GDPR and PHYSICAL security – How important is it?

Regular readers of this newsletter will know that I have paid a lot of attention and focus to the General Data Protection Regulation (GDPR). To recap, the GDPR is EU Data Protection legislation which is coming into force in May. It is a ‘beefed up’ version of the UK’s Data Protection Act 1998 and aims to introduce a common standard of data protection across the European Union – particularly covering the latest advances in social media. Despite Brexit, the UK will be under the legislation from May 25^th 2018 and the legislation is expected to make its way into British law after our exit from the European Union.

In the last couple of articles that I have covered the topic of GDPR in, I have focused primarily on GDPR in cyberspace – the need to focus on cyber security in order to keep on the right side of the legislation. Cyber security in the context of GDPR is no doubt extremely important, but for this article I would like to move away from technology and focus on GDPR in the context of physical security.

When referring to GDPR and compliance, very few commentators refer to the necessity to secure physical data. However, personal data is still stored in a physical format and therefore is still subject to GDPR legislation. For example, many schools use physical folders with pupil and parent information. Remember that Article 4 section 12 of the GDPR states that a “‘personal data breach’ means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed;”. This means that a member of staff, or worse a pupil, accessing sensitive data without proper consent is classed as a breach.

Think also of physical computers. Most staff will have access to a computer that they use for their work. In many cases, this will contain sensitive information. Do you have a policy in your school that staff must lock their computers if they leave their desk, even if it is only for a short while? Are those computers protected with strong passwords? In my experience working in the IT industry for many years, most users will not set strong passwords. They are usually easy to guess, or in the most worrying cases, system defaults such as ‘password’.

A report for the Telegraph newspaper in 2017 found that the top 10 most common passwords are as follows:

1.       123456

2.       123456789

3.       qwerty

4.       12345678

5.       111111

6.       1234567890

7.       1234567

8.       Password

9.       123123

10.   987654321

Granted, passwords are difficult to remember, especially when you have lots of different passwords for lots of different user accounts. Nobody wants to have to keep phoning their IT department because they’ve forgotten their password again.

Nonetheless, a strong password is absolutely critical to keeping sensitive data secure. A handy tip for creating passwords is to think of a phrase that sticks in your mind. For example: ‘the quick brown fox jumps over the lazy dog’. Now take the first letter of every word in that phrase and combine them to make a word: ‘tqbfjotld’. The password itself is unlikely to be guessed, but because you remember the phrase, you remember the password.

What about the security of your devices and servers? If you keep a server on-site a determined intruder could gain access to it on location. This would allow them to copy data onto an external drive and remove it from school grounds. If you do keep a server on-site, make sure that it is in its own locked room – and preferably that that room is air conditioned to avoid overheating. If you would like an extra level of security, then CCTV is a really good option. It is now possible to get ‘Cloud CCTV’ options, whereby a camera (or network of cameras) are installed in your school and connect to the internet network. It is then possible to access a live video feed of all your cameras in one online portal. The cameras can also record snapshots or video, allowing you to obtain the evidence you need to prosecute should the worst happen. The cameras are small and unobtrusive and are reliable – speak to me if you would like to find out a little more.

A good starting point for getting your physical data security up to scratch would be to assess what data you hold in physical form, where you keep it, and whether you need to keep it any longer. First of all, any data that is not crucial to running your school should be destroyed – there is no use keeping data unnecessarily.

Build up a list of your data sources and the data you hold. Then consider who has access to it, both intentionally and possibly unintentionally. If you keep folders with sensitive information in on school grounds, are they kept in an area away from unqualified staff? Are they kept in locked cabinets? Do your staff know exactly who should have access to what and can you be sure that they know not to share information with others? If you have important data stored on hard drives in servers and computers, do you ensure that you encrypt that data?

It is also worth introducing a policy around external hard drives and USB sticks, as well as personal cloud drives such as DropBox and Google Drive. We recommend that use of external drives is at least restricted, but preferably banned outright, and the use of personal cloud storage should also be banned – it is untraceable. Personal accounts for these services follow users wherever they go, meaning staff could potentially access sensitive material even if they are no longer employed by your school.

By ensuring all your staff (and pupils) understand and appreciate GDPR and how it affects your school, you can make sure everyone is pulling in the right direction to help your school be compliant. GDPR compliance involves an effort from all stakeholders in your school and the first step is strong, unambiguous policies surrounding data security.

For more information on GDPR, or for an IT security audit of your school, please do not hesitate to get in touch with me on 0330 002 0045 or contact schools@entrustit.co.uk.

Keep vigilant in the face of Cyber threats!

It appears impossible to read the news at the moment without hearing about another IT security breach. In the fortnight leading up to the time of writing, there have been reports of hacks at Uber, Imgur and a private members club whose clientele includes Stephen Fry.

Some reports suggest that cyber-attacks more than doubled in 2017. These include well publicised attacks such as the WannaCry ransomware attack that affected the NHS earlier in the year. Ransomware (a form of malware which locks files on your computer and will only unlock them in exchange for money) is a particular area of growth in cyber-attacks. In fact, more than 4,000 ransomware attacks have occurred every day since the beginning of 2016 (a 300% increase over 2015) and the proportion of phishing emails that contain a form of ransomware grew to 97.25% in 2016.

With so many attacks making the news, you may be concerned about the of cyber security threat to your Independent School. As a school with a duty of care to hundreds of pupils, it is extremely important that cyber security is tight. With so many schools keeping personal data on staff, pupils and parents as part of day-to-day operations, the consequences of losing sensitive material do not bear thinking about – particularly with the danger of steep fines under the GDPR legislation coming into force next May.

Although some Independent Schools have a dedicated ICT team, with engineers that protect and improve their networks, many don’t. For those that don’t, what practical steps can staff take to ensure that your school is as protected as possible

Patch Tuesday

Have you ever heard of Patch Tuesday? If you are not familiar with ICT, then chances are you have not. Patch Tuesday is an unofficial term referring to when Microsoft regularly releases patches for its software products. This is the second (and sometimes fourth) Tuesday of each month.

Every Patch Tuesday Microsoft releases a large number of updates for its Windows desktop and server software. These updates make UI (user interface) tweaks, performance improvements and security patches to Windows software.

If you are unfamiliar with Patch Tuesday, then chances are your desktops and servers aren’t getting the patches they need. By keeping on top of the updates, you can ensure that your hardware and software is up to date, and therefore protected from cyber security vulnerabilities

Education and Acceptable Use Policies

Whilst it is true that most Independent Schools have an ICT ‘Acceptable Use Policy’, it is also true that many pupils and staff have limited knowledge of it and limited knowledge of how they can stay on the correct side of it. In order for cyber security to work in a school environment, staff and pupils alike must understand why it is important to be safe online.

This must not just be in the context of the school, but also of the individual. Pupils are unlikely to be moved to stay safe online if they feel the only consequence of their actions is the school getting fined. By educating pupils of the dangers to them of poor judgement online, such as ransomware locking their valuable files or phishing emails stealing bank details, they are far more likely to take cyber security seriously.

By agreeing a fair ICT Acceptable Use Policy, educating pupils and staff on the details and rigorously enforcing it, you can make great progress in your school towards a safer cyber environment.

Contingency planning

Even if you feel that your cyber defences are relatively strong, a determined intruder is difficult to keep out. Schools have vast stores of personal data and Independent Schools in particular have data on high income individuals – this makes them targets for cyber-crime.

Therefore, it is important to have a plan in place should a cyber-attack occur. Under the GDPR legislation, all organisations experiencing a cyber-breach must notify the Information Commissioner’s Office (ICO) within 72-hours of the nature of the breach, what was stolen, and the measures you are taking to reduce the damage. To comply with this requirement, your school will need an individual that has at least a basic understanding of cyber security to liaise with the ICO directly.

You will also need a strong backup approach in place. It is preferable that you backup every day to a cloud server or an external drive. Once the backup is completed, removing the external drive from your servers and storing it securely will prevent the backups from also being infected. Furthermore, perform tests of your backups to ensure that they work and to give you a rough idea of how quickly you can restore your infrastructure from a backup. If your tests indicate that your backups take too long to restore, you may wish to look for better options.

Removable Media Controls

Many people still use USB thumb drives or external hard drives to store and transport files. However, removable storage media is an extremely unsafe way to manage file transfers. Thumb drives in particular are easy to lose and when pupils and staff can use personal thumb drives to move files around, you have little control over what files they are removing from the school premises, or indeed what files they are bringing in to the school network.

If a pupil or staff member were to bring in a thumb drive from home that had a malicious file on it, that file would have the potential to infect the whole school network.

Ensure that removable media is encrypted and scanned for malware before importing files onto the school network. Many businesses have even banned removable media entirely. A cloud option, particularly one that is built from the ground up with security in mind, such as Citrix ShareFile, is in my opinion by far the safest way to store and share documents.

Be Vigilant

It is not easy to keep on top of cyber security. However, it is so important to understand and to mitigate the risks. By putting the advice listed above into action you will not be completely protected from cyber threats, but you will have a strong foundation of security.

If any school would like further information or consultancy on ways in which they can protect themselves, or ways in which they can reach GDPR compliance next May, please do not hesitate to get in touch with me at schools@entrustit.co.uk or 0330 002 0045.

Preparing Your Independent School for GDPR: Cyber Security Issues

In my recent blog I talked about the importance of understanding your data and securing your information systems from internal threats in readiness for GDPR. In today's article I wanted to talk about the other side of the coin: securing your information systems from external security threats.

We only have to open a newspaper or turn on the news these days to hear about some new cyber security threat or data breach that has occurred. Protecting against such breaches forms an important part of GDPR compliance, since you need to be able to demonstrate that you are taking proper care of the personal data that your school holds.

There are a wide range of factors to consider here, which will include:

1. How is your network secured from threats like malware, ransomware and hackers?
In days gone by a firewall and some antivirus software would largely do the job, but with the constantly evolving threat landscape this is no longer the case and a much more sophisticated suite of school procedures, processes and technologies is needed to provide full protection.

2. What are your procedures for applying security updates to your systems?
New security threats are emerging daily and software vendors are releasing a constant stream of fixes and patches to try and mitigate the risks from these threats. Therefore it is critical that you apply these security fixes to both your servers and your PCs and laptops in a timely fashion. Indeed, the timeliness of updates has now become even more critical since some cyber criminals are now reverse engineering the fixes from vendors such as Microsoft, in order that they can see what vulnerabilities have been fixed, and using that information to directly target those vulnerabilities in organisations who have not applied the appropriate update to their systems.

3. How is your data backed up?
Taking full system backups which are regularly tested is essential, so that you know you could recover data in a timely fashion should your school be hit by a cyber threat such as ransomware.

4. What are your procedures around physical security of your servers and IT equipment? Having good cyber security in place is critical, but if someone can access your server room or acquire a laptop or smartphone containing school data, then the very best cyber security systems can be rendered useless.

5. How do you manage secure disposal of old PC and server equipment?
Equipment that is end-of-life and being replaced will often contain confidential data or emails, and therefore it is important that it is properly wiped, to guarantee that data cannot be restored.

6. How are your staff educated to ensure they are aware of the latest cyber security threats?
It is all too easy to click on seemingly legitimate attachments or web links which may actually contain malicious code, and with new threats constantly emerging, the vigilance of your staff in being able to spot such scams will form part of your defence strategy.

7. How and when are your procedures around cyber security reviewed and updated?
Given the constantly changing threat landscape, it is critical that procedures and controls around cyber security are regularly reviewed and updated

For more information about protecting your school from cyber threats or preparing for GDPR, please do not hesitate to contact me on 0330 002 0045 or email schools@entrustit.co.uk.

Protecting your School's Network Manager from Stress and Burnout

In my recent blog, Why Every Independent School needs a Super-Hero, I talked about the wide ranging variety of roles that we expect our network managers to fulfil, from support provider and trainer, right through to network architect, project manager, cyber security expert and much more besides. 

At this time of year, when for many of us our thoughts are beginning to turn to a welcome break from work, let's spare a thought for our network managers who are often planning for one of their busiest periods in the school year – the summer holidays.  

Whilst we are enjoying the sunshine, many of them will be immersed in technically complex projects to upgrade the school’s network infrastructure. Now don't get me wrong, for many network managers, this is an exciting period of the year when they get to experience new technology and increase their technical skill set.  However, it is important that all of us get a break from time to time, and as employers we all have a duty of care towards our staff to ensure that that is the case.

So, if not during the summer holidays, then when will your network manager get a break this year?  This can be a tricky challenge, since once the summer holiday projects are complete, and school is back in full swing, we need our network managers to be in school more than ever, to provide support, hand holding and training, especially during that back-to-school phase, when invariably passwords will have been forgotten, there will be large numbers of new pupils, some new staff and  some snagging issues from the holiday upgrade projects.  As a result, I see many network managers who become overloaded, and in some cases this can even lead to serious health issues.

One answer can be to partner with an experienced schools ICT provider, who can provide a flexible holiday cover support contract for your network manager, giving network managers the time and uninterrupted rest they need to recharge their batteries, whilst giving schools the reassurance that their ICT systems are still safely supported.  Such contracts can also provide a useful backstop for the network manager at other times, by providing them with extra resources and skills to call upon during what could otherwise be stressful situations, such as getting to the bottom of a particularly thorny problem, or providing day-to-day support when they are tied up on project work.

So while you are relaxing by the pool this summer, do spare a thought for our hardworking network managers.  

If you would like more information about EntrustIT’s support services for schools, including holiday cover for Network Managers, please do not hesitate to contact me on 0330 002 0045, email schools@entrustIT.co.uk or visit our website http://www.entrustit.co.uk/our-specialisms/education/

How would your Independent School cope with 22 Hours of ICT Downtime?

In the wake of British Airways catastrophic IT Failure which left so many passengers stranded at airports at the start of half term, I thought it would be timely today to talk about disaster recovery.

As anyone who has ever experienced network downtime will know, it is amazing how crippling an ICT system failure is to a school, and how far reaching the consequences can be. Not only does an outage create classroom and administrative operational chaos, it can also have serious consequences for the school’s reputation, particularly where there is loss of critical data such as pupils’ coursework, or a breach of security around confidential pupil data.

Whilst many schools I talk to tend to associate ICT downtime with large events such as fires or floods, the reality is that the majority of ICT downtime has much more mundane causes which can include hardware failures, loss of power, cyber security breaches (such as ransomware attacks) and software failures. And in many cases the downtime is considerable, with the EMC Global Data Protection Index 2016 study showing that the average length of unplanned downtime was 22 hours. Indeed the situation seems to be worsening this year, with ICT downtime caused by ransomware attacks in particular often running into a week or more.

And while many of us can work around a short system outage, when such outages are extending into days or even weeks there can be a serious impact on the school’s operations and reputation. As such, it is critical that the senior leadership team have a thorough understanding of their risk management processes and contingency procedures around network resilience, backups and disaster recovery.

So is it enough to have a disaster recovery plan? Sadly I fear not. I’m sure BA had a disaster recovery plan, but how well did it work when it was used in anger? For many schools, I find the disaster recovery plan that was put together some years ago and has sat in the fireproof safe ever since, without testing or updating. My experience is that this document needs to be constantly evolving, as our use of technology in education has moved on apace, and what was an acceptable recovery plan a couple of years ago may now be totally inadequate. In addition, our systems are constantly changing, with software updates and security fixes being installed on a regular basis, all of which can impact on the technical success of a recovery.

In order to ensure ongoing relevance, I always recommend that schools continually re-assess and test their plans around resilience, backup and disaster recovery, against the operational needs of their school and their changing use of technology. Some points to consider would include:-

• How long could you afford for each of your various ICT systems to be down for? 
• How much data and email, if any, could you afford to lose?  
• When did you last try a test restore of your data or email? Did it work?
• Have you tried a test of your full disaster recovery plan lately? Did it work? How long did it take? How much data was lost? Did the results demonstrate that recovery times and data loss met your school’s current operational requirements as defined above? 
• Do your backup and disaster recovery plans meet your forthcoming GDPR compliance obligations? 
• Where are your backups held? Would an incident like a fire or a ransomware attack wipe out your backups as well as your live systems? 
• In the event of a major disaster, what hardware would you restore your backups on to? 
• How would your school operate in the period whilst the systems were down? 
• How would you communicate details of an outage with parents, staff, pupils and the public to minimise the reputational damage to your school?

 If you are unclear of the answers to any of these questions, it may be time to review your processes and procedures around disaster recovery planning to ensure your school is not exposed to undue risk in this area. If you have any questions or would like information on ways EntrustIT can help, please do not hesitate to contact me on 0330-002-0045 or email schools@entrustit.co.uk

Cloud Computing in Independent Schools

It's true, the network does seem to get the blame for many things!

But if technology providers are to be believed, all our woes will soon be over, thanks to the advent of the “Cloud”.

This is a subject I get asked about a lot when I visit schools, so I wanted to put pen to paper to try and clarify what it's all about, as I know there is a great deal of confusion.

Cloud computing is a huge subject, but at its simplest it delivers software & data to any internet connected device; from datacentres owned by a service provider. Data will be synchronised across all devices that a user may use to connect and changes are immediately applied giving a “fully mobile” experience. Assuming you have the right level of internet connectivity, the experience will be almost indistinguishable from a traditional system – and of course it matters not if you lose or break the device because there’s nothing really stored on it that cannot be accessed from somewhere else.

Before I get bombarded by emails from the true experts among you, I realise this is a gross simplification. However I think it summarises nicely the key aspects of a cloud environment for an independent school.

The benefits of this kind of arrangement include:

• Systems can generally be accessed from anywhere, using any device. This facilitates remote working, easy sharing of data and Bring Your Own Device (BYOD).

• The hardware, software and security of the cloud system is maintained and managed by the service provider, removing a huge burden of work, worry and cost from the school.

• Remote storage of the data makes disaster recovery and resilience much simpler to achieve. Backup almost ceases to matter – although you have to be careful of the geography of your cloud partner (on which, more later).

• Such systems tend to be licensed on a "per user, per month" basis, thereby removing large CapEx spends on replacement server equipment and making costly disk and SAN upgrades a thing of the past.

There are however a number of different types of cloud and it is very important that schools understand the differences between them and the benefits and risks associated with each before making any decision to migrate to the cloud.

Public Cloud

With public cloud, the provider stores data in a network of computers, which potentially may be located anywhere in the world, with server use and storage pooled among clients. This model reaps huge economies of scale for the providers, and as such they are able to offer comparatively low monthly subscription costs. Well-known examples of public cloud would include Microsoft Office 365 and Google Apps for Education (GAFE).

Private Cloud

With the private cloud model, the same benefits are delivered as with public cloud, but on a "private" basis, with separate resources being dedicated to each client at the cloud provider’s data centre. This provides greater security and control over data, including assurances over exactly where the data is held. Being a more individual service, private cloud can also offer a much more tailored experience for schools, encompassing not just data storage and the common Microsoft applications, but a full desktop of all their education software. However, as this model does not allow providers to leverage the economies of scale in the same way as public cloud, it is necessarily more expensive.

Due Diligence and Data Protection

It is important to realise with any cloud implementation that, although you are transferring control of your data to a third party, you still remain legally responsible for protecting that data. As such it is vital to carry out due diligence to ensure you are happy with the level of security, availability and legal compliance the provider offers. This should include looking at their Service Level Agreements around availability, compliance with security standards such as ISO27001, and examining their T’s &C’s to ensure you are clear where your data is going to be held (including not just “live” data but also copies for backup and disaster recovery).

On this latter point, the data protection act requires that personal data may not be transferred out of the EEA unless the territory to which it is sent ensures an adequate level of protection. Given the US dominance of public cloud provision, it is transfers to and from the US that are most likely to affect a UK customer.

Last October the EU-US Safe Harbour agreement that enabled data transfers between the EU and the US to comply with Data Protection laws was overturned. Its successor (the EU-US Privacy Shield) only came into effect in July and is already being contested in courts in Ireland and France. To keep European business flowing the large public providers (Microsoft Azure, Google, Amazon) have attempted to embed EU data protection laws in their contracts for EU citizens. However, if we learned one thing from Snowden, it is that the US Government considers all data processed by a US business to be “fair game” – wherever the ultimate user may be from. So even if the cloud provider is well intentioned toward protecting its EU client base; there is no guarantee that the US courts or government will agree.

What does this all mean for an independent school?

Caution should remain in place when using public cloud services. There are some excellent applications available for education and you should take full advantage, however, try and resist public cloud based messaging solutions (email etc) unless they guarantee EU only data processing & be careful about what data you share using public cloud tools. At the end of the day, school data will always remain the responsibility of the school, and therefore it is for the school to assess safeguarding risks.

Cloud technologies can be a fantastic tool to embed ICT into school life, however, many schools remain sufficiently concerned over data geography to adopt private cloud solutions, or indeed “closed cloud” solutions where all data remains in school. The latter is a topic in its own right which I shall be exploring in a future article.

In the meantime, should any Bursar like my advice on data storage solutions that will leave their school fully compliant in this regard, or indeed any other ICT related issue, please do not hesitate to contact me on 0330 002 0045 or email schools@entrustit.co.uk