Friday, August 15, 2008

A Few More Words on DLP and Compliance

Today I was thinking about DLP again :-) (yes, I know that "content monitoring and protection" - CMF - is a better description) Specifically, I was thinking about DLP and compliance. At first, it was truly amazing to me that DLP vendors "under-utilize" compliance in their messaging. In other words, they don't push the "C-word" as strongly as many other security companies. Compliance dog doesn't snarl at you from their front pages and it doesn't bite you in you ass when you read the whitepapers, etc. Sure, it is mentioned there, but, seemingly, as an after-thought.

For example, Reconnex that was recently absorbed by McAfee, touts "information protection" before compliance. Similarly, my friends from nexTier only mention "compliance" on a few pages. Even newly unveiled DLP resource  (DLP In-Depth portal) only contains a little bit  of information on how DLP solutions help with various compliance projects. People tout "data protection", " data security", "data governance" (aka "we know big words - bigger than you") or even "data risk management" (aka "we are confused about what we sell")

I decide to explore this curious phenomenon.

Initially, I thought that it was reverse compliance at work? People not wanting to know what content packs up and leaves their network. Then I thought that maybe DLP vendors just aren't "the bandwagon jumping kind" (yeah, right!) Then I thought that they are "beyond compliance" already :-)

But you know what? I actually think that it is something different, much more sinister. It is the ominous checklist mentality (here too)!  You know, DLP is newer than  most regulations (PCI DSS, HIPAA, FISMA, etc) and - what a shock! - the documentation for these mandates just doesn't mention DLP (or CMF) by name. Sure, they talk about data protection (e.g. PCI DSS Requirements 3 and 4), but mostly in terms of encryption, access control, logging (of course!).

Also, PCI DSS directly and explicitly says "get a firewall", "deploy log management", "get scanned", "install and update AV" - but where is DLP? Ain't there...

Yes, Virginia, folks who "go by the book" and just "do the minimum" are missing out on the chance to procure DLP while their compliance budgets are still flowing. To me that means that many still don't get the "compliance+" model - buy for compliance -> use for security, operations, having fun, etc. Think what a good DLP solution  will do for you in discovering regulated data across the entire organization, blocking those pesky email with SSNs, PHI (hi, HIPAA) and CCs (hi, PCI) as well as solving plenty of other problems ...

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Dr Anton Chuvakin