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Are Your File Transfer Integrations GDPR Compliant?

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The onslaught of data security breaches today is relentless, with thousands of major breaches each year and 50 percent more breaches in 2019 vs. 2018, according to a report by Risk Based Security. The costs for each breach have burgeoned as well, with the average cost of a data breach at about $3.92 million.


Securing data from breaches not only spares bottom line and publicity, it's now also a basic legal requirement to comply with rapidly growing data privacy laws.


While organizations have long had to comply with industry-specific standards, such as HIPAA in healthcare and the Payment Card Industry Data Security Standard (PCI DSS), you now also face new consumer privacy regulations. Including:


  • GDPR from the European Union
  • California Consumer Privacy Act (CCPA)
  • Canada's Personal Information Protection and Electronic Documents Act (PIPEDA).

Protecting data starts with data governance, the process of creating and enforcing rules & policies to ensure information is formally and properly managed throughout the enterprise. One often overlooked but critical element of data governance: file transfer governance.


What is File Transfer Governance?


When organizations consider data governance, they typically think about data sitting in their database, data warehouse, and applications. They often overlook file transfer governance, or the governance of data in motion. But for compliance with GDPR, CCPA and PIPEDA, it's just as critical for organizations to develop a compliant process for file transfers.


Here are a few critical problems many organizations encounter and solutions to help you improve your file transfer governance and prevent expensive security headaches.


1. Are Your Data Movements Traceable and Audit-Ready?


To prepare for GDPR, CCPA, PIPEDA, HIPAA, PCI DSS and more, your organization needs to be able to trace all movements of sensitive data. It's also important to monitor the success of file transfers with your external partners and customers. After all, how can you be sure you'll be paid on time if you don't know whether your partner received your invoice?


Solution: Implement Activity Logging with Managed File Transfer


Implement a managed file transfer (MFT) solution that provides detailed activity logging to meet auditor and other reporting requirements. Audit logs should track and report on when & where files were moved and when they were received.


2. Do You Have Visibility into Your Data Movements?


Organizations need end-to-end visibility into the flow of data files so they can anticipate and quickly respond to file transfer delivery failures and avoid missing Service Level Agreements (SLAs). For example, line-of-business (LOB) users need visibility into data transfer workflows so they can understand how file transfers are impacting their business services and performance. IT experts need visibility to help prevent problems from occurring and to quickly diagnose problems if they occur. One of the major reasons that organizations are unable to trace data movements is because they're using too many tools. Many companies have different teams each using different tools or even ad hoc scripts to transfer files.


Solution: Audit & Streamline Duplicated Solutions


To gain better visibility, audit your existing toolset, see what's duplicated, and consolidate as many tools as possible into a single managed file transfer solution. In addition to gaining enhanced visibility, you should also be able to reduce time spent managing and fixing disparate file transfer processes, as well as free up some IT budget by eliminating unnecessary duplication.


3. Is Your Data Secure in Transit?


Unless you transfer only files that contain no sensitive data exclusively inside your network firewall, you'll need to encrypt your files, both in motion and at rest, to prevent access by unauthorized users. But if you're using File Transfer Protocol (FTP)--the most common way to share files--you do not have built in data security. FTP transfers commands and files in plaintext, enabling unauthorized users to easily capture sensitive information.


Solution: Develop a Consistent, Simply Understood Encryption Policy


Set a corporate policy to define which file transfers must be encrypted and build uniform procedures to make sure you do so. This policy should ensure that all sensitive data subject to regulatory risk, is encrypted both at rest and in motion. It should also specify that encryption of these transfers occur both during transfers between servers inside of your internal network and outside of the firewall.


4. Are Your Servers & Components Secure?


Companies have many different security guidelines, while MFT servers have numerous options. For example, an SFTP server might use either password authentication or public key authentication. An FTP server might use plaintext or TLS connections.


Solution: Set, Log, and Audit Server Configurations to Uniform Standards


You'll need to decide on consistent standards that meet regulatory compliance and implement an MFT solution that conforms to these requirements. Assign security experts to configure your MFT platform correctly in accordance with your security policies. Then, log and audit these configurations and changes to them so no one tampers with sensitive data entering or leaving the enterprise, and to demonstrate compliance with regulations or policies.


5. Are Your Data Movements Consistent and Efficient?


Manual, time consuming data management and remediation processes can have a significant negative impact on operations. Lack of automation can lead to manual errors and unable to catch fraudulent actions. IT teams spend considerable time finding data, reconciling data, or fixing data problems rather than performing their core job functions. In addition, if an organization relies on various file transfer scripts to automate various data movements, they likely do not meet regulatory compliance standards, and hand-coded scripts are more prone to breaking than MFT solutions, again, leaving you unnecessarily open to regulatory risks.


Solution: Implement MFT Automation; Consolidate & Replace Unsecured Scripts


To address these issues, it is necessary to adopt data governance processes and automated tools to uncover problem data and broken processes, then resolve these issues. An automated managed file transfer tool can ensure that data movements are standardized. The solution should incorporate both powerful if/then, copy, route and other built-in capabilities, as well as API access to shape it as desired, with the total confidence to be able to easily comply with file transfer regulations.


6. Do You Have Traceability at the User Level?


Knowing who in your organization is interacting with your data is a key aspect of data governance. Without traceability to the specific users adding data to your systems or moving files between databases, you are not compliant with key data governance regulations.


Solution: Set Up Roles and User Permissions


Select your centralized file transfer solution with user roles in mind. A quality platform should enable you to set up different roles and permissions for different users so you can easily control who can access, edit, or send & receive data.


Unifying Data Movements with Managed File Transfer


To fully comply with regulations, organizations ultimately need to invest in more robust file transfer tools, which is why many of them are increasingly turning to managed file transfer (MFT) solutions to enable file transfer governance and ensure broader data governance efforts are successful.


MFT tools consolidate disjointed file and data transfer services into a single, unified suite, providing visibility into all file transfers and making it easier to create standard and automated compliance with policies across organizations. These MFT Software tools are built to secure data at rest or in motion with the latest algorithms and provide detailed audit trails & logs to support regulatory compliance and SLAs.

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