As the implementation of the Protection of Personal Information Act (PoPI) gradually comes closer, South African organisations are wondering how best to prepare for it.
The key is to understand that data security lies at the heart of PoPI compliance, argues Godfrey Kutumela, head of security and cyber crimes prevention unit at IndigoCube.
“Personal information is part of the organisation’s total data set, so any strategy to become PoPI-compliant has to begin and end with how you manage and use data as part your business operations,” he says. “And, because virtually every organisation is moving to digitise all its data assets, data confidentiality and integrity is at the heart of any data privacy and protection management process.
“Once you understand this, it becomes much easier to scope, design and execute a data protection strategy that the regulator will deem reasonable.”
By way of background, Kutumela explains that while PoPI has been signed into law, full implementation has been delayed pending the approval of a regulator. Candidates for the post were shortlisted in April 2016, a major milestone on the road towards full implementation.
PoPI does not stipulate how organisations should protect and manage the personal data in their possession; rather, it requires that “appropriate, reasonable, technical and organisational measures” are taken.
“We are breaking new ground here, and it will take some time before there is a body of administrative decisions by the regulator that will give greater certainty,” he says. “In the meanwhile, there are three logical steps that organisations can take to demonstrate they have sought to apply the law.”
Kutumela’s three steps to PoPI compliance are:
* Identify personal data that is collected, stored or processed in your organisation. To accomplish this, it will be necessary to conduct an enterprise-wide exercise to determine the privacy risk the organisation faces. There is simply too much data to protect it all, so it’s vital to know where the personal data covered by PoPI is, with the guiding principle being the business strategy. Those applications and data stores that directly enable strategic goals should receive the highest priority.
* Control access to personal data using a risk-based identity model. Kutumela strongly argues that identity management and access control are the cornerstones of any security system. When it comes to protecting personal data within the spirit of the Act, they are vital. “Not only must personal information be protected from cyber-criminals, it must also be used appropriately, in line with the purpose for which it was collected,” he points out. “That means it should only be accessed by employees or apps for the purpose for which it was collected.” The challenge here is that digital business models depend on data sharing, so access decisions need to be dynamic, and based on a clearly defined set of risk factors.
* Protect personal data, whether structured or unstructured, adequately while it is at rest. The most effective way to protect personal data–or any data–is where it is stored, in the database. When it is being used, it is dispersed and does not present a target; as a result, attempts to hack data target data repositories. “Data repositories are where the crown jewels are kept, and they should be the focus of security efforts,” Kutumela says.