What Are Data Protection Controls?

In today's digital landscape, the importance of robust data protection control cannot be overstated. As companies store important data across different platforms, from their own systems to third-party services, they become more vulnerable to cyberattacks. These larger attack areas are often targeted by skilled hackers. 

Safeguarding data has become increasingly critical in light of the rapid advancement of Generative Artificial Intelligence (AI) technologies. As these systems become capable of creating, processing, and handling large amounts of information, the chances of data breaches, errors, and misuse increase. Generative AI can unintentionally bring risks like poor data quality, privacy violations, and intellectual property issues. 

Moreover, the increasing reliance on AI to automate business processes amplifies the necessity of establishing comprehensive data privacy frameworks. As organisations integrate AI into their operations, they must be vigilant about the implications of algorithmic biases, which can stem from flawed data acquisition and inadequate oversight. Failing to effectively manage these concerns can lead to reputational damage and a loss of user trust, which can have long-lasting repercussions that extend beyond financial penalties. With this in mind, many businesses have started to invest in data protection to mitigate potential threats, ensuring the integrity and confidentiality of sensitive information in an era where data is not only abundant but also more vulnerable to exploitation.

Data protection is a set of strategies and is vital for any organisation that collects handles, or stores personal data. A successful data protection strategy can help prevent data loss, theft, or corruption and can help minimise damage caused in the event of a breach.

What Are Data Protection Controls? 

Operational data protection controls are procedures and rules implemented to protect systems, applications, and the organisation as a whole. If the end goal is to successfully bring data protection into action, then data protection controls are a way to guide an organisation towards achieving this.

Benefits of Data Protection Controls 

Data protection controls offer several significant benefits that are crucial for organizations in safeguarding their sensitive information, especially as these controls play a vital role in helping organizations comply with data protection regulations. Privacy laws such as the General Data Protection Regulation (GDPR) in the EU and the Personal Data Protection Act 2012 (PDPA) in Singapore mandate that companies handling personal data implement robust security measures. 

Data protection controls help in:

1. Mitigating or preventing data leaks caused by inappropriate actions from employees, whether those actions are accidental or malicious. For example, by implementing these controls, organizations can effectively block the unauthorised exit of sensitive data from their networks or ensure that the information remains protected as it travels, allowing only authorised users to access it.

2. Facilitating secure collaboration within and outside the organisation. By establishing varying levels of access depending on the sensitivity of the information, organizations can make informed decisions about sharing data with third parties or limiting access to certain individuals. This ensures that highly confidential information is only shared with those who genuinely require it for their roles, minimizing the risk of exposure.

3. Demonstrating an organisation’s compliance with privacy regulations by encrypting data, blocking unauthorized access, and conducting regular audits of data usage, thus avoiding potential legal repercussions and fines.

Information Lifecycle Management

There is a list of policies and standard operating procedures (SOPs) that addresses the gaps across the information lifecycle.

Here is an example of documented gaps across business processes in an organisation, the red areas are the ones with gaps (across the information lifecycle) in that particular process, through our DPOinBOX platform which helps organisations create and manage a data privacy management programme.

A screenshot of the documented business processes in an organisation in the DPOinBOX platform

In the screenshot above, the green boxes reflect the compliant part of the business process to the data protection law, whereas the grey reflects the non-appability of the data protection law to the area of a business process.

Types of Data Protection Controls

Data protection security controls are essential mechanisms that organizations implement to safeguard their sensitive information from unauthorized access, theft, and corruption. These controls can be categorised into various types, each serving a specific purpose in the overarching goal of data security.

The types of controls are identified as:

1. Technical controls,

2. Administrative controls and

3. Physical controls - Operational and architectural

Technical controls

In the current digital environment that is constantly processing and storing large amounts of personal data, security is of utmost importance to an organisation. Typically, organisations fail to see a number of things that can compromise network security and open data up to risks. Controls are designed to guard information within an organisation against unauthorised access, modification, or disclosure. Technical security controls include both software and hardware solutions.

There is no mystery about the basic steps for technical security controls including everything from 2-factor authentication to firewalls, antivirus software, spam filters, keeping your software updated, changing your password regularly and other hardware-based solutions. In the event of a hacking attack, technical controls are considered the first line of defence. These technical controls should be defined as a strategy in internal policies like the organisation's Data Protection Policy and Information Security Policy.

The screenshot above is an example of no security/encryption in a process related to consumer respondent profiling in the DPOinBOX platform.

Administrative controls

Administrative controls define the human factors of security. It involves all levels of personnel within an organisation and determines which users have direct access to what resources and information by such means. There are other critical controls that need to be implemented to ensure that your organisation is secure. For instance, administrative controls are typically used to reduce the risk of unauthorised access, modification, and destruction of personal data.

These administrative controls are used to mitigate the risk of unauthorised access to personal data. These controls are typically reflected in policies such as Data protection policies/Standard Operating Procedures (SOPs). An example of administrative control is scheduled PDPA-related training as part of the organisation's yearly training calendar.

The screenshot above is an example of no contract for a process related to customer service. (Outsourcing issue) in the DPOinBOX platform.

Physical controls - Operational and architectural

A company's information security policies and procedures can help prevent unauthorised access to data, minimise damage caused when that data is accessed, and demonstrate its commitment to privacy and data security In today's business environment, personal data needs to be protected through multiple levels of security. Security controls must be implemented from the physical architecture to the application layer, and from the perimeter to the inside of a company's network. Hence, operational security controls are an essential part of any organisation's security architecture.

These are the things that employees are doing every day in the organisation's day-to-day operations, or every time they do something that accesses a system, location or storage. The controls are there to ensure that your systems, networks and databases are secure in their operations. Examples of operational and architectural controls - Storing confidential documents in locked file cabinet systems.

The screenshot above is an example of deploying an operational/architectural control in access control in the DPOinBOX platform. One example of the process is consumer refund management.

In summary, each of these data protection control types serves different purposes to achieve privacy goals. Administrative controls involve policies and procedures that govern the management of data security practices, ensuring compliance with regulations like GDPR and PDPA. Technical controls encompass technologies and tools such as encryption, firewalls, and access management systems that protect data at the infrastructure level. Lastly, physical controls refer to tangible measures, such as locked data centres and surveillance systems, that protect the organisation's physical assets. Together, these controls form a comprehensive security framework, enabling organisations to mitigate risks and protect business continuity.

Best Practices And Measures For Data Protection Security Controls

The best practices for data protection controls originate from a combination of regulatory requirements, industry standards, and risk management frameworks. Key regulatory frameworks mandate organisations to implement robust data protection measures to safeguard sensitive customer information. These regulations provide a foundation for best practices, ensuring that businesses comply with legal requirements while protecting customer data from breaches.

One of the best practices for a comprehensive data security strategy is to categorise data protection measures effectively. This approach allows organisations to take a proactive stance toward data risks and threats by building multiple layers of defence. These layers not only work to prevent breaches but also ensure quick detection and response, creating a more resilient security framework

There are three categories of controls: 

1. Preventative, 
2. Detective 
3. Corrective

Preventative controls

Preventative controls are safeguards put in place to stop or eliminate a known threat before it can be exploited. They are the security controls that a business puts in place to ensure that the information it holds is protected from unauthorised access, destruction or disclosure, which requires security controls along with other measures to manage the processing of personal data.

Preventative controls help to ensure that the business is compliant with the strict security requirements of the data protection laws. Here's an example of a preventive control - multiple authorisation levels to ensure that information cannot be tempered/modified without proper approval. I.e., maker-checker / access control into premise/system/to prevent unauthorised access.

Detective controls

The ability to detect unusual activity and data loss incidents has become critical to organisations. Detecting attacks and suspicious behaviour is difficult, but not impossible. Many organisations use an organised approach, combining tools and techniques to detect incidents. Let us take a look at an example of a detective control - a smoke/fire detector system in a building/alarm trigger mechanism when the door to the storage area is not shut properly.

Corrective controls

In the data protection context, one of the most common and critical controls is the data protection impact assessment (DPIA). The process of assessing the impact of new or revised policies, procedures, or practices on the organisation's data and IT systems is a fundamental part of the process of achieving data protection compliance.

The DPIA is a tool that helps organisations identify, prioritise, and mitigate the risks of the organisation's data and IT systems. The DPIA helps organisations to understand the threat to their data and IT system, and understand the impact that the new or revised policies, procedures, or practices will have.

To put it shortly, preventative controls are designed to avert potential security incidents before they occur. Detective controls, on the other hand, play a critical role in identifying and alerting organizations to suspicious activities or breaches as they happen. Lastly, corrective controls are necessary for addressing security incidents post-occurrence. This structured approach enhances overall data security, safeguards sensitive information, and ensures compliance with regulatory requirements, ultimately fostering trust and confidence among stakeholders.

Conclusion

Data protection initiatives within an organisation are incomplete without the proper controls. A gap assessment, as outlined in related articles, focuses on key risk areas and evaluates the effectiveness of current controls. This helps ensure that appropriate measures are designed and implemented during the Protect phase.  In today’s era of rapid digitalisation, the global challenge is that many organizations may overlook digital risks. Balancing the management of these controls with company operations and the bottom line presents an ongoing challenge for businesses. 

As illustrated above, the DPOinBOX software has capabilities to aid organisations in identifying and implementing controls to manage their data protection management programme effectively and easily.

Article By: Benjamin Shepherdson, GDPR & InfoSec (Exin), GRCP, CIPM

The views and opinions expressed in this article are those of the author and do not necessarily reflect the official view or position of DPEX Network.