • Training: The policy should be supported by training and education for all employees.
    • Enforcement: The policy should be enforced consistently and fairly.
    • Review: The policy should be reviewed and updated regularly.
  5. Scalability: Design policies that can adapt to the organization's growth and changing needs:

    • Flexible: The policy should be flexible enough to adapt to the organization's growth and changing needs.
    • Modular: The policy should be modular enough to be adapted to the organization's needs.
    • Comprehensive: The policy should be comprehensive enough to cover all aspects of the organization's operations.
    • Comprehensive: The policy should be comprehensive enough to cover all aspects of the organization's operations.
  6. Regular Review: Establish a process for periodic policy review and updates. For example, a policy should be reviewed and updated every three years.

Managing Exceptions and False Positives

Even well-designed DLP systems can generate false positives or require exceptions. Effective management of these issues is crucial:

  1. Exception Handling: Develop a process for reviewing and approving policy exceptions. For example:

    • Review: The exception should be reviewed and approved by the DLP manager.
    • Documentation: The exception should be documented in the DLP policy.
    • Communication: The exception should be communicated to all employees in a clear and concise manner.
    • Training: The exception should be supported by training and education for all employees.
    • Enforcement: The exception should be enforced consistently and fairly.
    • Review: The exception should be reviewed and updated regularly.
  2. False Positive Reduction: Every time a false positive is detected, the DLP system should be tuned to minimize the likelihood of similar false positives in the future. For example, if a DLP system flags a legitimate email as suspicious, the policy that triggers the DLP system should be adjusted to avoid flagging legitimate emails in the future.