Analytics, Security

Why the California Privacy Rights Act (CPRA) Presents Challenges for Legacy ERP Customers

By Michael Cunningham • November 20, 2020

While nearly everyone was focusing on the results of the 2020 Presidential race, California voters passed Proposition 24, the California Privacy Rights Act (CPRA) (full text here). You might be wondering if this is a new privacy law that will replace the 2018 California Consumer Privacy Act (CCPA), which went into effect earlier this year. The CPRA provides additional context to the CCPA and attempts to close some of the loopholes and ambiguity found in the original. The CPRA gives additional rights to consumers and places additional obligations on businesses. 

While some of the CPRA changes will take effect immediately, most will not become enforceable until July 1, 2023, and apply only to personal information collected after January 1, 2022. Like the run-up to the launch of CCPA, companies will have time to prepare for the new requirements. 

A Quick Summary of the California Privacy Rights Act 

In scope, the CPRA retains the same basic structure as the CCPA. It includes establishing a dedicated enforcement agency for consumers, tripling fines against companies that violate kids’ data privacy, and making it harder to weaken privacy laws in the future. 

A couple of the more notable additions in the CPRA are that the law expands the right to opt-out of sharing of information and establishes new rights to limit how businesses use “sensitive personal information,” a new term defined broadly to include, among other things: information about health conditions, genetic data, race and ethnicity, sexual orientation, precise geolocation, and more.

ERP applications already store an abundance of personally identifiable information, such as Social Security numbers, driver’s licenses, or passport numbers. This new data classification adds to the effort of identifying and classifying information necessary to remain in compliance.

The CPRA Signals Organizations Must Get Serious About Enhancing Data Access and Usage Visibility – Especially for Legacy ERP Applications  

The CCPA and CPRA require organizations to implement appropriate security measures around personal data privacy and satisfy consumer requests to opt-out of “sharing” and “selling” of their information. That means businesses must know what personal data they collect and how that data is accessed and used. However, companies using PeopleSoft, SAP ECC, S/4HANA, and Oracle E-Business Suite are likely facing significant compliance challenges due to inherent limitations that plague legacy ERP systems. Traditional ERP application logs do not produce the required level of granularity into how data is accessed.  

How Appsian360 Enables CCPA/CPRA Compliance 

Successful organizations will invest in technologies that monitor user behavior around data access and usage. This is where Appsian360 becomes an essential tool for compliance, as it expands native ERP logging capabilities to capture contextual details like what data was accessed, where it was accessed from, user IDs, IP addresses, pages accessed, actions performed, and more – information that is paramount for compliance reporting. 

More Data Privacy Acts Likely on the Horizon 

With the CPRA, Californians will likely have the most robust online privacy rights in the world. And it probably won’t be the last. The original passage of the CCPA incentivized other states to draft their own privacy bills. There’s been activity at the federal level as well. So, while the pandemic rightfully slowed down state and federal activity, there’s a good chance we’ll see additional privacy bills in 2021.

There’s no better time than the present to press forward with your compliance efforts, whether it’s for CCPA, GDPA, and now CRPA. Contact us to learn how Appsian can fast track your CCPA and CRPA compliance efforts by enhancing your visibility into data access and usage. 

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Security

Appsian Releases Report Revealing Executive Perspective on SAP Business Risks and Controls

By Michael Cunningham • June 25, 2020

Every organization using SAP ERP applications faces the unique challenge of maintaining a strong security posture while enabling productive business processes. Throw in the uncertainty of today’s rapidly changing environment, and you can bet that IT professionals and business stakeholders are facing misalignment between IT controls and business rules and objectives. 

To discover how organizations are evolving their security and risk management practices, Appsian commissioned a survey of nearly 200 senior stakeholders using SAP applications through an independent market research firm. We compiled the results of our survey into the SAP Security Report: Executive Perspective on SAP Business Risk Management

We found that this rapid state of change in today’s environment has brought about a new normal for acceptable risk in SAP – but not by choice. While some organizations are adopting new processes and technology to address risk, legacy strategies are holding back many in their path towards efficiently managing ERP data risks. 

We also uncovered four key takeaways from the respondents: 

1. Business Process Risks Are Slipping Through the Cracks 

Executive confidence is wavering in an organization’s ability to detect business risks from fraud, theft, and human error. While concern is generally high, a lack of consistent visibility into these business processes highlights a gap that many have yet to address. 

2. IT Leaders Are Concerned About Excessive User Privileges 

Excessive user privileges continue to be a top concern of leadership – and for good reason. Users have the keys to your kingdom, and with this, pose a heightened risk if their accounts are compromised or if they engage in malicious activity. 

3. Misalignment is Hurting Confidence in SAP Security 

Tight alignment between SAP security controls and business goals and objectives is paramount to secure, compliant, and efficient business processes. However, many respondents signal that the two are not aligned effectively. 

4. Limited Visibility & Complex Controls Are Hindering Progres

Organizations are facing the limitations of their existing technology and processes. Solving this will require a new approach to overcome complexities in controls and limited visibility into their business-critical applications. 

Want to gain a better understanding of how organizations are evolving their ERP security and risk management practices? Curious about the kinds of risks organizations are most concerned about, and how they view and prioritize user and system visibility, access control, oversight, and accountability? 

Download your free copy of the SAP Security Report today and take a deeper dive into these findings.  

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Security

CCPA Enforcement Is on Track to Start July 1, 2020. Are Your Data Privacy Strategies Ready?

By Michael Cunningham • June 24, 2020

Time is almost up for companies scrambling to get their data privacy strategies in compliance with the California Consumer Protection Act (CCPA). Beginning as early as July 1, 2020, the California Attorney General’s office can start enforcing the CCPA and handing out penalties of up to $2,500 per violation or up to $7,500 per intentional violation.  

So, when exactly, will the CCPA become law? On June 1, 2020, the California AG took the final step before the regulations become enforceable by submitting the final text of the CCPA Regulations to the California Office of Administrative Law (the “OAL”). The OAL has 30 working days–plus an additional 60 calendar days related to the COVID-19 pandemic–to review the submission and approve it to become an enforceable law. Doing the math, the California AG can begin enforcing violations as early as July 1 or as late as September 1, 2020

Strategies for Improving ERP CCPA Compliance  

Companies using PeopleSoft, SAP ECC, S/4HANA and Oracle EBS are likely facing additional compliance challenges due to inherent limitations built into these legacy ERP systems. Let’s look at a couple of tactics for enhancing your ERP systems to improve compliance with CCPA and establishing the capabilities to prepare for the uncertainty around data privacy. 

1: Enhance Visibility into User Activity 

The CCPA requires organizations to implement appropriate security measures around personal data and satisfy data subject access requests (DSARs). That means businesses must know what personal data they store and the user activity going on around it. However, traditional ERP systems do not provide the required level of granularity. 

To achieve detailed visibility around data usage, organizations need to expand their native logging capabilities by adopting a strategy that focuses on data access and usage. Meaning, organizations must capture contextual details like date of access, UserID, IP address, device, location of access, actions performed, etc. 

This is information that is critical for compliance reporting and understanding how data is being used within your organization. 

2: High Privilege Access Should be the Highest Priority for Strengthening DLP 

When it comes to ERP systems, the static rules that govern access can be limiting because roles and privileges are user-centric, not data-centric. User-centric roles say a person (or group in most cases) can view something under any circumstances, while data-centric means the nature of the data defines the access. This gets organizations in trouble time and time again from a DLP perspective because high privilege users always have the ability to see more data than they actually need (to do their job.) This makes non-compliance with CCPA almost inevitable. Overexposure of data is your biggest enemy and governing access by static rules (aka ‘all or nothing access rules’) creates an enormous liability.

Implementing data-centric policies (typically through attribute-based access controls) ensures that a user can only access data deemed necessary and job-related. This is because the data itself is governing access – not a user role. For example, access to certain high-risk transactions can be restricted based on a user’s location – or access can be granted, but with masked data fields. With every variation of context, attribute-based access controls can pivot and adjust accordingly. By reducing the threat surface, companies can reduce the risk of data leakage and mitigate compromised access damages.  

3: Use Real-Time Analytics and Data Visualization (SEIM) to Expedite Incident Response Time 

 Integrated and real-time analytics displayed on dashboards were always a “nice-to-have” feature for security teams; however, keeping CCPA deadlines of breach identification and reporting in mind, data visualization has become a must-have feature. These advanced dashboards equip security professionals with real-time snapshots of data usage. The drill-down capabilities allow for enhanced data discovery and exploration to expedite breach detection and response, helping organizations stay compliant with CCPA and other existing and upcoming regulations.   

Ready or Not, CCPA Enforcement Has Arrived  

If you’ve not wrapping up your CCPA compliance efforts by now, there’s no better time than the present to start (or continue down that road). Appsian can help you fast track your compliance efforts by enhancing your visibly and applying a data-centric ERP compliance framework. 

The last thing any company wants is to discover that they’re out of CCPA compliance only when there’s a breach of the regulation. 

Contact us to learn how Appsian can help you address your end-to-end security and compliance needs.

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Security

Managing Compliance Costs with Enhanced Cybersecurity Visibility

By Greg Wendt • May 14, 2020

Data privacy regulations are rapidly reshaping the way companies monitor, manage, and even define the data they collect and store. Prior to new privacy regulations put in place by the European Union and the state of California, the data lifecycle focused solely on collection and dissemination. This meant that the enterprise would collect as much information as possible then store it in a way that maximized accessibility, particularly with the rise of mobile. Cybersecurity, when it was discussed, focused on establishing defensive perimeters to mitigate external threats.

However, since GDPR was implemented in 2018 and reinforced by CCPA in 2019, companies have been required to reconsider how that information lives in their organization and identify who has access to it in order to meet basic compliance standards. Security teams that can adapt to the new requirements are critical to tackling the ballooning costs in compliance, particularly as other states and countries look to pass their own privacy regulations. 

The CCPA and GDPR have elevated customer data security to become a key priority across multiple departments. Since both laws are in the early stages of implementation and interpretation by enforcement agencies, legal departments have become an essential ally in compliance. In the case of the GDPR, the right to be forgotten has been contested by search giant Google in several high-profile court cases, adding greater nuance and detail to how the law impacts data management. Human resources is also a valuable partner in compliance management as they are best positioned to engage employees on new security protocols and assist in the successful deployment of new technology to ensure that workflow is not disrupted. 

Legacy infrastructure increases compliance costs 

The CCPA alone is expected to cost enterprises $55 billion in initial compliance costs, with additional costs to be expected in maintenance fees, with IBM’s 2019 Cost of a Data Breach Report states that the average total cost of a data breach increased to an average of $3.92 million in 2019, though in the United States the average cost per breach rose to $8.9 million. Much of that cost is driven by the recovery process, which involves understanding how the system was breached, what information was affected and bringing systems back online. For many organizations, understanding the scope of damage is difficult because current security systems aren’t designed for data visibility or access management, both of which enable security teams to track who has accessed what data and when. 

Data visibility is a particularly acute challenge in ERP systems because they contain highly sensitive business data, such as financial information, intellectual property or insurance details. Since ERP systems hold so much valuable data, they’re often the last piece of the digital infrastructure to be updated. This results in security gaps when patches are missed, or new security features are added to a legacy system. The “black box” of ERP systems can cause delays in damage assessments, resulting in the risk of hefty fines as the GDPR requires affected customers to be notified within 30 days of when information is compromised. 

Organizations lack tools to comply with “right to know” 

Compliance costs have largely been driven by the wave of “right to know” and “right to be forgotten” requests from their users. The right to know establishes the right of the consumer to know exactly what data a company has collected on them, and to download that data. For the enterprise, this requires being able to identify, organize and share all information pertaining to every single user, breaking the black box paradigm that existed before GDPR. Recent research shows that each request is estimated to cost approximately $1,400, quickly adding to compliance costs. 

The right to be forgotten allows consumers to request that any data related to them be deleted from an organizations’ database. Though the rule is less broadly applicable than the right to know, organizations should be careful of potential violations in their third-party partners or even of careless practices by employees. 

For GDPR and CCPA compliance, outdated and disparate infrastructure also adds major challenges, especially when adhering to the response time limits set out by GDPR. The law requires that organizations respond to right to know requests within 30 days. Yet a global survey of 103 companies worldwide across various industries found that 58% of respondents were unable to meet data access and portability requests within the one-month time limit. One of the main barriers to timely right to know requests was the lack of consolidated, transparent data structures that made finding all relevant information on each individual a costly and long process. 

When organizations don’t understand where collected data is or who can access it, compiling a right to know report is next to impossible. Without any means of tracking access within their internal databases, most enterprises have no idea if the personal information of any user has been accessed, copied or stored in multiple places, forcing compliance teams to track down each piece individually and risking fines when request response takes longer than 30 days. Not only does this heighten the likelihood of compliance violations, but also contributes to the rise of insider security threats, particularly in highly sensitive fields like healthcare and finance. 

As a result, security and compliance teams have begun joining forces to better understand the lifecycle of business data in the enterprise and how it can be effectively secured. 

Regulations align with industry trends 

In many ways, the new regulatory pressures brought by the CCPA and GDPR align with emerging trends in cybersecurity. Insider threats are one of the fastest growing trends in data breaches, accounting for 34% of attacks in 2019. Security features that enable granular tracking of user behavior in real-time addresses ensures access management can be done accurately while also adhering to privacy standards set forth by the GDPR and CCPA. As a result, organizations improve both security and compliance because they can be better prepared to respond to insider threats, minimize direct damage caused by a breach as well as void penalties incurred by compromising customer data. With greater means to identify and differentiate users, security teams are also able to increase access controls as well as better understand who has modified data and when. 

The GDPR and CCPA have had a significant impact on the public expectation for privacy and security. While security measures like multi-factor authentication (MFA) and complex passwords have existed for years, consumers and developers frequently opposed requiring them due to concerns over adding too much friction to the user experience. With cybersecurity concerns entering the mainstream, many consumers are actively seeking out additional ways to protect and manage their personal data. For the enterprise, this has increased employee’s receptiveness to new security features such as MFA to internal systems. Particularly with complex ERP systems, system administrators can unify the heightened expectations for security created by the GDPR and CCPA to reduce the costs of compliance. 

Advanced security tools can address challenges experienced across all departments by supporting secure migrations, enabling better data visibility in new systems, and reducing the long-term costs of compliance. As the security discussion evolves to when not if a hack takes place it is essential to have a holistic program in place to understand what actions will be taken when data is compromised. By hiding their head in the sand, the unprepared enterprise not only risks more damaging attacks but also larger fines. The right security tools can lay the foundation for a program that effectively fulfills the multidisciplinary role of security and engages all necessary experts to protect data and minimize compliance costs. 

This article was originally published by CPO Magazine. 

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