Building trust in the digital world: EU General Data Protection Regulation

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Bruce Schneier – Privacy protects us from abuses by those in power, even if we’re doing nothing wrong at the time of surveillance.”[1] 

To protect rights of European individuals the EU has agreed on a new EU General Data Protection Regulation. European citizens will get a whole new set of rights:

This new EU regulation will assist companies in respecting information of the people they are working with. Organizations will be accountable to incorporate these rights into their daily business practices, if they are not already.


Political agreement on the General Data Protection Ruling was reached on 15 December 2015. It will replace the existing Directive 95/46/EC. It should be formally adopted in 2016 and come into force in 2018.   The agreed text is here.


The new ruling concerns personal data of all citizens of Europe and applies to organizations established in the Europe and also to organizations outside Europe that deal with data of  European citizens.


Companies controlling and processing personal European data must not only comply but also be able to demonstrate they comply, e.g. through the use of policies and privacy impact assessments and compliance to new data security requirements including:

  • additional obligations for contracts
  • use of encryption,
  • back up and security testing

Organizations with more than 250 employees must also appoint a data protection officer.

Data  breaches must be reported to the Supervisory Authority within 72 hours as soon as a company becomes aware of a data breach. Potential impacted individuals also have to be notified.

The sanctions for breach of the General Data Protection Regulation are significant. Regulators can impose fines of up to 4% of total annual worldwide turnover or €20,000,000. This is regardless if you’re a Google or a 1-person consultancy, in both cases violating this law will hurt your business’ bottom line.

So don’t hesitate to prepare implementation, build your policy, start with assessments and protect the personal data in your company.


[1] “The Value of Privacy by Bruce Schneier”. Retrieved 2015-02-09.

[2] The Trouble with European Data Protection Law, Bert-Jaap Koops, Tilburg University, TILT

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How to create secure e-banking services in an agile world?


Banks gained the trust of their clients by the delivery of secure banking solutions. Client information and financial transactions are continuously protected against data leakage and cybercrime. But the IT world is changing……


IT departments adopted ‘Agile’ ways of working. So called ‘devOps’ teams deploy changes to banking solutions continuously. On a daily or monthly base all kind of new features and improvements are added to the banking apps and e-banking solutions.


Because Agile is faster and less expensive. Focus is on new functionality and the question “is the solution still secure?” comes later and sometimes  too late. Penetration test show vulnerabilities which because of a lack of budget and time are not resolved before the ‘Go Live’. Risks are accepted based on good intentions, which are often not fulfilled due to the focus on new innovations.

Schermafbeelding 2015-12-03 om 19.47.02How to solve?

The same as for functionality testing, security testing has to become part of the day to day work of a developer. Security Officers have to provide security test tooling (SAST, DAST) so that developers can deliver secure apps based on defensive coding.

At the same time, the backlog should get sufficient attention of Agile Risk Managers. Per feature in the backlog, stakeholders should assess the risks of a new feature. The secure devOps teams should also create (evil) user stories and other controls. In this way business can check concepts and identify risks in a timely way.

Instead of waiting for the results of the Penetration test, it is Continuous integration of risk management and security from backlog to delivery  which will deliver ‘secure user stories’ and ‘secure apps’.