Data Privacy
This whitepaper outlines a practical, privacy-by-design approach for safeguarding sensitive information across every device and entry point—identity, endpoints, servers, infrastructure, collaboration, mobility, and third parties—without sacrificing productivity.
Principles: Minimize collection, separate duties and keys, encrypt at rest and in transit,
verify with evidence, and expire access quickly. Build controls users can live with.
1) Identity, Access & Directory
Identity is the new perimeter. Govern the full lifecycle and reduce standing privilege.
- MFA everywhere; phishing-resistant methods preferred (FIDO2/WebAuthn).
- Conditional access by risk, geo, device health, and user role.
- JIT/JEA admin with approvals; short-lived credentials and break-glass with hardware tokens.
- Automated provisioning/deprovisioning (HRIS → IdP) with SCIM/Graph.
- PAM for privileged sessions; session recording where lawful and disclosed.
- Strong passwordless or passkeys; disable legacy auth (IMAP/POP/NTLM) where possible.
2) Workstations & Laptops
Harden endpoints to protect data at the point of creation and access.
- Full-disk encryption (BitLocker/FileVault) with escrowed recovery keys; pre-boot auth.
- Remove local admin; just-in-time elevation with audit trails.
- Application allow-listing; exploit protection; host firewall baselines.
- Patch SLAs and automated update rings; rapid vulnerability remediation.
- EDR with privacy-conscious telemetry retention and role-based views.
- Screen lock, idle timeouts, privacy filters for shared/field work.
- Data-at-rest
- Encrypt user profiles and key app data folders; protect hibernation files.
- Data-in-use
- Harden clipboard, print, and screenshot policies for regulated apps.
3) Servers (On-prem & IaaS)
- Disk/volume encryption; secrets in KMS/HSM; rotate service creds.
- Prod vs non-prod segmentation; east-west filtering; admin via jump hosts.
- Baseline configs (CIS), golden images, drift detection, immutable infra where feasible.
- Log minimal necessary fields; tamper-evident storage; time-sync with secure NTP.
4) Network Devices: Firewalls, Routers, Switches
- Mgmt plane: TLS/SSH only, IP allowlists, MFA; disable telnet/HTTP/SNMPv1.
- Versioned backups; signed configs; out-of-band management.
- VLANs/micro-segmentation; ACLs default-deny; DHCP/DNS guard; storm control.
- NetFlow/IPFIX to analytics; DoS rate-limits; automatic config compliance.
5) Wireless & Guest
- 802.1X/EAP-TLS with certificate identity; separate corp/BYOD/guest SSIDs.
- Client isolation; WIDS/WIPS; disable open auth; rotate keys.
- Guest portal with rate limits; DNS and content filtering.
- Coverage planning & privacy zoning for cameras/meeting spaces.
6) Email & Messaging
- Inbound: anti-phish, DMARC/DKIM/SPF, BEC defenses, sandboxing.
- Outbound: DLP policies; label-triggered encryption (TLS/S/MIME/portal).
- Safe links/attachments; legal hold; retention by policy.
- External sharing boundaries; watermarking; recording governance.
7) DNS, Web Filtering & Proxies
- DoH/DoT resolvers with domain risk scoring and block lists.
- Block newly registered/DGA domains; isolate risky browsing.
- TLS inspection with privacy guardrails and user notice where lawful.
- DNS logging with PII minimization and documented retention.
8) Zero-Trust Access & Modern VPN
- Per-app micro-tunnels; device posture checks; short-lived tokens.
- MFA + device cert binding; split tunnel with DNSSEC/DoH.
- Granular logging; session recording for admin flows (with notice).
- Auto-quarantine on posture failure; self-remediation prompts.
9) Mobile & BYOD
- MDM/MAM: Android work profile; iOS user enrollment; app-level policies.
- Prevent copy/paste to unmanaged apps; block unsanctioned cloud saves.
- Per-app VPN; jailbreak/root detection; remote wipe of work data only.
- Minimal telemetry with clear user notices and consent where required.
10) IoT, OT, Printers & Cameras
- Dedicated VLANs; egress allow-lists; deny lateral movement.
- Rotate credentials; sign/verify firmware; disable cloud backdoors.
- Mute mics/cameras by policy; privacy masking where applicable.
- Inventory & SBOM where feasible; retire end-of-support gear.
11) Voice & Collaboration
- SRTP/TLS; role-based access to recordings; retention schedules.
- Meeting classification, lobbies, watermarking, external controls.
- PII-aware transcripts; redact sensitive content when possible.
- Contact center PCI pause/resume; DLP for omnichannel.
12) Databases & Storage (NAS/SAN/Object)
- Transparent encryption; key separation of duties; column masking.
- RBAC/ABAC; no shared admin creds; rotate service accounts.
- Snapshot/backup encryption; immutability (WORM) for archives.
- Query & activity logging with periodic access reviews.
13) Web Apps, APIs & Reverse Proxies
- WAF, bot management, rate limiting, geo controls; mTLS where apt.
- Cookie flags, CSRF defenses, session hardening; no secrets in code.
- Collect minimum necessary data with clear consent & notices.
- API gateways with OAuth2/OIDC, scopes, throttling, auditing.
14) Backups, DR & Recovery
- Immutable backups in separate trust zone; distinct credentials.
- Regular restore tests; documented RTO/RPO; evidence capture.
- PII minimization in logs/backups; selective restores to reduce scope.
- Forensic chain-of-custody and hash verification where needed.
15) Vendors & Third-Party Access
- DPA/BAA where applicable; data mapping & transfer impact assessment.
- SSO + MFA; scoped API keys; IP allowlists; short token TTL; event hooks.
- Evidence of controls (SOC 2/ISO); continuous vendor risk monitoring.
- Automated offboarding revokes accounts, keys, and tunnels immediately.
16) Logging, Monitoring & SIEM
- Data minimization and tokenization/redaction for PII in logs.
- UEBA to detect anomalies; tuned alerts; duty segregation for analysts.
- Retention aligned to policy with immutable tiers and legal hold.
- Runbooks for privacy incidents: contain → notify → eradicate → learn.
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