Blog posts by Matthias Reinwarth

Please! No More GDPR Related Blog Posts!

You have heard it all before: May 25th, 2018, enormous fines, "you have to act now", the "right to be forgotten", DPO and breach notification. Every manufacturer whose marketing database contains your data will send you information, whitepapers, webinars, product information and reminders about GDPR. And they of course can help you in getting towards compliance. So you have set up a filter in your mail client that sorts GDPR messages directly into spam and #gdpr is muted in your Twitter client.  

Because you have started your journey towards compliance to GDPR early? Compliance activities have long been established and your employees are informed? Consent management is not just theory? Data Leakage is prevented, monitored, detected and if it does occur, communicated appropriately?  

But there might be still a good reason to read on: Unlike other regulations, there is no regular inspection of compliance with the requirements. Rather, individuals (including customers, employees or other relevant data subjects) and the competent supervisory authorities are able to make enquiries if alleged or actual omissions or offences are to be investigated. However, as yet there is no proof of GDPR compliance as a regular and permanent seal of quality. 

It is difficult to identify sufficient indicators for good preparation. Yes, vendors and integrators provide some basic questionnaires… But you still might be in need of a neutral set of criteria determining the maturity level of your organization's readiness in the areas of compliance with regulatory or industry-specific regulations or frameworks. To support such reviews, KuppingerCole provides Maturity Level Matrixes that are specifically targeted to distinct areas of the IT market, in this case, GDPR readiness.  

Assessing the quality and maturity of the controls, systems and processes implemented by your organization is essential. Given the level of agility required from business and market requirements this assessment needs to be executed on a regular basis. Continuous improvements are essential to achieve an adequate level of compliance in all key areas of the GDPR. 

To achieve the highest level 5 of GDPR maturity it is essential to continuously measure GDPR readiness to enable an organization to understand their status quo, document it and, if possible, realize the potential benefits of investing in improving data protection. Then you might happily ignore further GDPR-related blogposts. 

The KuppingerCole Maturity Level Matrix for GDPR readiness provides neutral criteria exactly for that purpose. Find it here for download. 

And get in touch with us if you feel that an independent assessment (along the lines of exactly the same maturity levels) might be even more meaningful. 

Not Just Another Buzzword: Cyber Risk Governance

Today, companies are increasingly operating on the basis of IT systems and are thus dependant on them. Cyber risks must therefore be understood as business risks. The detection and prevention of cyber security threats and appropriate responses to them are among the most important activities to protect the core business from risks. 

But in practice, however, many challenges arise here. The requirement to arrive at a uniform and thus informed view of all types of business risks often fails due to a multitude of organisational, technical and communication challenges:  

Technical risk monitoring systems in the enterprise (e. g. systems for monitoring compliance with SoD rules or systems for monitoring network threats at the outer edge of an enterprise network) are often extremely powerful in their specific area of application. Interoperability across these system boundaries usually fails due to a lack of common language (protocols) or the semantics of information to be exchanged (uniform risk concepts and metrics). 

The same thing is happening in the organization of large organizations: although it is only a few years in which we have observed this trend, this leads to independently operating IT operations teams, IT security teams and (cyber) governance teams that focus on individual tasks and their solutions with which they deal with individual, but very similar problems. They typically act without adequate integration into a corporate security strategy or a consolidated communication approach for the joint, coordinated management of risks. They do this without correlating the results to determine a comprehensive IT security maturity and thus without identifying the overall risk situation of a company. 

Management boards and executives must act and react on the basis of incomplete and mostly very technical data, which can only lead to inadequate and incomplete results. The implicit link between cyber risks and business risks is lost when only individual aspects of cyber security are considered. Management decisions made on the basis of this information are usually far from adequate and efficient. 

The only way to solve this problem is to move from tactical to strategic approaches. Recently the term “Cyber Risk Governance” has been coined to describe holistic solutions to this problem, covering organization, processes and technologies. More and more companies and organizations are realizing that cyber risk governance is a challenge that needs to be addressed at management level. Cyber security and regulatory compliance are strong drivers for rethinking and redesigning a mature approach to improve cyber resilience.  

This requires an adequate strategic approach instead of tactical, more or less unplanned ad hoc measures. A strong risk governance organisation, a strategic framework for a comprehensive cyber risk governance process and related technological components must underpin it. This can only be achieved by bundling corporate expertise, taking a holistic view of the overall risk situation and understanding the sum of all risk mitigation measures implemented. 

If the situation described above sounds familiar, read more about “Cyber Risk Governance” as a strategic architecture and management topic in the free KuppingerCole "White Paper: TechDemocracy: Moving towards a holistic Cyber Risk Governance approach". 

Keep Calm and Carry on Implementing

The trouble with hypes is that they have an expiration date. From that date on they either need to be made real for some very good purposes within a reasonable timeframe, or they go bad. There have been quite a few hype topics around recently. But there have not been many single topics that have been covered by media at a frequency and from many different angles and with as many different focal areas as the Blockchain (or distributed ledgers in general). And most probably none of those articles failed to include the adjective "disruptive".

There have been books, conferences, articles, reference implementations, hackathons, webinars and lots more indicators proving that the blockchain is somehow the prototype of a hype topic.

But apart from the bitcoin currency as one regularly cited (and initial) usage of this technology, there have not been too many clearly visible use cases of the blockchain for the everyday user. Actually, it could be doubted that even bitcoin really is something for the everyday user. Other than every now and then needing one of those for paying ransom to get your encrypted files back...

Many great ideas have been developed and implemented in PoC (Proof of Concept) scenarios, but the truth is that the technology still is not very visible in general (which is quite normal for infrastructure concepts) and that there are no commonly known outstanding blockchain use cases in the wild, at least any that everybody knows. The main challenge is the identification of an adequate use case that can be implemented with blockchain technology and that is immediately offering benefits for the end user and the provider of the service.

This might change with the announcements a major insurance company, namely Axa, has made recently. The geeky name "fizzy" stands for an Ethereum-based implementation of a modern insurance concept that allows user-travelers to be covered by an "automatic" insurance policy, in case of a booked (and insured) flight being delayed for more than two hours. Blockchain technology provides adequate security. Automation, smart contracts and parameterization make it adaptable and available.

By doing this, “fizzy” provides smart, real-life benefit while leveraging the advantages of the blockchain technology. This is exactly what we should expect manifestations of this technology to look like. Instead of aiming at disrupting complete business models, organizations across industries should look into implementing smart and adequate solutions that provide real benefit to the end-user. Until this has proven successful at a convincing scale we might want to postpone the task of "reinventing and disrupting complete industries" into the next project phase.

Finally: Building up Trust as a Foundation for Sustainable Business Strategies

It seems almost ironical, but the currently and constantly growing number of legal and regulatory requirements might be the important (and first actually working) catalyst for changing the attitude of organizations towards privacy. While the true rationale behind it are most probably the substantial fines that come with several of these regulations, first and foremost the GDPR.

The value of customer data, from basic account data to detailed behavioural profiles is undisputed. And whether information is really the new oil in the digitalized economy or if comparisons are misleading anyway: Customer identity and access management (CIAM) is already a core discipline for almost any organization and will be even more so.

Changing the attitude towards consumer and employee privacy does not necessarily mean that all those promising new business models building upon data analytics are prevented by design. But it surely means that all the data can be used for these extended purposes if and only if the data subject (consumer, employee, social user, prospective customer, etc.) gives permission. This user consent is something that will need to be more and more deserved by companies relying on user data.

The problem with trust is that it needs to be strategically grown over long periods of time, but as it is highly fragile it can be destroyed within a very short period of time. This might be through a data breach, which surely is one worst case scenario. But the mere assumption, maybe just a gut feeling or even hearsay that data might be reused or transferred inappropriately or inspected by (foreign) state authorities can immediately destroy trust and make users turn away and turn towards a competitor.

The real question is why many organizationa have not yet started actively building this trusted relationship with their users/customers/consumers/employees. The awareness is rising, so that security and privacy are moving increasingly into the focus of not only tech-savvy users, but also that of everyday customers.

Building up trust truly must be the foundation of any business strategy. Designing businesses to be privacy-aware from ground up is the first and only starting point. This involves both well-thought business processes and appropriate technologies. Trustworthy storage and processing of personal data needs to be well-designed and well-executed and adequate evidence needs to be presented to many stakeholders including the individual Data Processing Authorities and the users themselves.

Being more trusted and more trustworthy than your competitors will be a key differentiator for many customer decisions today and in the future. And trusting users will be more readily willing to share relevant business information with an organization as a data steward. But this must be based on well-executed consent management lifecycles, especially when it turns out to be to the benefit of all involved parties.

KuppingerCole will embark on the Customer Identity World Tour 2017 with 3 major events in Seattle, Paris and Singapore. Trusted and privacy-aware management of customer data will be a main topic for all events. If you want to see your organization as a leader in customer trust, you might want to benefit from the thought leadership and best practices presented there, so join the discussion.

Beyond Simplistic: Achieving Compliance Through Standards and Interoperability

"There is always an easy solution to every problem - neat, plausible, and wrong.
 (
H.L. Mencken)

Finally, it's beginning: GDPR gains more and more visibility.

Do you also get more and more GDPR-related marketing communication from IAM and security vendors, consulting firms and, ehm, analyst companies? They all offer some pieces of advice for starting your individual GDPR project/program/initiative. And of course, they want you to register your personal data (Name, company, position, the size of a company, country, phone, mail etc...) for sending that ultimate info package over to you. And obviously, they want to acquire new customers and provide you and all the others with marketing material.

It usually turns out that the content of these packages is OK, but not really overwhelming.  A summary of the main requirements of the GDPR. Plus, in the best cases, some templates that can be helpful, if you can find them between the marketing material included in the "GDPR resource kit". But the true irony lies in the fact that according to the GDPR it is not allowed to offer a service that has a mandatory consent on data that is not needed for the service being offered (remember?… Name, company, position, the size of a company, country, phone, mail etc...).

The truth is, that GDPR compliance does not come easily and the promise of a shortcut and an easy shortcut via any GDPR readiness kit won't work out. Instead, newly designed but also already implemented processes of how personal and sensitive data is stored and processed, will have to be subject to profound changes.

Don't get me wrong: Having a template for a data protection impact analysis, a prescanned template for breach notification, a decision tree for deciding whether you need a DPO or not, and some training material for your staff are all surely important. But they are only a small part of the actual solution.

So in the meantime, while others promise to give you simple solutions, the Kantara Initiative is working on various aspects for providing processes and standards for adequate and especially GDPR-compliant management of Personally Identifiable Information. These initiatives include UMA (User-Managed Access), Consent and Information Sharing, OTTO (Open Trust Taxonomy for Federation Operators) and IRM (Identity Relationship Management).

Apart from several other objectives and goals, one main task is to be well-prepared for the requirements of GDPR (and e.g. eIDAS). The UMA standards is now reaching a mature 2.0 status. Just a few days ago two closely interrelated documents have been made available for public review, that makes the cross-application implementation of access based on provided consent possible. "UMA 2.0 Grant for OAuth 2.0 Authorization" enables asynchronous party-to-party authorization (between requesting party = client and resource owner) based on rules and policies. "Federated Authorization for User-Managed Access (UMA) 2.0" on the server side defines and implements authorization methods that are interoperating between various trust domains. This, in turn, allows the resource owner to define her/his rules and policies for access to protected resource in one single place.

These methods and technologies serve two major aspects: They enable the resource owner (you and me) to securely and conveniently define consent and implement and ensure it through technology. And it enables requesting partners (companies, governments, and people, again you and me) to have reliable and well-defined access in highly distributed environments.

So, they need to be verified if they can be adequate methods to getting to GDPR compliance and far beyond: By empowering the individual, enabling compliant business models, providing shared infrastructure and by designing means for implementing reliable und user-centric technologies. Following these principles can help achieving compliance. "Beyond" means: Take the opportunity of becoming and being a trusted and respected business partner that is known for proactively valuing customer privacy and security. Which is for sure much better than only preparing for the first/next data breach.

This surely is not an easy approach, but it goes to the core of the actual challenge. Suggested procedures, standards, guidelines and first implementations are available. They are provided to support organizations in moving towards security and privacy from the ground up. The UMA specifications including the ones described above are important building blocks for those who want to go beyond the simple (and insufficient) toolkit approach.

GDPR and Customer Data - Eyes on the Stars and Feet on the Ground

Big data analytics is getting more and more powerful and affordable at the same time. Probably the most important data within any organisation is knowledge of and insight into its customer's profiles. Many specialized vendors target these organisations. And it is obvious: The identification of customers across devices and accounts, a deep insight into their behaviour and the creation of rich customer profiles comes with many promises. The adjustment, improvement and refinement of existing product and service offerings, while designing new products as customer demand changes, are surely some of those promises.

Dealing with sensitive data is a challenge for any organisation. Dealing with personally identifiable information (PII) of employees or customers is even more challenging.

Recently I have been in touch with several representatives of organisations and industry associations who presented their view on how they plan to handle PII in the future. The potentials of leveraging customer identity information today are clearly understood. A hot topic is of course the GDPR, the general data protection regulation as issued by the European Union. While many organisations aim at being compliant from day one (= May 25, 2018) onward, it is quite striking that there are still organisations around, which don't consider that as being important. Some consider their pre-GDPR data protection with a few amendments as sufficient and subsequently don't have a strategy for implementing adequate measures to achieve GDPR-compliant processes.

To repeat just a few key requirements: Data subject (= customer, employee) rights include timely and complete information about personal data being stored and processed. This includes also a justification for doing this rightfully. Processes for consent management and reliable mechanisms for implementing the right to be forgotten (deletion of PII, in case it is no longer required) need to be integrated into new and existing systems.

It is true: In Europe and especially in Germany data protection legislation and regulations have always been challenging already. But with the upcoming GDPR things are changing dramatically. And they are also changing for organisations outside the EU in case they are processing data of European citizens.

National legislation will fill in details for some aspects deliberately left open within the GDPR. Right now this seems to weaken or “verschlimmbessern” (improve to the worse, as we say in German) several practical aspects of it throughout the EU member states. Quite some political lobbying is currently going on. Criticism grows e.g. over the German plans. Nevertheless, at its core, the GDPR is a regulation, that will apply directly to all European member states (and quite logically also beyond). It will apply to personal data of EU citizens and the data being processed by organisations within the EU.

Some organisations fear that compliance to GDPR is a major drawback in comparison to organisations, e.g. in the US which deal with PII with presumably lesser restrictions. But this is not necessarily true and it is changing as well, as this example shows: The collection of viewing user data, through software installed on 11 million "smart" consumer TVs without their owner's consent or even their information, led to a payment of $2.2 million by the manufacturer of these devices to the (American!) Federal Trade Commission.

Personal data (and the term is defined very broadly in the GDPR) is processed in many places, e.g. in IoT devices or in the smart home, in mobile phones, in cloud services or connected desktop applications. Getting to privacy by design and security by design as core principles should be considered as a prerequisite for building future-proof systems managing PII. User consent for the purposes of personal data usage while managing and documenting proof of consent are major elements for such systems.

GDPR and data protection do not mean the end to Customer Identity Management. On the contrary rather, GDPR needs to be understood as an opportunity to build trusted relationships with consumers. The benefits and promises as described above can still be achieved, but they come at quite a price and substantial effort as this must be well-executed (=compliant). But this is the real business opportunity as well.

Being a leader, a forerunner and the number one in identifying business opportunities, in implementing new business models and in occupying new market segments is surely something worth striving for. But being the first to fail visibly and obviously in implementing adequate measures for e.g. maintaining the newly defined data subject rights should be consider as something that needs be avoided.

KuppingerCole will cover this topic extensively in the next months with webinars and seminars. And one year before coming into effect the GDPR will be a major focus at the upcoming EIC2017 in May in Munich as well.

KYC is a must, not only for compliance reasons, but what about KYE?

Providing a corporate IT infrastructure is a strategic challenge. Delivering all services needed and fulfilling all requirements raised by all stakeholders for sure is one side of the medal. Understanding which services customers and all users in general are using and what they are doing within the organisation’s infrastructure, no matter whether it is on premises, hybrid or in the cloud, is for sure an important requirement. And it is more and more built into the process framework within customer facing organisations.

The main drivers behind this are typically business oriented aspects, like customer relationship management (CRM) processes for the digital business and, increasingly, compliance purposes. So we see many organisations currently learning much about their customers and site visitors, their detailed behaviour and their individual needs. They do this to improve their products, their service offerings and their overall efficiency which is of course directly business driven.  Understanding your customers comes with the immediate promise of improved business and increased current and future revenue.

But the other side of the medal is often ignored: While customers and consumers are typically kept within clearly defined network areas and online business processes, there are other or additional areas within your corporate network (on-premises and distributed) where different types of users are often acting much more freely and much less monitored. 

Surprisingly enough there is a growing number of organisations which know more about their customers than about their employees.  But this is destined to prove as short-sighted: Maintaining compliance to legal and regulatory requirements is only possible when all-embracing and robust processes for the management and control of access to corporate resources by employees, partners and external workforce are established as well. Preventing, detecting and responding to threats from inside and outside attackers alike is a constant technological and organisational challenge.

So, do you really know your employees? Most organisations stop when they have recertification campaigns scheduled and some basic SoD (Segregation of Duties) rules are implemented. But that does not really help, when e.g. a privileged user with rightfully assigned, critical access abuses that access for illegitimate purposes or a business user account has been hacked.

KYE (Know your Employee - although this acronym might still require some more general use) needs to go far beyond traditional access governance.  Identifying undesirable behaviour and ideally preventing it as it happens requires technologies and processes that are able to review current events and activities within the enterprise network. Unexpected changes in user behaviour and modified access patterns are indicators of either inappropriate behaviour of insiders or that of intruders within the corporate network.  

Adequate technologies are on their way into the organisations although it has to be  admitted that “User Activity Monitoring” is a downright inadequate name for such an essential security mechanism. Other than it suggests, it is not meant to implement a fully comprehensive, corporate-wide, personalized user surveillance layer. Every solution that aims at identifying undesirable behaviour in real-time needs to satisfy the high standards of requirements as imposed by many accepted laws and standards, including data protection regulations, labour law and the general respect for user privacy.

Nevertheless, the deployment of such a solution is possible and often necessary. To achieve this, such a solution needs to be strategically well-designed from the technical, the legal and an organisational point of view. All relevant stakeholders from business to IT and from legal department to the workers’ council need to be involved from day one of such a project. A typical approach means that all users are pseudonymized and all information is processed on basis of Information that cannot be traced back to actual user IDs. Outlier behaviour and inadequate changes in access patterns can be identified with looking at an individual user.  The outbreak of a malware infection or a privileged account being taken over can usually be identified without looking at the individual user.  And in the rare case of the de-pseudonymization of a user being required, there have to be adequate processes in place. This might include the four eyes principle for actual de-cloaking and the involvement of the legal department, the workers’ council and/or a lawyer.

Targeted access analytics algorithms can nowadays assist in the identification of security issues. Thus they can help organisations in getting to know their employees, especially their privileged business users and administrators. By correlating this information with other data sources, for example threat intelligence data and real-time security intelligence (RTSI) this might act as the basis for the identification of Advanced Persistent Threats (APT) traversing a corporate network infrastructure from the perimeter through the use of account information and the actual access to applications.

KYE will be getting as important as KYC but for different reasons. Both rely on intelligent analytics algorithms and a clever design of infrastructure, technology and processes.  They both transform big data technology, automation and a well-executed approach towards business and security into essential solutions for sustainability, improved business processes and adequate compliance.  We expect that organisations leveraging existing information and modern technology by operationalising both for constant improvement of security and the core business can draw substantial competitive advantages from that.

GDPR and the post-Brexit UK

The Brexit-Leave-Vote will have substantial influences on the economy inside and outside of the UK. But the impact will be even higher on UK-based, but also on EU-based and even non-EU based organisations, potentially posing a major threat when it comes to various aspects of business. Especially seen from the aspects of data protection, security and privacy, the future of the data protection legislation within the UK will be of great interest.

When asked for his professional view as a lawyer, our fellow analyst Dr. Karsten Kinast replied with the following statement:

"On the 23rd June, UK carried out a referendum to vote about UK´s EU membership. About 52% of the participants voted for leaving the EU. The process of withdrawal from the EU will have to be done according to Art. 50 of the Treaty on the European Union and will take about two years until the process is completed.

The withdrawal of the UK´s membership will also have an impact on data protection rules. First of all, the GDPR will enter into force on the 25th May 2018, so that by this time, the UK will still be in process to leave the EU. This means that UK businesses will have to prepare and be compliant with the GDPR.

Additionally, if UK businesses trade in the EU, a similar framework to that of the GDPR will be required in order to carry out data transfers within the EU member states. The British DPA, ICO, published a statement regarding the existing data protection framework in the UK. According to ICO, 'if the UK wants to trade with the Single Market on equal terms we would have to prove adequacy – in other words UK data protection standards would have to be equivalent to the EU´s General Data Protection Regulation framework starting in 2018'.

Currently, the GDPR is the reference in terms of data protection and organizations will have to prepare to be compliant and, even if the GDPR is not applicable to UK, a similar framework should be in place by the time the GDPR enters into force."

So it is adequate to distinguish between the phase before the UK actually leaving the EU and the time afterwards. In the former phase, starting right now EU legislation will still apply, so in the short term organisations might be probably well advised to follow all steps required to be compliant to the GDPR as planned anyway. With the currently surfacing reluctance of the British government to actually initiate the Art. 50 process according to the Lisbon treaty by delaying the leave notification until October, this first phase might even take longer than initially expected. And we will most likely see the UK still being subject to the GDPR as it comes into effect by May 2018 and before the actual exit.

For the phase after the actual exiting process the situation is yet unclear.  What does that mean for organisations doing business in and with the UK as soon as GDPR is in full effect?

  • In case they are UK-based and are only acting locally we expect them to be subject to just the data protection regulations as defined in Britain after the exit process. But any business with the EU will make them subject to the GDPR.
  • In case they are based in the EU they are subject to the GDPR anyway. In that case to have to be compliant to the rigid regulations as laid out in the EU data protection regulation.
  • In case they are based outside of the EU but are doing business with the EU as well, they are again subject to the GDPR.
  • We expect the number of companies outside the EU doing business only with a post-Brexit UK (i.e. not with the EU at all) to be limited or minimal. Those would have to comply with the data protection regulations as defined in Britain after the exit process.

Reliable facts for the post-Brexit era are not yet available. Nevertheless, CEOs and CIOs of commercial organisations have to make well-informed decisions and need to be fully prepared for the results of the decisions. An adequate approach in our opinion can only be a risk-based approach: organisations have to assess the risks they are facing in case of not being compliant to the GDPR within their individual markets. And they have to identify which mitigating measures are required to reduce or eliminate that risk. If there is any advice possible at that early stage, it still remains the same as given in my previous blog post: Organisations have to understand the GDPR as the common denominator for data protection, security and privacy within the EU and outside the EU for the future, starting right now and effective latest by May 2018. Just like Karsten concluded in the quote cited above: To facilitate trading in the common market the UK will have to provide a framework similar to the GDPR and acceptable to the EU.

So any organisation already having embarked on their journey for implementing processes and technologies to maintain compliance to all requirements as defined by the GDPR should strategically continue doing so to maintain an appropriate level of compliance by May 2018 matter whether inside or outside the UK. Organisations who have not yet started preparing for an improved level of security, data protection and privacy (and there are still quite a lot in the UK as well, as recent surveys have concluded) should consider starting to do so today, with the fulfilment of the requirements of the GDPR adapted to the individual business model as their main goal.

We expect stable compliance to the regulations as set forth in the GDPR as a key challenge and an essential requirement for any organisation in the future, no matter whether in the EU, in the UK or outside of Europe. Being a player in a global economy and even more so in the EU single market mandates compliance to the GDPR.

Managing the customer journey

Every one of us, whether a security professional or not, is also a part-time online customer or a subscriber of digital services. Providing personal information to a service organisation, to a social media platform or a retailer is a deliberate act. This will be even more the case with the upcoming GDPR being in full effect soon. Ideally the disclosure of potentially sensitive information should always lead to a win-win-situation with both directly involved parties, the customer and the provider of services benefiting from information provided by the end user.

So organisations need to make sure that managing customer information needs to be performed at an utmost level of diligence to the benefit of both the customer and the organisation. That means that the customer identity is to be put into the centre of all processes. And organisations need to understand that there are more sources available within (and outside of) the organisation, where information about a single customer is available, providing social, behavioural, interest, transactional and much more data, including historical data. Combining and consolidating this data into a single unified customer profile while maintaining scalability, security and compliance is most probably one of the essential challenges organisations will have to solve in the future.

Customers interacting with a service provider or any other internet-facing organisation typically start with eight registration process, either from scratch by creating a new account or by reusing and complementing existing 3rd party account information, e.g. from social logins. From that moment on they are interacting with the system and thus they implicitly provide a constant flow of information through their behaviour. But Customer Identity and Access Management strategically goes far beyond that. Information about a single specific customer might already be available in the enterprise CRM system, providing in-depth insight into former interactions, e.g. with helpdesk. Previous purchases or subscriptions will be documented in their respective systems and more information might be available in the enterprise IAM system (especially when the organisation needs to understand, that a customer is also an employee) or the corporate ERP system.

These types of information and valuable when it comes to understanding customer identity as a whole. The actual task of retrieving and leveraging this information should not be underestimated: in many organisations these different systems are usually run by different teams and different parts of the organisation and this often leads to so-called information silos. Getting to a unified customer profile necessarily requires breaking up the barriers between those organisational and technical silos. Cross-organisational and cross-functional teams are typically required to consolidate the information already available within a single enterprise. Aligning different sources of information and different semantics resulting from different business purposes to get to a meaningful pool of consumer profiles requires expertise from various teams.

After having done their“homework”(by exploiting their already existing knowledge about each customer identity), many organisations are also looking into integrating information available from third parties, which means data sources outside of the organisation. Potential sources are manifold: they range from social media (Facebook, Twitter, Google+ and many others, including regional and special interest social media services) and the reuse of profile data (including likes, recommendations, comments) to sources of commercial marketing data, and from existing sources for Open Data to credit rating organisations.

When it comes to comparing effort and benefit, it becomes obvious, that greedily collecting each and every information available cannot be effective. Identifying the right set of information for the right business purpose is one of the major challenges. Having the right information available for the end user to improve his user experience and for the organisation to support decision-making processes has to be the key objective. Nevertheless, the definition of an adequate set of “right” information is a moving target that needs to be adjusted during the life time of a customer identity and the underlying CIAM system.

However, it must be made sure that the reuse of all the above mentioned information is only possible, when the owner of this data, i.e. the customer, has agreed to this processing of the information for additional purposes. User consent is key, when it comes to recombining and analysing existing information.

GDPR now!

The news is already getting quieter around the GDPR, the general data protection regulation as issued by the European Union. Several weeks ago it has been discussed in detail in many articles, and background information has been provided by many sources, including lawyers and security experts, but in the meantime other topics have taken its place in the news.

But unlike some other topics, the GDPR won't go away by simply ignoring it. It is less than two years from now, that it will reach legally binding status as a formal law for example in Germany. Probably one of the most striking characteristics of the new regulation that is constantly underestimated is the scope of its applicability: It actually applies in all cases where the data controller or the data processor or the data subject is based in the EU. This includes all data processors (e.g. cloud service providers) or data controllers (e.g. retailers, social media, practically any organisation dealing with personally identifiable information) which are outside the EU, especially for example those in the US. They, however, seem to be gaining the lead in taking the right first steps already in comparison with European organisations.

So the GDPR will be a major game changer for a lot of customer facing services. For many organisations changing the processes, the applications and the infrastructure landscape to be compliant with the regulations of the upcoming new requirements as laid out in the GDPR will be a massive challenge.

The following image focuses just on some of the “highlights” of the European General Data Protection Regulation. But apart from this each and every organisation should review the current version of the text which goes far beyond that. It is available on the Internet, e.g here, and detailed and profound commentary is available e.g. here. My fellow analyst Dr. Karsten Kinast provided a great short wrap-up during his keynote at EIC 2016 in Munich earlier this year.


While two years sound like a long period of time actually the opposite is true. The requirements as imposed by the GDPR are at least partially substantially different from existing national data protection regulations. Every organisation has to identify, which steps are required to implement proper measures to comply to these regulations for their own processes and business models. When looking at the amount of time required to implement all changes identified, somewhat less than two years no longer appears to be overly plenty of time.

Unfortunately, especially industry associations appear not to be willing to supply adequate support or advice and often enough end up in commonplace remarks. Instead of providing appropriate guidance often the opposite is done by repeatedly praising Big Data as the basis for next generation business models. While this might nevertheless be true for some organizations, it can only be true when being compliant to the upcoming GDPR in every relevant respect.

Many important decisions will have to be left for court decisions in the end. This might turn out as a difficult challenge with only little practical advice being available as of now. But doing nothing is not an option at all.

Compliance to legal or regulatory requirements is rarely considered as a value in itself, but it is - and will be even more - a sine qua non when it comes to data protection, customer consent and privacy very soon. On the other hand: Assuring a high level of security and consumer privacy ahead of the legal requirements can be a competitive advantage. So if you have not yet started making your organisation and your business ready for the GDPR and its upcoming regulations, today might be a good day to take the first steps. 

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Privacy & the European Data Protection Regulation Learn more

Privacy & the European Data Protection Regulation

The EU GDPR (General Data Protection Regulation), becoming effective May 25, 2018, will have a global impact not only on data privacy, but on the interaction between businesses and their customers and consumers. Organizations must not restrict their GDPR initiatives to technical changes in consent management or PII protection, but need to review how they onboard customers and consumers and how to convince these of giving consent, but also review the amount and purposes of PII they collect. The impact of GDPR on businesses will be far bigger than most currently expect. [...]

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