Inspired by the reporter.lu 2021 review, I have adapted a quote by the investigative journalist Hans Leyendecker to my role as Chief Information Security Officer (CISO) in my New Year’s greeting: ‘A good CISO is an unsatisfied CISO. No one who is completely satisfied is capable of implementing security’. This sentence has comforted many internal and external CISOs I have worked with in 2021: Guillaume, Ingo, Laura, Marc, Matthieu, Patrick, Yannick… We often feel like a troublemaker when we point out procedures that are not followed, common security practices that are considered too complicated, good reflexes that have been abandoned due to lack of time. We confess our uncertainty about risk analysis or our pessimism if we survive without our advice being followed… But we have all learned that to succeed, we need a positive spirit, openness to new technologies, autonomy, creativity, and above all an year for market changes. This is generally what CISOs do: they follow the latest recognized standards, try to convince, coach, implement artificial intelligence in network supervision… But their role is also to find vulnerabilities, to set social engineering traps, to insist on good documentation avoid future errors and loss of know-how, to require traceability of decisions and acceptance of risks (without embellishment), thus ensuring sustainable decisions, instead of justifying preconceived ones. The CISO is thus the right ally for a CEO who is looking for the best decisions in the face of new challenges. It is by disagreeing with an observed security that the CISO stimulates to find better. And his persistence avoids risks: services started without an adequate agreement on responsibility, too fast migration to the cloud creating dependency for a short-term advantage, open doors to cybercrime, resignation in the face of internal negligence. It avoids downtime or costly replacements or fixes. Fortunately, it is not only CISOs who are holding back. A courageous CEO recently confessed to me that he often finds himself in the position of putting the brakes on projects in which the customer’s view, financial feasibility, security, legal compliance, etc. have been neglected. Enthusiasm does not guarantee success. For sustainable projects, managers cannot escape from working with CISOs and taking care of security and data protection themselves. And there are often CISOs who come up with interdisciplinary and creative solutions, sometimes simpler than expected and standing in contrast to the flagship products that do everything but work efficiently without… Read more »
Posts By: Ingo Senft
GDPR: Do you have a PIMS that holds up?
Interview with Lëtzebuerger Gemengen, translation by itrust consulting. On 28 May 2018, the General Data Protection Regulation (GDPR) came into force in the EU. Three and a half years later, many organisations are slow to comply, considering it too complex. For Carlo Harpes, the situation is worrying. The Managing Director of itrust consulting recommends PIMS, a Privacy Information Management System, helping companies in order to comply with the GDPR requirements. Explanations. What is a PIMS? A ‘privacy information management system’, abbreviated ‘PIMS’ even in French, is an ‘information security management system that manages the protection of privacy as potentially affected by the processing of personal data’. Personally, this is what I would have called a ‘management system to protect personally identifiable information’ and I would present it as a way to comply with the GDPR. To implement this, there are 1,001 solutions, usually valid for small organisations where data protection is not the primary concern. But for the past 26 months there has been one PIMS, which has been described so precisely that organisation can be certified on this basis, the one documented in ISO/IEC 27701. Who needs it? 3,5 years was not enough time for most organisations to comply with the GDPR. How many have not appointed a DPO (although this is a legal requirement for any public entity)? How many do not have a register of processing that complies with the requirements? How many cannot prove to the CNPD their compliance with the principles of the GDPR, including the one requiring ‘appropriate technical and organisational measures’? Faced with the difficulty of knowing what is appropriate and how to demonstrate it, leaders (policy makers, mayors, heads of administration, CEOs and manging directors), often give up and hide behind the non-compliance of their neighbours. From my observations, this situation is worrying, and only the CNPD, which has the obligation to sanction, should be aware of this state. All the organisations involved here would have benefited from this PIMS. Who defined this PIMS? The Luxembourgish authority ILNAS, which I represented at ISO in multiple expert meetings dedicated to this standard since 2014, was arguing with its European partners for a fast and fully GDPR compatible standard. To support compliance with these requirements, we have made numerous suggestions for improvements to the overly complicated numbering and certain overly cumbersome wording. In France, the CNIL has welcomed its participation and encourages the adoption… Read more »
Merry Christmas and Happy New Year
CSB#48 – Can we use the CyberSecurity Act (CSA) to improve the current information security baseline?
Dr Carlo Harpes to explain the potential of the EU Certification initiative, the role of regulators and public procurement to require certification, the pitfalls in certification such as with the LU CARPA initiative, the need for collaboration among all actors, the need to learn and improve ICT development lifecycle and testing, the danger of dependency after mergers of today’s certification authorities and the importance to care about ‘high’ certification that should stay feasible for innovative company, not only for market leaders.
Press release about ‘LuxQCI’ with itrust consulting as partner of the consortium
An SES-driven consortium that seeks to develop a satellite-terrestrial quantum communication infrastructure and the roadmap for wider European integration, setting the path for next-generation cybersecurity. To design the LuxQCI, Luxembourg has put in place a consortium comprising InCert, itrust consulting, LuxConnect, LuxTrust and the University of Luxembourg (SnT), that is led by SES’s fully owned affiliate SES Techcom.


