For all those who wish to use EBIOS Risk Manager to conduct a PIA (Privacy Impact Assessment, commonly, or Data Protection Impact Assessment – DPIA, in the specific context of the Article 35 of GDPR), here is an infographic which summarizes the approach:
Broadly speaking, information security / cybersecurity and privacy are both about data protection.
The goal is different: in the information security field, the goal is to protect the organization, while in privacy, the goal is to protect individuals / data subjects.
But the way to manage risk is perfectly compatible!
To conduct a PIA with EBIOS Risk Manager, all you have to do is:
All the information required in a PIA is all found in the study:
The following document can be used for determining the baseline of the Workshop 1 of EBIOS Risk Manager, when the scope of the study is a processing of personal data:
It constitutes a declaration of applicability relating to the fundamental principles related to the protection of privacy.
The other Workshops of the study makes it possible to satisfy the obligations of the GDPR in terms of security (cf. art. 32) if you assess the impacts on the data subjects in addition to those on the organization.
You can thus use EBIOS Risk Manager to carry out a PIA (cf. art. 35).
Answer from a Club EBIOS member: “Pay attention to scales using several types of impacts”
EBIOS guide reminder: “This action [scale development] consists of creating a scale describing all possible levels of impacts, just like the scales of needs, a scale of impact levels is usually ordinal (the objects are classified in order of magnitude, the numbers indicate ranks and not quantities) and composed of several levels to classify all risks“.Therefore, it is usual to see users of the method build several ordinal scales depending on the nature of the impact (financial, legal, operations, privacy…) to estimate the severity of the feared events. The construction is then done by individually scaling each type of impact, without worrying about the consistency between the levels.
However, only a global result is used in risk maps to assess the severity of each compared to the others. Information on the nature of the impacts is lost.
To avoid misleading conclusions about the importance of risks, care must be taken to check the transverse coherence of the gradation of impacts in the scales. For example, checking that the estimatation of a level 3 impact on operations will be of the same value for the organization as the financial and legal impacts of the same level.
Where possible, the pivotal criterion (for consistency) may be the financial scale. If this is not the case (often the case), the side-by-side impacts should be presented and their importance assessed by those seeking consensus. In this case, the scales can have empty boxes (level having no equivalence for all types of impacts considered). This can be the case when one estimates the loss of human lives for example.
It is sometimes difficult for managers to establish these scales in a generic way. A good solution is then to ask the stakeholders to prioritize the feared events after identifying the impacts, and build the scales based on this estimate.
Answer from another member: “It is useful to have heterogeneous impact scales, it is an important means of communication with the business”
In addition, the ideal is in my opinion:
This makes it easy to carry out a study of both information security and privacy by presenting side-by-side the impacts to the organization and the impacts to the individuals (data subjects).
Answer from a Club EBIOS member: “Two options”
Several proposals are possible to demonstrate that the problems associated with traceability are treated in an EBIOS study without considering traceability as a criterion:
Another answer’s response: “Traceability is not a security criterion”
The security criteria are used to assess the impacts in case of reaching each of them, and in particular to study the security needs. In information security, only availability, integrity and confidentiality are considered as security criteria (see in particular ISO/IEC 2700x).They should not be confused with the topics of security measures or regulatory references. Indeed, the (false) need for traceability comes from the fact that we want to know what happened after an incident (detection measure) and/or various obligations (legal, regulatory, sectoral or security policy-related). It is therefore useless and even counterproductive to study the need for traceability.
In addition, a scale of needs and a scale of impacts related to traceability should be available. It is often by trying to build them that one realizes that it is a “desire of someone” that falls under security measures or coverage of a legal “risk”.
Finally, this would involve studying all the threats that lead to the loss of traceability! Actually, this is related to the good implementation of a security measure, which is not necessary to treat as a risk (or otherwise it should be done for encryption, access control, etc.).
However, as the study of the needs is a communication tool with business, it is possible to integrate traceability into the security criteria so that business becomes more involved in the process by seeing its point of view taken into account…
Answer from a Club EBIOS member: “We can act on several elements so that the result corresponds to the expectations”
Studies are sometimes criticized because of the combinatorial explosion of the elements to be studied. Therefore, before or at the beginning of any study, it is necessary to wonder what the sponsor is able to accept in terms of readability.Some wish to have as much detail as necessary to treat the risks (and/or justify the measures) in a fine way.
In this case, it is possible to handle the entire combination of events and threat scenarios.
If this is not the case, here are some tips that will help you reduce the entropy of the analysis:
Lean management is trendy. This also concerns risk management, in particular in France, with the recent publication of the EBIOS Risk Manager method by the French National Agency for Cybersecurity (ANSSI).
However, if the new method fosters an agile approach of risk management, it does not provide the tools to support the mandated brainstorming workshops.
Here, through the EBIOS College of Practitioners, we propose an innovative set of posters that can be used:
The posters come with a complete user guide to help exploit the posters to the best of their potential. Le guide provides numerous tips based on Thales return-on-experience using these posters. In addition, a complete risk assessment example is provided. The example relates to the naval domain, and more precisely, to the securing of a passenger ferryboat. The example is a representative of the type of (very short but complete) report that can be generated using the approach.
By using these posters on a Thales internal cybersecurity course in 2018, and on two real business case studies in 2019, we have developed the optimal number of posters and fine-tuned the content of each poster, bringing them to a level of maturity that is compliant with operational business cases. Since 2020, the posters were also used on three remote risk assessments within a European project, including the one provided as example.
We have noticed during those case-studies that risk management using this technique is fun. It is a way of demystifying risk management, making it easier to understand, whilst remaining highly time-efficient.
This format is especially appropriate during bid activities, or project kick-off. It also fosters a collaborative state of mind, recalling that system architecture securing is not the sole business of cybersecurity experts, but the result of a collaborative work involving the management, domain experts, the CISO and CIO.
Obérisk, an Obeya-like Risk Management Approach by Stéphane Paul of Thales Research & Technology (Critical Embedded Systems Laboratory) is made available in the form of PowerPoint slides under the CC BY-NC-SA (i.e. Creative Commons Attribution + Non Commercial + Share Alike) licence. Obérisk includes a set of posters, a user guide and a full-blown example.
This guide is the EBIOS* generic approach. It provides a common base to any sector-specific breakdown. Initially designed for information security, EBIOS can be employed in all fields using the appropriate techniques and knowledge bases.
EBIOS allows us to assess and treat risks. It also supplies all the information required for communication within the organization and with its partners, and for validation of the way risks have been treated. It thus constitutes a complete risk management tool.
This is a real toolbox, from which we choose the actions to be implemented and the method of using them according to the objective of the study. It allows us to assess the risks using scenarios and to develop a coherent policy from them, based on concrete and assessable controls.
This case study aims at showing how to use the EBIOS toolbox in the privacy specific sector:
In a risk study, analyzed impacts highly rely on each stakeholder’s point of view. Starting from this understanding, this document push to take into account each actor considerations, in a “by design” logic, so that the product, system or service is accepted by everyone.
This document aims at providing useful elements to manage the risks related to the use of BYOD (Bring Your Own Device):
This study aims at showing how to use the EBIOS toolbos in the privacy specific sector:
This flyer summerizes the essential issues raised by the case study:
This document presents sectors in which tisk management plays a major role in order to enlight similarities and dissimilarities. Risk management is not only for information technology but concerns a growing amount of sectors that think about their survival and expansion strategies.
This memento provides with the concepts related to business continuity and their position in information security. Then, specific activities for business continuity are presented in 4 iterative steps. The referential, the organization and the associated tools are finally studied.