Industry:DPC BS 10012

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Submission Response
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Final version
[This response is submitted on behalf of the Open Web Application Security Project (OWASP)]

4.3 Training and awareness

Comment: Information security organizations have a wide body of knowledge that can help in the protection of personal information and have well-established channels for the dissemination of new threats.

Proposed change: Add reference to "information security organizations" in the sentence "The organization shall also ensure that this member of staff works with relevant external trade organizations and data protection organizations in order to remain informed about issues related to the management of personal information." so that it reads "The organization shall also ensure that this member of staff works with relevant external trade organizations, INFORMATION SECURITY ORGANIZATIONS and data protection organizations in order to remain informed about issues related to the management of personal information.".

4.4 Risk assessment

Comment: The risk assessment should not be limited to the planned/existing processing. Threat risk modelling looks at mis-use too and should be used to identify threats and vulnerabilities in the systems used to collect, store, use, transmit personal information. See http://www.owasp.org/index.php/Threat_Risk_Modeling for a further explanation in the context of a web application.

Proposed change: In the first paragraph, add a new sentence "The organization shall use threat risk modelling to expose additional threats and vulnerabilities.".

4.7.2 On-line privacy statements

Comment: Privacy statements on the Internet should not be limited solely to websites.

Proposed change: Change the text "where personal information is collected over the Internet via a website, an on-line privacy statement is included on the website." to "where personal information is collected over the Internet (E.G. WEBSITE, INSTANT MESSAGING, WIDGET, MOBILE APPLICATION, EMAIL, ETC) OR OTHER DIGITAL CHANNEL, an on-line privacy statement is included."

4.7.3 Record of FPNs and statements

Comment: The retention of fair processing notices (FPNs) and online privacy notices for as long as personal information to which they relate is retained will require knowing exactly where the data are at all times, so that it can be destroyed securely when it is no longer required.

Proposed change: Add a sentence at the end of this paragraph "The PIMS must address how personal information will be monitored throughout its lifecycle, from collection to secure destruction, including all processes, systems, applications, media (electronic or otherwise) and other organisations where the information may reside, pass through or be processed by."

4.10 Accuracy

Comment: The procedures suggested are somewhat reactive. Organisations can also review their own data to identify inaccuracies and make corrections e.g. de-duplication, removal of redundant data, address validation, re-checking with the subject, etc.

Proposed change: In the fifth paragraph ("The PIMS shall incorporate procedures for:...") add another item "c) periodic checking of data integrity and correction of identifiable inaccuracies".

4.11 Retention and disposal

Comment: If personal information is transmitted between systems or stored in multiple locations, all instances of the data must be removed securely at the disposal point. For example, data may initially have been collected via a web application and could exist on web servers, on database servers, on proxies, and in paper reports and file exports generated from the web application as well as any internal or third-party systems where the data is transferred to.

Proposed change: In the fourth paragraph("The PIMS shall incorporate or reference disposal procedures which are managed:...") add another item "4. cover all systems, applications, media and other locations where the personal information may have existed".

4.13.1 Security controls

Comment: Compliance with BS ISO 27001 is one consideration. But many business processes rely on software, and much of this software is not secure enough to protect personal information.

Proposed change: Add another note "Organizations developing or using software (e.g. websites, CRM systems, web applications, widgets) to process personal information may wish to consider using a maturity model to assess their software development processes against industry "best practice", and create a plan to improve. A well-developed example is the SAMM (Software Assurance Maturity Model)- see http://www.opensamm.org/ Organisations might also consider choosing software development frameworks and methods that have been heavily analysed and carefully designed to improve security such as the OWASP Enterprise Security API – http://www.owasp.org/index.php/ESAPI available for a range of common web programming languages.".

4.13.2 Storage and handling

Comment: Online storage and handling are also particularly at risk from external threats.

Proposed change: Add another note "Any online systems that store or handle personal information must also be examined carefully. The Open Web Application Security Project (OWASP) provides open access to many guides and tools to help with the development, testing, deployment and verification of application security - http://www.owasp.org/".

4.13.5 Security assessments

Comment: Web applications are often built insecurely; many of today's business processes are being enabled over the web and this is exposing personal information to additional threats. There are many problems common to other software systems, but web applications also have particular issues. There is currently only one standard available to specifically establish a level of confidence in the security of web applications.

Proposed change: Add a note "The OWASP Application Security Verification Standard (ASVS) is an open standard that defines ranges in coverage and levels of rigor that can be used to perform application security verifications - http://www.owasp.org/index.php/ASVS".

4.13.6 Notification of security incidents

Comment: Organizations should be pro-actively looking for security incidents, not just reacting when an incident is brought to their attention.

Proposed change: Add a new item to the first paragraph ("The PIMS shall incorporate procedures:..."), "e) to identify actual, unusual and potentially malicious behaviour".

Bibliography

Comment: OWASP builds documents, tools, teaching environments, guidelines, checklists, and other materials to help organisations improve their capability to produce secure code. All of the OWASP tools, documents, forums, and chapters are free and open to anyone interested in improving application security. The ICO currently has a draft Privacy Notices Code of Practice consultation open until 3 April at http://www.ico.gov.uk/about_us/consultations/our_consultations.aspx

Proposed change: Add to bibliography "The Open Web Application Security Project (OWASP) at http://www.owasp.org".

Add to bibliography "Privacy Notices Code of Practice, ICO at [tbc]"

Draft Text version 2
No changes

Draft Text version 1
''The format for providing feedback requires a comment and proposed change. As feedback is provided PER SECTION, we cannot assume anyone will read the feedback to other sections first i.e. each comment/change must stand on its own merit.''

4.3 Training and awareness

Comment: Information security organizations have a wide body of knowledge that can help in the protection of personal information and have well-established channels for the dissemination of new threats.

Proposed change: Add reference to "information security organizations" in the sentence "The organization shall also ensure that this member of staff works with relevant external trade organizations and data protection organizations in order to remain informed about issues related to the management of personal information." so that it reads "The organization shall also ensure that this member of staff works with relevant external trade organizations, INFORMATION SECURITY ORGANIZATIONS and data protection organizations in order to remain informed about issues related to the management of personal information.".

4.3 Risk assessment

Comment: The risk assessment should not be limited to the planned/existing processing. Threat risk modelling looks at mis-use too and should be used to identify threats and vulnerabilities in the systems used to collect, store, use, transmit personal information. See http://www.owasp.org/index.php/Threat_Risk_Modeling for a further explanation in the context of a web application.

Proposed change: In the first paragraph, add a new sentence "The organization shall use threat risk modelling to expose additional threats and vulnerabilities.".

4.7.2 On-line privacy statements

Comment: Privacy statements on the Internet should not be limited solely to websites.

Proposed change: Change the text "where personal information is collected over the Internet via a website, an on-line privacy statement is included on the website." to "where personal information is collected over the Internet (E.G. WEBSITE, MOBILE APPLICATION, EMAIL, ETC) OR OTHER DIGITAL CHANNEL, an on-line privacy statement is included."

4.7.3 Record of FPNs and statements

Comment: The retention of fair processing notices (FPNs) and online privacy notices for as long as personal information to which they relate is retained will require knowing exactly where the data is at all times, so that it can be destroyed securely when it is no longer required.

Proposed change: Add a sentence at the end of this paragraph "The PIMS must address how personal information will be monitored throughout its lifecycle, from collection to secure destruction, including all processes, systems, applications, media (electronic or otherwise) and other organisations where the information may reside or pass through."

4.10 Accuracy

Comment: The procedures suggested are somewhat reactive. Organisations can also review their own data to identify inaccuracies and make corrections e.g. de-duplication, removal of redundant data, address validation, etc.

Proposed change: In the fifth paragraph ("The PIMS shall incorporate procedures for:...") add another item "c) periodic checking of data integrity and correction of identifiable inaccuracies".

4.11 Retention and disposal

Comment: If personal information is transmitted between systems or stored in multiple locations, all instances of the data must be removed securely at the disposal point. For example, data may initially have been collected via a web application and could exist on web servers, on database servers, on proxies, and in paper reports and file exports generated from the web application as well as any internal or third-party systems where the data is transferred to.

Proposed change: In the fourth paragraph("The PIMS shall incorporate or reference disposal procedures which are managed:...") add another item "4. cover all systems, applications, media and other locations where the personal information may have existed".

4.13.1 Security controls

Comment: Compliance with BS ISO 27001 is an important consideration. But many business processes are underpinned by software, and much of this software is not secure enough to protect personal information.

Proposed change: Add another note "Organizations developing or using software (e.g. CRM systems, web applications) to process personal information may wish to consider using a maturity model to assess their software development processes against industry "best practice", and create a plan to improve. A well-developed example is the OpenSAMM (Software Assurance Maturity Model)- see http://www.opensamm.org/ Organisations might also consider choosing development frameworks and methods that have been heavily analysed and carefully designed to improve security such as the OWASP Enterprise Security API – http://www.owasp.org/index.php/ESAPI available for a range of common web programming languages.".

4.13.2 Storage and handling

Comment: Online storage and handling are also particularly at risk from external threats.

Proposed change: Add another note "Any online systems that store or handle personal information must also be examined carefully. The Open Web Application Security Project (OWASP) provides open access to many guides and tools to help with the development, testing, deployment and verification of application security - http://www.owasp.org/".

4.13.5 Security assessments

Comment: Web applications are often built insecurely; many of today's business processes are being enabled over the web and this is exposing personal information to additional threats. There are many problems common to other software systems, but web applications also have particular issues. There is currently only one standard available to specifically establish a level of confidence in the security of web applications.

Proposed change: Add a note "The OWASP Application Security Verification Standard (ASVS) is an open standard that defines ranges in coverage and levels of rigor that can be used to perform application security verifications - http://www.owasp.org/index.php/ASVS".

4.13.6 Notification of security incidents

Comment: Organizations should be pro-actively looking for security incidents, not just reacting when an incident is brought to their attention.

Proposed change: Add a new item to the first paragraph ("The PIMS shall incorporate procedures:..."), "e) to identify actual, unusual and potentially malicious behaviour".

Bibliography

Comment: OWASP builds documents, tools, teaching environments, guidelines, checklists, and other materials to help organisations improve their capability to produce secure code. All of the OWASP tools, documents, forums, and chapters are free and open to anyone interested in improving application security.

Proposed change: Add to bibliography "The Open Web Application Security Project (OWASP) at http://www.owasp.org".

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