Privacy Management
Privacy Management technology comprises tools and processes an organization uses to comply with data protection laws like GDPR and CCPA and to obtain customer consent for processing their personal information. In cybersecurity, these tools are defensive, aiming to reduce the risk of financial penalties, legal issues, and reputation harm resulting from the misuse or exposure of protected customer data.
Consent Management Platforms (CMP)
A Consent Management Platform (CMP) is a front-end tool that captures, records, and manages user consent preferences for data processing and tracking technologies (such as cookies, pixels, and scripts).
Cybersecurity Context: A CMP is the first line of defense against privacy-related legal penalties. Its security function is not to prevent external hacking, but to ensure legal compliance and accurate data governance.
Risk Mitigation: By logging a clear record of consent (or refusal), the CMP provides an auditable trail that protects the organization from fines in the event of a regulatory inquiry.
Configuration Exposure: A poorly configured CMP —one that fails to block non-essential trackers before consent is given —creates a security vulnerability by unlawfully exposing user data to third-party advertising and analytics vendors, leading to privacy non-compliance.
Data Discovery & Rights Management
Data Discovery & Rights Management refers to the back-end infrastructure used to locate where specific pieces of customer data reside across an organization's systems and to automate the fulfillment of data subject rights (DSRs)—such as the right to access or the right to erasure.
Cybersecurity Context: This technology is critical for internal data hygiene and reducing the attack surface of sensitive data.
Data Minimization: By accurately discovering and classifying all sensitive data (PII, health records, etc.), these tools help enforce data minimization policies, ensuring that sensitive data isn't left exposed in unnecessary test environments or unsecured log files. If an attacker gains access to a server, the scope of a breach is limited to the data strictly necessary to keep it there.
Integrity Assurance: A robust system confirms that when a customer requests the deletion of their data (right to erasure), the deletion is absolute across all databases, backups, and third-party vendors. This ensures the integrity of the compliance program, which is often audited. Failure to find and erase all data can lead to regulatory fines, even if the data was not technically "hacked."
ThreatNG provides comprehensive defense for Privacy Management technology by extending its external threat intelligence to cover crucial components such as Consent Management Platforms (CMPs) and Data Discovery & Rights Management. The solution focuses on uncovering external configurations and data leaks that could lead to massive regulatory fines and compliance failure.
External Discovery
ThreatNG achieves complete visibility into Privacy Management tools through External Discovery, performing unauthenticated scanning from an adversary's perspective.
Technology Stack Investigation Module: This module identifies the specific vendor and version of the front-end CMP (e.g., OneTrust, Cookiebot) implemented on an organization’s web properties by analyzing script headers and network requests. It also identifies back-end services that might be related to Data Discovery & Rights Management functions (e.g., specific API endpoints or cloud storage bins).
Domain Intelligence: ThreatNG maps all domains and subdomains related to the privacy program, such as a Data Subject Access Request (DSAR) portal or a subdomain hosting a privacy policy, ensuring all access points are monitored for exposure.
External Assessment and Examples in Great Detail
ThreatNG transforms the discovery of privacy management assets into immediate, quantifiable risk through its External Assessment capabilities.
Data Leak Susceptibility (Data Discovery & Rights Management): This assessment is critical for protecting data subject rights. ThreatNG analyzes the organization's public footprint for evidence of misconfigurations that could expose data. A prime example is discovering a cloud storage bucket used by a Data Discovery service that was misconfigured to be publicly readable. This could expose a batch of DSAR request files containing PII and regulatory compliance records. ThreatNG identifies this failure, raises the Data Leak Susceptibility score, and flags the potential for a massive, fine-inducing regulatory violation.
Web Application Hijack Susceptibility (CMP): ThreatNG assesses the security of the front-end components that host the CMP. If the CMP is hosted on a subdomain susceptible to Subdomain Takeover, an attacker could hijack the site and replace the legitimate consent banner with a malicious version that captures user clicks but fails to register consent, leading to a severe GDPR or CCPA compliance violation.
Investigation Modules
Security teams use the Reconnaissance Hub to pivot from assessment to prioritized investigation.
Advanced Search: An analyst can use Advanced Search to query their external attack surface for all instances of a specific CMP (e.g., TrustArc) that are simultaneously running on an exposed server with a high Cyber Risk Exposure score. This allows the team to focus remediation efforts on the most vulnerable instances where the compliance gatekeeper itself is at risk of compromise.
Overwatch: This cross-entity vulnerability intelligence system provides instant impact assessment. Suppose a critical vulnerability is found in the JavaScript library used by a Consent Management Platform to record consent logs. In that case, Overwatch automatically associates this vulnerability with all identified external websites that use that technology. This ensures the organization can immediately patch the component that supports its legal compliance, preventing an auditable failure.
Intelligence Repositories
ThreatNG’s Intelligence Repositories (DarCache) provide the external context needed to prioritize privacy risks.
DarCache Rupture (Compromised Credentials): This intelligence source informs the assessment by providing data on leaked employee credentials relevant to administrators of the Privacy Management systems. Suppose an administrator’s password is found in an external data dump. In that case, it immediately raises the risk of an internal breach that could compromise the integrity of the DSAR portal or the core Data Discovery tool.
DarCache Vulnerability: It integrates severity scores and exploitation likelihoods to ensure that vulnerabilities in the underlying infrastructure of the privacy tools are addressed based on real-world threat activity, prioritizing only the most exploitable flaws.
Reporting and Continuous Monitoring
ThreatNG provides Continuous Monitoring and detailed reporting for all privacy-related assets.
Continuous Monitoring: ThreatNG constantly checks for configuration changes. If the organization fails to renew the SSL certificate for its Data Rights Management portal, the change is instantly detected, and a high-severity alert is triggered.
Reporting: The solution generates the External GRC Assessment Mapping report, which is essential for demonstrating regulatory accountability. This report highlights compliance gaps related to the discovery of an exposed CMP implementation or a configuration error that could violate a customer’s right to erasure, providing leadership with clear, prioritized actions to maintain a legally sound privacy posture.
Complementary Solutions
ThreatNG's external threat data cooperates with complementary security solutions to bolster privacy defense. The intelligence derived from the Reconnaissance Hub—such as the discovery of a misconfigured DSAR portal—can be used to enrich alerts within a Security Monitoring (SIEM/XDR) platform, ensuring that any internal network activity targeting that portal is immediately flagged as a high-risk external threat. Furthermore, the confirmed data exposure intelligence can be provided to a Governance, Risk, and Compliance (GRC) solution, allowing it to automatically trigger a regulatory notification workflow based on external evidence of a compliance failure.
