We have been discussing IRM, DRM, DLP and other acronyms back and forth for a quite a while now and I am sure there are a good bunch of solutions out there for those organizations, that have policies and procedures in place to sufficiently plan, build and run thus a tool. Thus, I was pretty much „meh“ about any discussions revolving around the pros and cons of approaches… Well, our close friends sometimes surprise us with problems, we never seem to have „seen“ before. One of those friends runs a small System Integrator / VAR company and approached me with a problem, that is common among these service providers: handling of RMAs… Usually, if you have outsourcing agreements and service contracts, you would also have a number of SLAs that cover the use, transport, protection and security of data and mobile data storage devices such as flash-disks, thumb-drives or the very useful external hard drives, which are used to back-up full Virtual Servers if no SAN/NAS is available on-site. Well, these SLAs cover exactly that: the STANDARD operating procedures and day-to-day handling of those devices. But what happens, if one or more of the external hard-drives becomes defective and is not accessible because the controller is broken? You just had a full back-up pushed onto that drive last Friday and – during your standard tests of back-up media – you find the disk to irresponsive due to controller failure. You KNOW that your client's full data-center including Domain Controller, Exchange and ERP systems are on that drive. You are unable to read the data, you can also not delete the drive and you cannot “open” the casing because it voids the warranty under which you would like to get the drive replaced by your vendor/distributor. Actually, you would have to send in the defective drive as-is (with all your client-data on it) and wait to have it replaced or repaired. If replaced – what happens to the “raw disks”? They could easily be put into a computer or hooked up to another controller and data extracted. If repaired, the controller will be exchanged and at least QA tests will reveal the sensitive nature of the data stored… According to the System Integrator community it is impossible to negotiate a special data-protection agreement with the Distributors, as their margins are already too low to invest in legal advisory regarding a set of 150 € products. Also, the clients are rather unwilling to sign a waiver, which reduces or fully removes liability for any data breach from the SI. I would really LOVE to talk to some lawyers of the HD manufacturers and/or Distributors about this topic, as I fear that a large number of these RMAs happen without any thought about data protection…
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