GDPR Data Leaks
In the context of cybersecurity, a "GDPR data leak" is the unintentional and unauthorized exposure of personal data to a public or unauthorized environment. Unlike a data breach, which often implies a malicious, targeted attack, a data leak typically results from a security misconfiguration, a technical oversight, or human error. Despite its non-malicious nature, a GDPR data leak is considered a security incident that can lead to a data breach and has the same severe consequences under the General Data Protection Regulation (GDPR).
Here is a detailed breakdown of GDPR data leaks in a cybersecurity context:
Key Characteristics
Unintentional Exposure: The defining feature of a data leak is that it is not the result of a deliberate hack or intrusion. For example, a developer might mistakenly set a cloud storage bucket to "public" instead of "private," making its contents accessible to anyone with the correct URL.
Lack of Access Controls: Data leaks are most often caused by a failure in implementing proper access controls. This could involve an unpatched server, a misconfigured firewall rule, or a publicly accessible file server that lacks password protection.
Broad Digital Footprint: In today's interconnected world, data can leak from various sources, including:
Cloud Services: Misconfigured cloud storage like Amazon S3 buckets or Azure Blob Storage.
Public Code Repositories: Sensitive information such as credentials, API keys, and cryptographic keys accidentally committed to public repositories like GitHub.
Open Databases: Databases left open and unsecured on the public internet.
Email and Messaging: Confidential data accidentally sent to the wrong person or to a public mailing list.
Why Data Leaks Are a GDPR Violation
GDPR Article 5, the core set of principles, requires that personal data be processed in a manner that ensures its "integrity and confidentiality." It also mandates that controllers use "appropriate technical and organizational measures" to protect personal data from unauthorized access or processing. A data leak, regardless of its cause, is a direct failure to meet these requirements.
Furthermore, a data leak can be a precursor to a more severe data breach. Once the data is exposed, it can be found and exfiltrated by cybercriminals, leading to identity theft, financial fraud, and reputational damage to the individuals involved. This triggers GDPR's breach notification requirements (Articles 33 and 34), which mandate that controllers report a breach to the relevant data protection authority and, in some cases, to the affected data subjects.
Consequences
The consequences of a GDPR data leak are the same as a data breach and can be severe:
Regulatory Fines: Data leaks can result in the same high-tier GDPR fines of up to €20 million or 4% of a company's global annual turnover, whichever is higher, depending on the severity and nature of the leak.
Reputational Damage: The public and customers lose trust in an organization's ability to protect their data.
Legal Action: Individuals affected by the data leak may sue the organization for damages.
Operational Disruption: The organization must spend significant resources to investigate the incident, secure the leaked data, and comply with breach notification requirements.
In summary, in the context of cybersecurity, a GDPR data leak is a critical security incident caused by a preventable oversight. It highlights the importance of not only defending against malicious attacks but also ensuring that all data processing activities, particularly on public-facing assets, are secured by design and default to protect personal data from unintentional exposure.
ThreatNG helps with GDPR Data Leaks by providing an external, unauthenticated view of an organization's digital presence to discover and remediate unintentional exposures of personal data. A data leak is considered a security incident that can lead to a GDPR violation. ThreatNG's solution, which includes external discovery, continuous monitoring, and various assessment capabilities, is well-suited to manage this risk proactively.
ThreatNG's Role in Preventing GDPR Data Leaks
ThreatNG helps prevent GDPR data leaks through several key capabilities:
External Discovery: ThreatNG performs unauthenticated discovery to find assets that an organization may not know it has, such as misconfigured subdomains or test servers, that could be leaking data. This "outside-in" perspective is crucial for identifying accidental exposures.
External Assessment: ThreatNG's assessments, particularly the External GRC Assessment, directly map external vulnerabilities to GDPR requirements.
Files in Open Cloud Buckets: A prime example of a data leak is finding files in publicly exposed cloud storage. ThreatNG's Cloud and SaaS Exposure assessment looks for open exposed cloud buckets across AWS, Microsoft Azure, and Google Cloud Platform. The presence of personal data in open buckets directly violates the GDPR's principles of confidentiality and integrity and a controller's responsibility to implement appropriate security measures.
Data Leak Susceptibility: ThreatNG also provides a Data Leak Susceptibility score that considers intelligence from various sources, including compromised credentials found on the dark web and cloud service exposure.
Continuous Monitoring: Since data leaks can occur at any time, ThreatNG's continuous monitoring is vital. It provides a real-time view of the external attack surface, digital risks, and security ratings, which is essential for managing the ongoing requirements of GDPR for data security.
Investigation Modules: ThreatNG's investigation modules allow for a detailed analysis of potential data leaks.
Sensitive Code Exposure: This module scans public code repositories and mobile apps for exposed secrets and credentials. The discovery of a leaked API key or private cryptographic key in a public repository is a clear example of a data leak that can lead to a GDPR breach. The exposure of this kind of sensitive data is relevant to GDPR Articles 5, 24, 25, and 32, which deal with data confidentiality, controller responsibility, and security by design.
Mobile Application Exposure: ThreatNG evaluates an organization's mobile apps to check for exposed sensitive information and credentials. Finding exposed access or security credentials within an app is a data leak that is relevant to multiple GDPR articles, including those on principles of processing, lawful processing, and security.
Intelligence Repositories: ThreatNG's DarCache repositories provide up-to-date threat intelligence to help identify leaked information.
Dark Web Presence: This repository monitors for compromised credentials on the dark web. The presence of compromised emails on the dark web is a relevant GDPR finding because it indicates a breach of data confidentiality and may require breach notification.
Vulnerability repository: This repository includes a database of known exploited vulnerabilities (KEV) from CISA. Finding a critical or high-severity vulnerability on a subdomain is relevant to GDPR because it poses a direct risk of unauthorized access or data exfiltration, which would constitute a data leak.
Complementary Solutions
ThreatNG's external focus can be enhanced by integrating complementary solutions to establish a comprehensive security posture. For example, suppose ThreatNG identifies a publicly exposed administrator page on a subdomain that is a potential data leak. In that case, an organization can use a Security Information and Event Management (SIEM) solution to monitor for any unauthorized access attempts to that page. This synergy enables a comprehensive response, from initial external detection of the exposed asset to a thorough analysis of any potential internal exploitation.
Similarly, suppose ThreatNG finds open non-standard ports, which are relevant to GDPR because they increase the attack surface and can lead to unauthorized access. In that case, this information can be shared with an internal vulnerability management platform. The vulnerability management platform can then use this data to prioritize patching and remediation efforts on those specific assets that are both internally vulnerable and externally exposed to a data leak.
