External GDPR Assessment

In the context of cybersecurity, an "External GDPR Assessment" is a systematic process for identifying and evaluating risks to an organization's personal data from an outside-in perspective. It's a key component of a proactive GDPR compliance strategy because it focuses on vulnerabilities that are visible to an attacker from the public internet, rather than solely relying on internal-facing audits.

The primary goal of an external assessment is to determine if an organization's publicly exposed assets have any security weaknesses that could be exploited to compromise personal data. It directly addresses the GDPR's requirements for Integrity and Confidentiality (Article 5) and for implementing appropriate technical and organizational measures to ensure data security (Article 32).

Here are the key components of a detailed External GDPR Assessment:

1. External Asset Discovery

The assessment begins with a comprehensive mapping of the organization's entire digital footprint that is visible from the outside. This includes:

• Subdomains: Identifying all subdomains, including forgotten or unmanaged ones (e.g., old test servers or development environments).

• IP Addresses and Open Ports: Scanning for all public-facing IP addresses and services, including non-standard ports that might have been left open by mistake.

• Public Code Repositories: Searching public platforms like GitHub for exposed credentials, API keys, or other sensitive information in source code.

• Cloud and SaaS Services: Discovering misconfigured cloud storage buckets (e.g., publicly accessible Amazon S3 buckets) or other cloud assets that could expose personal data.

2. Vulnerability and Digital Risk Analysis

Once the external assets are identified, they are analyzed for vulnerabilities that are relevant to GDPR. This step involves simulating a hacker's mindset to determine how they would exploit the discovered weaknesses. This includes:

• Data Leakage: Actively looking for instances where personal data—such as customer lists, employee data, or sensitive financial information—has been unintentionally exposed on the public internet.

• Misconfigurations: Identifying common security misconfigurations, such as a lack of HTTPS redirection, outdated SSL certificates, or missing security headers on a website.

• Third-Party Risk: Assessing the security posture of third-party vendors and partners by examining their public-facing assets for vulnerabilities that could affect the personal data they process on behalf of the organization.

• Phishing and Brand Impersonation: Analyzing the digital landscape for lookalike domains or DNS weaknesses that could enable an attacker to create fake websites for credential theft, which is a standard method for obtaining personal data.

3. Risk and Impact Evaluation

The GDPR is a risk-based framework, so the assessment must go beyond simply listing vulnerabilities. It needs to evaluate the potential impact of each finding on the rights and freedoms of data subjects. This involves:

• Data Sensitivity: Categorizing the type of personal data at risk (e.g., standard data vs. sensitive special category data).

• Likelihood of Harm: Assessing how likely it is that the vulnerability will be exploited and what the potential consequences would be for the individuals affected.

• Severity of Consequences: Evaluating the potential harm, such as financial loss, identity theft, or reputational damage to the individuals.

4. Actionable Reporting

The final output is a report that provides a clear and prioritized list of findings. This report should be actionable, with a focus on remediation. It should include:

• Risk Score: A clear rating (e.g., critical, high, medium) to help an organization prioritize the most dangerous vulnerabilities.

• Technical Details: Specific information on each finding, including how it was discovered and how to fix it.

• Compliance Mapping: A direct link between each external vulnerability and the specific GDPR articles it violates, demonstrating the business and legal consequences of non-compliance.

An External GDPR Assessment is a crucial component of modern cybersecurity. It provides an essential perspective that internal audits cannot, helping organizations proactively find and fix the very weaknesses that could lead to a data breach and the severe penalties that come with it.

ThreatNG is a solution that can help with an External GDPR Assessment by providing an outside-in, unauthenticated evaluation of an organization's digital presence to find and manage risks that could result in GDPR non-compliance. The solution is designed to align a company's security posture with external threats, identifying vulnerabilities and exposures in the same way an attacker would.

How ThreatNG Helps with an External GDPR Assessment

External Discovery and Assessment

ThreatNG performs purely external unauthenticated discovery, meaning it doesn't need internal connectors to find an organization's internet-facing assets. The platform's External GRC Assessment capability is a key component, as it directly maps identified risks to frameworks such as the GDPR. This assessment helps uncover and proactively address external security gaps.

For example, ThreatNG can discover:

• Subdomains missing security headers, which is relevant to GDPR because it could expose personal data to interception or tampering. The absence of an automatic HTTPS redirect is also a relevant finding, as it exposes data in transit to potential interception, which undermines GDPR's security and confidentiality requirements.

• APIs on subdomains that process or return personal data. If these APIs are not adequately secured, it could violate GDPR Articles 5, 24, 25, and 32.

• Old developer resources or demo pages that are publicly accessible. These could contain sensitive information, test credentials, or misconfigurations, posing a risk to data security under GDPR.

Continuous Monitoring and Reporting

An external GDPR assessment shouldn't be a one-time activity. ThreatNG provides continuous monitoring of an organization’s external attack surface and digital risks. This helps to ensure that new vulnerabilities and data exposures are detected as they emerge. For reporting, ThreatNG provides several formats, including Executive, Technical, and External GRC Assessment Mappings. These reports provide risk levels to help prioritize security efforts and offer recommendations for risk mitigation.

Investigation Modules

ThreatNG includes several investigation modules for a deeper analysis of external risks that could lead to GDPR non-compliance:

• Sensitive Code Exposure: This module scans public code repositories and mobile apps for leaked credentials and secrets. For instance, ThreatNG can find an exposed AWS Access Key ID or a private SSH key in a public repository, which is a significant GDPR risk. This type of finding is highly relevant to GDPR Articles 5, 24, 25, and 32 because it can lead to unauthorized access and breaches.

• Domain Intelligence: This module analyzes an organization's domain-related assets. A key example for GDPR is the detection of domain name permutations with a mail record. An attacker could use a lookalike domain with a mail record to launch a phishing campaign to collect personal data, directly violating GDPR's data integrity and confidentiality principles.

• Cloud and SaaS Exposure: This module identifies both sanctioned and unsanctioned cloud services, as well as open cloud buckets. The discovery of files in open cloud buckets is a relevant finding for GDPR, as it can expose personal data and violate principles of confidentiality and security of processing.

Intelligence Repositories

ThreatNG's continuously updated intelligence repositories (DarCache) are another valuable asset for an external GDPR assessment.

• The Dark Web repository monitors for compromised credentials and ransomware events. The presence of compromised emails on the dark web is relevant to GDPR because it indicates a potential breach of confidentiality and may require breach notification.

• The Vulnerability repository provides information on vulnerabilities from sources like NVD, EPSS, and KEV. Finding critical or high-severity vulnerabilities on an external-facing subdomain is highly relevant to GDPR because such vulnerabilities can be exploited to gain unauthorized access and exfiltrate data, triggering GDPR Articles 33 and 34.

Synergies with Complementary Solutions

ThreatNG's external assessments can be more powerful when used in conjunction with complementary solutions. For example, ThreatNG can discover an exposed API on a subdomain. That information, which is relevant to GDPR, can be used with a web application firewall (WAF) to apply stricter access controls and monitoring to that specific API, helping to mitigate the risk of a breach.

Similarly, ThreatNG's discovery of a subdomain takeover vulnerability can be used with a security information and event management (SIEM) solution. The SIEM can monitor logs for any unauthorized login attempts or unusual activity on that subdomain, providing a comprehensive, end-to-end view of the threat. This synergy helps an organization not only identify the external risk but also correlate it with internal activity to ensure full compliance.