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.

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

Monetising Your School’s ICT Facilities

Independent schools spend a significant amount of money on ICT facilities both to enhance the learning environment and to ensure the smooth running of the school’s administrative function. Whilst most schools will look to incorporate messages about their ICT facilities into their marketing literature to attract new pupils, there is also the opportunity to leverage ICT to generate income from other sources too.

Technology plays an important part in most people’s lives nowadays, and when booking social, educational or leisure activities, having access to good technology, such as fast Wi-Fi and Internet connectivity, forms an important part of people’s decision making process in choosing a venue for such events. This is something which Independent Schools can capitalise on, since they have these facilities anyway, which are often lying dormant, or as a minimum under-utilised, during the school holiday periods.

ICT suite(s) are an obvious facility that can be let out in the school holidays to summer schools, clubs or local groups. However lettings do not need to be restricted to the ICT suite alone nowadays, since most independent schools now enjoy school-wide Wi-Fi and support for BYOD (Bring Your Own Device) which presents the opportunity to let out any classroom, allowing guests to bring their own equipment and effectively set up an ICT suite "on the fly".

Many Independent Schools have also invested in a music technology suite, which is a desirable facility which can be let to groups, clubs and budding local musicians during periods when the school is not using it.

Wi-Fi is also now considered a "must have" for events such as weddings, parties, summer schools or business conferences. Whilst they are not always aware of it, many schools’ Wi-Fi systems offer the facility to generate restricted-duration tickets for guest Wi-Fi access, as well as the ability to charge for Wi-Fi access in the way that many hotels do, typically offering a basic level of connectivity for free and then charging a fee for higher speed/capacity.

Most schools have also bitten the bullet and paid the charges needed to get high speed leased line Internet connectivity into their premises. However many smaller businesses or clubs in the area cannot necessarily afford these type of costs. This offers another opportunity to Independent Schools to provide a slice of their internet connectivity to a local small business/golf club/sports club etc as an income generator for the school.

So one way and another there is much that schools can do to leverage their ICT and create an additional income stream from it.

Naturally if you're planning to provide access to your school ICT facilities to outsiders, then some suitable security provisions need to be put in place. This is relatively straightforward though, since firewall policies can be set up and Wi-Fi configured such that guests are kept completely separate from the school's network traffic and systems.

If you would like more information on this topic, please do not hesitate to contact me on 0330-002-0045 or email schools@entrustit.co.uk.

Preparing for GDPR – Understanding and Securing your School’s Data

Following on from my recent blog, “GDPR – What’s it all about and how does it affect Independent Schools” I’ve had requests from several schools asking for more information, so I thought it would be useful to elaborate on some of the issues that GDPR raises for Independent Schools.

I wanted to start by further exploring the importance of understanding what personal data you hold and where that confidential data is stored. Bear in mind personal data can be as simple as a pupil, teacher or parent’s name or email address.

This may sound like an odd topic, as I'm sure many of you are thinking you know exactly where all your schools’ data is held. But do you really?

The scary reality nowadays is that your school’s precious data may already be widely scattered. Yes, some of it will certainly be residing (hopefully securely) on your in-house servers. But what about the proliferation of school, staff and pupil owned portable devices such as laptops, tablets and smartphones which now hold school data or emails? Or data that has been copied to removable media such as USB sticks? Or data that has been shared with business partners and other third-parties? Or copies of data taken for backup purposes?

Then there is the cloud. The cloud has revolutionised the way many schools store their data, but in doing so has also globalised the way data is stored, with many public cloud providers distributing data across servers worldwide in order to optimise costs.

So do you really know where all your data is held? And does it matter?

Well in terms of GDPR it certainly matters, as you need to be able to demonstrate that you are protecting your data and using it appropriately. The more widespread and less controlled your data is, the more vulnerable you leave your school to a breach of data security. So understanding what you have and where it is forms the first step towards compliance.

If, on reflection, you realise that your school’s data is already widely scattered, you may wish to bring it together in one secure, central repository in order to make it easier to control and manage. Luckily nowadays there are technologies that facilitate this; for example we have built our very own EducateIT desktop platform for schools, which is an onsite private cloud solution which allows a school to bring together all their data in one secure, central, onsite repository, where they and their authorised partners can access it securely wherever they are, without the source data ever leaving the security of the school. For other schools, where data is generally central, but perhaps also resides on some mobile devices too, we work to implement processes and technologies to prevent data leakage and manage mobile devices.

Either way, it is paramount to put the school back in control of its data, knowing both where it is and who has access to it. This in turn needs to be documented, both so that the senior leadership team team have understanding of, and control over, their valuable data and also in order to provide documentation for compliance and audit purposes. This not only puts schools back in control of their data, but minimises the risk of a security breach and takes the first step towards preparing for GDPR compliance.

Once you have this understanding, the next step is to understand how you secure your data. This broadly falls into two categories – access control (effective security for authorised users) and cyber security (protection against unauthorised access).

Today I am going to talk about the former, as having good access control systems lies at the heart of successfully protecting your school’s data, and forms an important part of preparing your school’s information systems for GDPR compliance.

GDPR places accountability on schools to have in place policies, procedures and documentation that demonstrates the personal data they hold is stored securely. Bearing in mind that schools hold a vast array of personal data, much of which is about children, whom the GDPR identifies as “vulnerable individuals” deserving of “special protection”, and it becomes clear that the legislation is likely to cover the vast majority of a school’s data.

Therefore, for each of your computer systems, it is important to understand, and have documented, who has access to that system and what level of access they have. Bear in mind that it is best practice to give each user the minimum access they require to the system. Allowing wider access to systems puts you at greater risk of a data security breach or data loss through incidents such as accidental deletion, a ransomware attack or malicious insider threats. As well as having SOPs in place to handle the ICT access control requirements of new starters, it is equally important that there are procedures in place to cover leavers (both pupils and staff) and what happens when somebody changes role within the school.

Password policies are always a bone of contention and an area where a fine balance needs to be struck. Policies that are too lax lead to easily guessable passwords which may not demonstrate due care of data under GDPR. On the other hand, policies which demand highly complex, long passwords which change frequently, may lead to dozens of forgotten passwords and/or the temptation to record passwords on sticky notes, which also certainly doesn’t demonstrate due care of data!

Nowadays, it is also likely that third parties such as freelancers, suppliers and of course parents will have access to some of your ICT systems or data. In this case this needs to be secured in just the same way, so you are clear who has access to what parts of the system, why this is needed and how it is controlled. There also need to be procedures in place to review, amend and remove access for third parties, as relationships evolve and change.

Mobile and remote working present a whole additional set of challenges to ICT security, with the potential for copies of data or emails to be residing on all kinds of devices, both school owned and personally owned, which do not necessarily conform to school security standards. So developing policies around mobile working and ensuring there is not leakage of data or unauthorised access to data form a critical part of compliance. Policies and technologies also need to be implemented to protect against data breaches from mobile devices that are lost or stolen.

Finally, bear in mind that it is not just your main school-wide IT systems that fall under the GDPR. Any indexed system that contains personal data is subject to the legislation, so do make sure you are also including in your access control procedures all those little databases or spreadsheets that have been developed by an individual or department and which contain personal data.

I hope this has given you a useful insight into some of the key areas to consider around readying your school for GDPR compliance. If you need help preparing for GDPR, or indeed with any element of your ICT system, please do not hesitate to contact me on 0330 002 0045 or email schools@entrustit.co.uk

GDPR – What’s it all about and how does it affect Independent Schools?

The new EU General Data Protection Regulation (GDPR) comes in to effect in May 2018 and represents the most radical change in data protection legislation in the last 20 years. Whilst many schools, and indeed businesses, that I work with were hoping this would go away, especially in light of Brexit, it has now been confirmed that the UK will be implementing the legislation and as such, is “the elephant in the room” that schools can no longer afford to ignore. So today I thought it would be useful to share some information on what GDPR is all about and what key actions Independent Schools need to be taking to ensure compliance.

  By way of background, GDPR has been developed to reflect the changing use of data in the digital world in which we now live. With the digital economy being primarily built upon the collection and exchange of data, including large amounts of personal data, which is often sensitive, there is a need to protect EU citizens’ privacy rights. GDPR is designed to enable citizens to benefit from modern digital services, whilst providing sound, well formulated and properly enforced data protection safeguards to help mitigate risks and inspire public confidence in how their information is handled by businesses, third parties, the state and public service providers.

Whilst these aspirations are to be lauded, there is much concern amongst schools and businesses alike as to the reality of understanding and implementing the legislation within their organisation. And whilst the implementation date of 25th May 2018 may still seem a long way off, the reality of the situation is that the changes this legislation requires many organisations to make are so far reaching that they need to start work now in order to be compliant in time.

The new legislation also gives the regulator real "teeth" in terms of enforcement. For example if you do not comply with some of the fundamental provisions in the legislation, such as obtaining necessary consent, you can be fined up to 4% of your total worldwide annual turnover or €20 million, whichever is greater. Equally, penalties of up to €10 million or 2% of your total annual turnover apply for not putting in place adequate security.

In addition, breaches have to be notified to the data protection authority and in some cases the people affected, without delay. This leaves the school concerned highly exposed to reputational damage and potential pay-outs to affected parties.

The situation for schools is further complicated by the fact that the GDPR identifies children as “vulnerable individuals” deserving of “special protection”. As such, schools also need to be aware that the new rules introduce some child-specific provisions, most notably in the context of legal notices and the legal grounds for processing children’s data.

One important element of GDPR compliance is protecting your data from external security threats. Schools are becoming an increasingly popular target to cyber criminals unfortunately, as there is a perception that they are a soft target, not always equipped to spot signs of increasingly sophisticated cyber fraud. Threats like ransomware for example, which I highlighted in my recent blog, are sadly now becoming more and more common in schools. And apart from the financial and operational impact these type of threats have on the school, which can be extremely damaging as they lock pupils and staff out of the system, such malware can also be used to export information. This presents a major risk under GDPR, given the compromised data involves the details of schoolchildren, which could have serious implications if it fell into the wrong hands.

In addition to outside security threats, there are a plethora of other threats to schools’ confidential data, ranging from something as simple as a staff member’s laptop or phone containing school email or data being lost or stolen, through to unauthorized copies of data being made or inadequate starter and leaver procedures for systems access.

There is no doubt that GDPR will have a wide ranging impact on schools, affecting functions as diverse as marketing, fund raising, admissions, HR and ICT, and as such is something that will need much Senior Leadership Team time and planning in order to mitigate the risks and ensure compliance by the deadline.

So what do Independent Schools need to be doing in order to mitigate the risks?

Well this is a big question and one I will be exploring in more detail in coming blogs, but to give you a flavour, the type of things you should be considering include:

1. Identify what personal data you are holding. Bear in mind personal data can be as simple as a pupil, teacher or parent’s name or email address. This is vital because you need to be able to demonstrate that you are protecting this data and using it appropriately. So understanding what you have and where it is forms the first step towards compliance.
2. Identify threats to this data. This could include things like cybercrime mentioned above, but also accidental loss by staff, deliberate theft by staff or pupils, lost devices and unauthorised access to data. This is vital if schools are to avoid the fines of up to €10 million that can be levied for unauthorised access to, or disclosure of, personal information.
3. Invest in and implement the right technologies to deal with insider and external threats to data. This will involve a wide raft of technologies to provide protection from a range of different threats. It is vital to realise that a firewall and a piece of anti-virus software are not enough.
4. Put together a new or updated data protection policy and train staff on it. This is important as everyone in your school needs to understand their obligations under GDPR and how to make themselves fully compliant.
5. Put in place processes for ongoing education for all members of staff around cyber security and data protection. Because the cyber security landscape is constantly changing, it is very important that all staff are constantly kept up-to-date with best practice around security and data protection.
6. Create a breach notification plan. This is important because if the worst should happen, and you do experience a data breach under GDPR, you need to have a clear plan to deal with it and communicate it as smoothly and accurately as possible, and with the least possible damage to your school.

In future blogs I will be exploring these issues in more depth, but if in the meantime you need help with GDPR compliance, please do not hesitate to contact me on 0330-002-0046 or email schools@entrustit.co.uk