External GDPR Risk Assessment

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Written By Threat NG Staff

An External GDPR Risk Assessment is a specialized type of cybersecurity risk assessment that focuses on identifying and evaluating potential threats to an organization's personal data from an outside-in, unauthenticated perspective. In contrast to an internal audit, which examines an organization's systems from within its network, this assessment looks at the digital footprint that is visible to the public and potential attackers. Its purpose is to uncover vulnerabilities that could be exploited to compromise personal data, leading to a violation of the General Data Protection Regulation (GDPR).

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

1. External Attack Surface Discovery

The first step is to map the organization's entire external digital presence. This goes beyond the main website to include all internet-facing assets that an attacker could find. This includes:

  • Subdomains: Finding all subdomains, including those that are old, forgotten, or not correctly configured.

  • IP addresses and open ports: Identifying all IP addresses and the services running on them, particularly any non-standard or vulnerable ports.

  • Cloud and SaaS assets: Discovering misconfigured cloud storage buckets, publicly exposed APIs, and other cloud resources that may contain personal data.

  • Public code repositories: Scanning public platforms like GitHub for exposed credentials, API keys, or other sensitive information accidentally left in code.

2. Vulnerability and Risk Analysis

Once the external attack surface is mapped, the assessment proceeds to identifying and analyzing potential vulnerabilities relevant to the GDPR. This analysis is driven by the specific principles of the regulation, such as data integrity and confidentiality. Examples of what this analysis looks for include:

  • Data leaks: Searching for instances where personal data, such as customer information or employee details, has been leaked to the public internet, including on the dark web.

  • Weaknesses in web applications: Testing for common vulnerabilities like cross-site scripting (XSS) or SQL injection, which could be used to exfiltrate personal data from a website.

  • Misconfigured security controls: Evaluating the effectiveness of security measures like firewalls, SSL/TLS certificates, and DNS settings to ensure they are configured to prevent unauthorized access.

  • Phishing and brand impersonation risks: Identifying domain name variations and misspellings that attackers could use to create fake websites for credential harvesting or other data theft.

3. Impact Assessment

After vulnerabilities are identified, the assessment evaluates the potential impact of an exploitation on the rights and freedoms of data subjects. This analysis is crucial because the GDPR is risk-based, meaning the severity of a violation is determined by the harm it could cause. This step considers:

  • Type of data exposed: Is it standard personal data (like an email address) or is it special category data (like health records or political opinions), which carries a higher risk?

  • Number of individuals affected: A vulnerability affecting a small number of records is less severe than one that could compromise millions of user accounts.

  • Potential for harm: What could an attacker do with the data? Could they commit identity theft, financial fraud, or cause reputational damage to the individuals involved?

4. Remediation and Reporting

The final phase involves providing a clear, actionable report. This report should not only list the vulnerabilities but also provide a risk score and a prioritized remediation plan. The report should be tailored to different audiences:

  • Executive summary: A high-level overview of the top risks and their potential impact on the business, including financial and reputational consequences.

  • Technical details: A detailed breakdown of each vulnerability, including the steps to reproduce it and specific recommendations for how to fix it.

An External GDPR Risk Assessment is a proactive measure that goes beyond a standard compliance checklist. Simulating the perspective of an attacker helps organizations find and fix the very weaknesses that could lead to a serious GDPR violation, thereby protecting data subjects and ensuring the organization's accountability and compliance.

ThreatNG helps with an External GDPR Risk Assessment by providing an unauthenticated, outside-in view of an organization's digital footprint to identify and assess GDPR-related security vulnerabilities and exposures. It's an all-in-one solution that integrates discovery, assessment, monitoring, and intelligence to give a clear picture of risks that could lead to a personal data breach or regulatory non-compliance.

How ThreatNG Helps with External GDPR Risk Assessments

1. External Discovery

ThreatNG performs purely external discovery without needing internal access or connectors. This is critical for uncovering assets that an organization may not be aware of, such as forgotten subdomains or public-facing test environments, which can be significant GDPR blind spots. For instance, it can identify developer environments that may expose personal data or system internals, a risk relevant to GDPR Articles 24, 25, and 32.

2. External Assessment

ThreatNG assesses external risks by analyzing an organization's attack surface and digital risk. The External GRC Assessment is a key capability, as it explicitly maps external findings to compliance frameworks, including the GDPR. This assessment directly identifies exposed assets and vulnerabilities from an attacker's perspective, linking them to specific GDPR articles. For example, ThreatNG can locate:

  • Subdomains missing a Content Security Policy (CSP), which is a relevant security issue under GDPR Articles 5, 24, 25, and 32 because it increases the risk of cross-site scripting (XSS) attacks that could expose personal data.

  • Misconfigured APIs on subdomains that could expose personal data, a risk that is relevant to GDPR Articles 5, 24, 25, and 32.

  • Subdomains with no automatic HTTPS redirect, which is relevant to GDPR Articles 5 and 32 as it risks the interception or modification of personal data in transit.

3. Reporting and Continuous Monitoring

ThreatNG provides various reports, including Executive, Technical, and GRC Assessment Mappings. These reports help organizations prioritize and respond to risks by giving context, risk levels, and recommendations. Furthermore, its continuous monitoring of the external attack surface and digital risks ensures that organizations can detect new vulnerabilities as they emerge, which is crucial for maintaining GDPR compliance in a rapidly evolving threat landscape.

4. Investigation Modules

ThreatNG offers several investigation modules that allow for a deeper analysis of GDPR-related risks.

  • Domain Intelligence provides a comprehensive analysis of domains, subdomains, and their associated technologies. A key example is its ability to find domain name permutations with a mail record. Suppose an attacker registers a lookalike domain with a mail record. In that case, they can use it for a phishing campaign to collect personal data, directly violating GDPR Article 5 on data integrity and confidentiality.

  • Sensitive Code Exposure discovers exposed code secrets and credentials in public repositories and mobile applications. The discovery of sensitive information in public code repositories is relevant to GDPR Articles 5, 24, 25, 32, 33, and 34, because such exposure can trigger mandatory breach notifications if it involves personal data.

  • Mobile Application Exposure evaluates an organization's mobile apps for exposed access credentials or security credentials, which are direct GDPR risks. The discovery of sensitive information in a mobile application is relevant to multiple GDPR articles, including Article 5, 6, 9, 24, 25, 32, 13, 14, 15, and 34, as it impacts data processing principles, security obligations, and breach notification requirements.

5. Intelligence Repositories

ThreatNG's intelligence repositories, branded as DarCache, provide continuous threat data.

  • DarCache Dark Web monitors for compromised credentials and ransomware events. The presence of compromised emails on the dark web indicates a lapse in confidentiality and security of processing, a relevant issue under GDPR Articles 5 and 32.

  • DarCache Vulnerability provides data on vulnerabilities from sources like NVD, EPSS, and KEV, which is crucial for identifying critical and high-severity vulnerabilities that pose an immediate threat. The external discovery of high or critical vulnerabilities on a subdomain is relevant to GDPR Articles 5, 24, 25, and 32, because they can be exploited to gain unauthorized access to personal data.

Complementary Solutions

ThreatNG's external perspective can be enhanced by using it with other security solutions. For example, ThreatNG could discover an open non-standard port on a subdomain, which is a significant security concern that increases the attack surface. This finding, which is relevant to GDPR Articles 5, 32, and 33, can then be correlated with an internal vulnerability management platform to see if a known, unpatched service is using that specific port. This would help an organization prioritize patching the vulnerability, as it is both externally exposed and internally recognized as a risk. Another example is using ThreatNG to identify exposed APIs on a subdomain. This information can be sent to an API security gateway to enforce stricter access controls and monitoring for suspicious activity, ensuring the API is not being used to access personal data improperly.

Threat NG Staff
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