Isaca CDPSE - Certified Data Privacy Solutions Engineer

Critical data elements are the data elements that are essential for the organization to achieve its business objectives, comply with legal and regulatory requirements, and protect the privacy and security of the data subjects. Critical data elements should be mapped to the data process flow, which is a graphical representation of how data is collected, processed, stored, shared, and disposed of within the organization. Mapping critical data elements to the data process flow helps to identify the sources, destinations, transformations, and dependencies of the data, as well as the potential risks and controls associated with each step of the data lifecycle.

References: CDPSE Review Manual, 2021, p. 83

The answer is B. Personal data could potentially be exfiltrated through the virtual workspace.

A comprehensive explanation is:

A virtualized workspace is a cloud-based service that provides remote access to a desktop environment, applications, and data. A virtualized workspace can enable software development teams to collaborate and work efficiently across different locations and devices. However, a virtualized workspace also poses significant privacy risks, especially when it is implemented by a third-party provider.

One of the greatest privacy concerns of using a third-party virtualized workspace is the potential for personal data to be exfiltrated through the virtual workspace. Personal data is any information that relates to an identified or identifiable individual, such as name, email, address, phone number, etc. Personal data can be collected, stored, processed, or transmitted by the software development organization or its clients, partners, or users. Personal data can also be generated or inferred by the software development activities or products.

Personal data can be exfiltrated through the virtual workspace by various means, such as:

Data breaches: A data breach is an unauthorized or unlawful access to or disclosure of personal data. A data breach can occur due to weak security measures, misconfiguration errors, human errors, malicious attacks, or insider threats. A data breach can expose personal data to hackers, competitors, regulators, or other parties who may use it for harmful purposes.

Data leakage: Data leakage is an unintentional or accidental transfer of personal data outside the intended boundaries of the organization or the virtual workspace. Data leakage can occur due to improper disposal of devices or media, insecure network connections, unencrypted data transfers, unauthorized file sharing, or careless user behavior. Data leakage can compromise personal data to third parties who may not have adequate privacy policies or practices.

Data mining: Data mining is the analysis of large and complex data sets to discover patterns, trends, or insights. Data mining can be performed by the third-party provider of the virtual workspace or by other authorized or unauthorized parties who have access to the virtual workspace. Data mining can reveal personal data that was not explicitly provided or intended by the organization or the individuals.

The exfiltration of personal data through the virtual workspace can have serious consequences for the software development organization and its stakeholders. It can result in:

Legal liability: The organization may face legal actions or penalties for violating the privacy laws, regulations, standards, or contracts that apply to the personal data in each jurisdiction where it operates or serves. For example, the General Data Protection Regulation (GDPR) in the European Union imposes strict obligations and sanctions for protecting personal data across borders.

Reputational damage: The organization may lose trust and credibility among its clients, partners, users, employees, investors, or regulators for failing to safeguard personal data. This can affect its brand image, customer loyalty, market share, revenue, or growth potential.

Competitive disadvantage: The organization may lose its competitive edge or intellectual property if its personal data is stolen or misused by its rivals or adversaries. This can affect its innovation capability, product quality, or market differentiation.

Therefore, it is essential for the software development organization to implement appropriate measures and controls to prevent or mitigate the exfiltration of personal data through the virtual workspace. Some of these measures and controls are:

Data minimization: The organization should collect and process only the minimum amount and type of personal data that is necessary and relevant for its legitimate purposes. It should also delete or anonymize personal data when it is no longer needed or required.

Data encryption: The organization should encrypt personal data at rest and in transit using strong and standardized algorithms and keys. It should also ensure that only authorized parties have access to the keys and that they are stored securely.

Data segmentation: The organization should segregate personal data into different categories based on their sensitivity and risk level. It should also apply different levels of protection and access control to each category of personal data.

Data governance: The organization should establish a clear and comprehensive policy and framework for managing personal data throughout its lifecycle. It should also assign roles and responsibilities for implementing and enforcing the policy and framework.

Data audit: The organization should monitor and review the activities and events related to personal data on a regular basis. It should also conduct periodic assessments and tests to evaluate the effectiveness and compliance of its privacy measures and controls.

Data awareness: The organization should educate and train its staff and users on the importance and best practices of protecting personal data. It should also communicate and inform its clients, partners, and regulators about its privacy policies and practices.

The other options are not as great of a concern as option B.

The third-party workspace being hosted in a highly regulated jurisdiction (A) may pose some challenges for complying with different privacy laws and regulations across borders. However it may also offer some benefits such as higher standards of privacy protection and enforcement.

The organization’s products being classified as intellectual property © may increase the value and attractiveness of the personal data related to the products, but it does not necessarily increase the risk of exfiltration of the personal data through the virtual workspace.

The lack of privacy awareness and training among remote personnel (D) may increase the likelihood of human errors or negligence that could lead to exfiltration of personal data through the virtual workspace. However it is not a direct cause or source of exfiltration, and it can be addressed by providing adequate education and training.

References:

8 Risks of Virtualization: Virtualization Security Issues1

Security & Privacy Risks of the Hybrid Work Environment2

The Risk of Virtualization - Concerns and Controls3

What is Virtualized Security?4

Encryption of network traffic is the most important control to mitigate the risk of potential personal data compromise when employees access corporate IT assets remotely. Encryption is a process that transforms data into an unreadable form, making it difficult for unauthorized parties to intercept, modify, or steal it. Encryption of network traffic ensures that the data transmitted between the remote employees and the corporate network is protected from eavesdropping, tampering, or leakage.

Intrusion prevention system (IPS), firewall rules review, and intrusion detection system (IDS) are also useful controls for network security, but they are not as effective as encryption for protecting personal data in transit. IPS and IDS can monitor and block malicious or suspicious network traffic, but they cannot prevent data exposure if the traffic is intercepted by a third party. Firewall rules review can help optimize and secure the firewall configuration, but it cannot guarantee that the firewall will not be bypassed or compromised by an attacker. Therefore, encryption of network traffic is the best option among the choices given.

A private cloud is a cloud deployment model that provides exclusive access and control to a single organization or a specific group of users within the organization. A private cloud is best for an organization whose main objectives are to logically isolate personal data from other tenants and adopt custom privacy controls for the data, as it offers the highest level of security, privacy, and customization among the cloud deployment models. A private cloud allows the organization to implement its own privacy policies, standards, and procedures for the personal data, as well as to configure the cloud infrastructure, services, and applications according to its specific needs and preferences. A private cloud also reduces the risk of data breaches, unauthorized access, or co-mingling of data from other tenants, as the personal data is stored and processed in a dedicated and isolated environment.

References: CDPSE Review Manual, 2021, p. 125