By Dave Williams, 3M
Often, the General Data Protection Regulation (GDPR) is talked about in the context of digital communications and ensuring that data is within compliance requirements. However, GPDR is a principle-based regulation, which means rather than being given a list of prescriptive guidelines, it is up to financial services organisations to identify and then assess risks.
In practice, that means that GDPR compliance has been broken if privacy has been breached via any method, such as taking a photograph of or even viewing confidential information on a smartphone or laptop screen, or removing a document from an unattended briefcase in a café.
Location is immaterial: employees are obliged to protect company data whether they are working from an office, in a public place, or even from home (while no-one is suggesting flatmates or family would do anything with confidential or sensitive data, in their own interests they should be protected from that exposure).
In the run-up to GDPR’s introduction in May 2018, 3M sat down with Forrester Research analyst Enza Iannopollo who said: “All it takes is some sensitive customer or employee data being exposed to the wrong set of eyes to result in a potentially highly detrimental—and highly publicised—data breach.”
While GDPR has increased the spotlight on visual privacy, it was already a topic that more organisations were beginning to take more seriously, including the banking sector, where use of on-screen filters and other privacy measures were already being widely adopted. Visual privacy has been either implicit or explicit in other industries for several years, and is sometimes included as part of ISO27001 certification too.
In its Data Security section, the UK’s Financial Conduct Authority (FCA) says: “Data security is not purely an IT problem”, and “Firms of all sizes should think carefully about how they secure their data. Having good data security policies and appropriate systems and controls in place will go a long way to ensuring customer data is kept safe. However, you need to make sure your employees understand the policies and procedures and your firm keeps up-to-date when people move on,” and also: “Look at the physical safety of your business premises.” The FCA’s predecessor, the Financial Services Authority (FSA), covered visual security (including phone cameras and mobile workers).
Forrester Research’s Enza Iannopollo also made the excellent point that, “ Visual privacy is not just about meeting compliance requirements, it’s about protecting a firm’s most valuable assets.” Fortunately, more organisations are beginning to regard ‘shoulder-surfing’ and ‘visual hacking’ as integral to both compliance and information-security strategies. Visual hacks are relatively fast and easy to achieve, as well as requiring zero specialist skill. Breached information could be used for malicious purposes, such as fraud, stolen credentials, or sold to a third party.
The scale of the risk
The exact scale of the risk is hard to put numbers around, but studies and anecdotal evidence indicate that it is very real, and potentially big. For example, back in 2016, global security specialist organisation The Ponemon Institute conducted the Global Visual Hacking Experiment on behalf of 3M, covering eight countries and 157 trials carried out by a ‘white hat hacker’, posing as a temporary officer worker (with the permission of the participating companies). All trials took place in full view of other workers, and included various methods of collecting data, including taking documents from desks, and using a phone’s camera to photograph people’s screens. Not only were the hacks successful in an average of 91 per cent of attempts, the hacker was only challenged in 30 per cent of attempts.
The Open Spaces Study (also carried out by The Ponemon Institute for 3M), found that nine out of 10 people said they had caught someone looking at data on their laptops when in public. This is no surprise, given that many of us will have seen something on someone else’s screen, and sometimes that could be information that is confidential or sensitive.
How to reduce the risk of visual hacking
While visual privacy may be easy to carry out, arguably it is also easier and faster to guard against compared to other aspects of information security. A first step is to make sure that everyone within the company is aware of visual privacy’s importance, its role in GDPR compliance, plus their responsibilities to take appropriate measures. All this needs to be mandated from management downwards and across the board, including: IT, facilities management, human resources, finance, legal, risk, compliance, sales, marketing and customer-facing teams.
Staff should feel that they can politely challenge anyone within their office buildings not wearing appropriate ID, whom they do not recognise, or are in part of the site with restricted access. Simple steps to reduce the potential of sensitive or confidential information include: clean-desk policies; putting confidential documents back in locked cabinets when not in use; and not leaving documents uncollected in copier or printer trays. Consider using the ‘pull printing’ function found on many office multi-function-printing (MFP) devices to only release a document to an authorised recipient.
When working in public, reinforce to employees that they should not leave their electronic devices, documents or briefcases unattended, even if just for a couple of minutes. Encourage staff to sit with their backs against a barrier such as a wall, instead of in the middle of a room where their screens may be visible to anyone passing behind them. If not already in place, mandate the use of automatic log-ins and screensavers, and also consider applying privacy filters, which make it extremely hard to view on-screen information unless at close-range and from straight-on (viewers otherwise just see a blank view).
As many financial organisations are adjusting to new ways of working right now — trying to find ways to work smart anywhere — keeping data safe and achieving GDPR compliance may pose additional challenges for many organisations. While visual privacy is just one of aspect of that task, it is both important and addressable.
This is a Sponsored Feature
Seven lessons from 2020
Rebeca Ehrnrooth, Equilibrium Capital and CEMS Alumni Association President
Attending a New Year’s luncheon on 31 December 2019, we played a game that involved predicting the world in 2020. Some of the questions included: would Uber become profitable? Would the three-decade bond rally finally come to an end? Would the US hit a recession?
Unlike any of our predictions based on a traditional approach to business and predicting, we now know that 2020 became the year where business, professional and personal plans were turned upside down, reshaped and put-on hold. The proverbial black swan had arrived.
As revealed in a new CEMS Guide to Leadership in a Post-COVID-19 World, to which I contributed, the COVID-19 pandemic has exposed deficiencies in the 20th Century vision of leadership, giving a rare opportunity to question the status quo.
So, what are the main lessons from 2020?
- Humans are enormously adaptive. This is not an extinction scenario. The world is getting used to dealing with global human disaster which may become a recurring event. Life continues guided by new parameters.
- No sector or country is immune to rapid change. Just as the leveraged finance and equity markets ground to a halt during the Global Financial Crisis, we have seen a disruption in the financial markets (including M&A) in 2020, including a significant redistribution of wealth between sectors; think tech vs airlines and the hospitality industry. When a market is disrupted it has secondary and tertiary effects such as less work for accountants, lawyers, financiers etc.
- Location is not as important anymore. The belief that finance staff need to be based in one of the financial capitals to be effective has been forever altered. Pursuing a career in finance from anywhere is becoming possible. However, it’s likely that over time, financial controls and human interaction will move the work model back towards the traditional office approach, as work is a critical sanctuary for people. While working from home may allow more time for family, chores and sports, it is mainly effective for people who already have their internal and external networks. For junior employees it presents a notable challenge as they may be forced to spend their formative years without a chance to really build their networks.
- Change is likely to be lasting. The opportunity for alternative finance and tech focused providers is enormous and 2020 will accelerate this shift. For example, many retail banks are providing rather poor customer service, blaming the pandemic. Even the most loyal customers will be heading elsewhere. For recent graduates and current students this is a major shift; future winners and key employers may not be names we are used to seeing in the headlines.
- There will be a spotlight on leaders with visionary strategy and understanding of the operations. 2020 showed many politicians and business leaders behaving like they were playing a game of snakes and ladders, rather than executing a thought-out strategy. The next wave of thoughtful leadership is urgently required.
- Collaboration leads to success. The definition of a pandemic is an infectious disease prevalent worldwide. A global problem requires a collaborative solution rather than each country and industry on their own. Quoting Steven Riley, professor of infectious disease dynamics at Imperial College London: “Once you have the knowledge and you share the knowledge, then you are able to take measures to push transmission much lower”. This principle is transferable to management education. In a world more complex than ever, investing in a degree is hard currency. Combined with the full global alumni network, corporate partners and schools, CEMS is capital that doesn’t depreciate.
- Resilience has become a watch word. Saint-Exupéry’s quote resonates with me: “If you want to build a ship, don’t drum up people to collect wood and don’t assign them tasks and work, but rather teach them to long for the endless immensity of the sea.” We are in a new paradigm – so prepare for the next change. For COVID-19, while we hope that the vaccine will soon upon us, the broader long-term positive challenge remains.
Data after Brexit: How does the end of the transition affect GDPR?
By John Flynn, Principal Security Consultant at Conosco
The UK has officially left the European Union now that the transition period has ended on January 1st 2021. But this could raise issues with one of the biggest bugbears for many companies – the international transfer of personal data.
Businesses can relax, somewhat – GDPR, which took businesses months to get their heads around, is not being replaced. It will continue as the UK GDPR 2018, and will still be based on the criteria of the Data Protection Act of 2018. However, the UK will retain the right to change the UK GDPR as it sees fit in the future.
The main changes apply to those who receive data coming into the UK from Europe. Transfers from the UK to other countries can continue under existing arrangements.
We know it can be difficult to cut through the legal jargon, so we have simplified what you need to know to protect yourself and your data:
1 – Update your privacy notice
Most businesses do not have the correct clauses in place ahead of January 1st, potentially exposing their liability, should something happen to their data. All company privacy notices online will need to be updated to specifically state ‘UK GDPR’, as opposed to ‘EU GDPR’. You will also need standard contractual clauses in place, which cover both parties – those transferring and those receiving the data.
The Information Commissioner’s Office (ICO) has a list of what needs to be included in the standard contractual clause here. The ICO will remain the UK regulator for data protection, regularly liaising with each EU member state.
This also applies to Multi Corporate Groups who operate in multiple countries, who need to update their documentation and privacy notice to expressly cover the data transfers. The UK has applied for an adequacy assessment, which would negate the need for contractual clauses, however this has not yet been approved by the EU.
2 – Data privacy assessments
Any company which runs applications and software should always perform a Data Privacy Impact Assessment. This was also in the guidelines before, but these assessments are now more important for those who outsource their IT operations internationally.
For example, when using a service such as a cloud-based system, the company must be sure that its service provider adheres to UK GDPR and stores the data within the European Economic Area (EEA), or has a binding corporate agreement with the company, where data is stored outside of the EEA. You should also, as mentioned above, make sure that a contractual clause is in place.
3 – Review local legislation
Contracts should now have contractual clauses that specify the responsibilities of the data controller and the data processor. If you are receiving personal data from a country territory or sector covered by a European Commission adequacy decision, the sender of the data will need to consider how to comply with its local laws on international transfers. You should check local legislation and guidance in this case.
4 – Cyber Security health check
The ICO is increasing its capacity and efforts to crack down on data breaches, post-Brexit. Now is a great time for all companies to have a health check to understand their Information Security posture and GDPR compliance. Nobody wants to be caught handling data improperly and fined when it could have been prevented with education and training.
A gap analysis performed by an expert is money well-spent. It’s also a fact that companies that have cybersecurity and Information Security controls are not only able to better defend against attacks but are also far better placed to recover from an attack.
It’s important that all businesses – large and small – are properly preparing their data storage and transferring for the 1st January. ICO has been busy setting examples by fining large, high-profile companies for failing to keep millions of customers’ personal data safe.
It will continue to come down hard on the data breaches of personal identifiable information and special categories of data. The saying ‘prevention is better than a cure’ rings truer than ever this year, and you will thank yourself if you make the efforts to properly store your data now, and not when it’s too late.
2020 reflections and 2021 outlook
By John Hunter, Head of Banking and Fiduciaries, Finance Isle of Man
Reflections on the most surreal year
The Covid-19 pandemic has completely changed the world as we knew it, resulting in catastrophic loss of life and fears of a downturn hang over global economies like a sword of Damocles. In the UK, the new strain has further exacerbated the situation. As I am sure many have already said we are living in what could be called the most surreal times. People have been trying to cope with this “new normal”, by changing their lifestyles and evolving behaviours.
The Isle of Man responded swiftly to the pandemic by closing its borders and enforcing social restrictions which everyone respected and adhered to. Socially and culturally the Island demonstrated all the good things that come from living on a relatively small Island where community still means so much.
The Isle of Man’s financial services sector adapted quickly, seamlessly transitioning to working from home. The banks too adopted flexible remote working practices and continued to support clients around the world helping them navigate the challenging situation and making the most of any opportunities that arose.
Although there is no substitute for face-to-face interactions, we all embraced web-conferencing platforms like Microsoft Teams and Zoom to stay connected with contacts around the world and build and nurture business relationships, whether it was with financial services firms or high net worth individuals looking to relocate to the Island.
Furthermore, a priority for the Isle of Man has been to reinvigorate the business and cultural ties with South Africa. In a normal world, we would have travelled to the country, held in-person meetings with businesses and industry representatives and talked about building on our wonderful historic ties. However, because of the scale and breadth of disruption we had to change all our plans! We hosted a virtual roadshow which comprised a series of webinars exploring why it has never been more important for South African businesses and individuals to choose the right jurisdiction for long term financial planning.
Looking ahead to the future
We are all hoping that the global rollout of vaccines will provide the pathway to some form of return to normality and all the things people are missing will be back. Like amidst all periods of immense turmoil, interesting, new possibilities have emerged such as the revolution in work culture and a renewed importance of being close to nature and green spaces is. And these possibilities can help reshape society for the better.
The global economic recovery and rebuild might seem further away in the current environment especially amidst the new lockdowns. But we are confident in the resilience of economies and are hopeful that different industrial sectors and governments working together would result in green shoots.
The financial services industry has an important role to play in getting the world economy back on its feet. It is a core component of the solution to continue facilitating the financing of corporates, as well as to develop sustainable finance and nurture digital technologies which have proven to be vital during the pandemic. The sector should continue its cooperation and collaboration with governments and regulators to ensure efficient capital flows and financial stability for businesses and individuals.
Banks too have a crucial role to play as they are instrumental to the effective transmission of monetary policies and stimulus packages. As mentioned in a report by EY: “Financial insecurity in the wake of COVID-19 will require banks to boost consumer confidence and help build a more resilient working world.”
We expect the Isle of Man’s financial services sector and banks to continue navigating the situation with resilience as they have been doing thus far and contributing to the global recovery process. Also, we truly hope this will be our busiest year ever (subject to our ability to travel), with an extensive global schedule of planned activity to promote the Island as an international financial centre of excellence and innovation. Personally, I had planned to be in South Africa for the British & Irish Lions tour, but regrettably, it might not take place and as such we will look forward to catching up with friends there as and when we can.
No doubt, there are significant challenges for the world ahead but as Albert Einstein said: “in the midst of every crisis lies great opportunity”. And it is this opportunity that we all need to work together to identify and make the most of. We are confident that in 2021 the Isle of Man will continue to support financial services businesses help their clients, employees, and the wider society through these surreal times. We are all in this together.
FSS and India Post Payments Bank AePS Partnership Advances Financial Inclusion in India
New Delhi, January 12th,2020: FSS (Financial Software and Systems), a leading global payment processor and provider of integrated payment products,...
Seven lessons from 2020
Rebeca Ehrnrooth, Equilibrium Capital and CEMS Alumni Association President Attending a New Year’s luncheon on 31 December 2019, we...
Over a quarter of Brits now have an account with a digital-only bank
The number of Brits with a digital-only bank account has gone up by a percentage increase of 16% Almost 1...
How fintech companies can facilitate continued growth
By Jackson Lee, VP Corporate Development from Colt Data Centre Services The fintech industry is rapidly growing and, in the...
BNP Paribas joins forces with Orange Business Services to deploy SD-WAN for 1,800 retail sites in France
Co-construction approach ensures business continuity during deployment BNP Paribas has chosen Orange Business Services to deploy an SD-WAN solution in...
2021 Predictions: Operational Resilience Takes Center Stage
Breaking down barriers between Risk and Business Continuity By Brian Molk, Fusion Risk Management What a year! Simply put, the global...
Five Workplace Culture Trends of 2021
5 January 2021 – 2020 – a year like no other – is responsible for driving organisational change, especially workplace...
The Impact of the Digital Economy on the Banking and Payments Sector
By Gerhard Oosthuizen, CTO Entersekt. New banking regulations, digital consumers, the eradication of passwords, contactless technology – these are just...
Be Future-Ready: The Case for Payments as a Service (Paas)
By Barry Tarrant, Director, Product Solutions, Fiserv Over the years, financial institutions have faced a myriad of changes in regulations,...
Mark Wright – No Longer an Apprentice
Just for context, you won The Apprentice and became Lord Sugar’s business partner in 2014 – you set up your...