Life after GDPR: Implications for Cybersecurity

Published: 2018-01-23
Last Updated: 2018-01-23 21:16:25 UTC
by John Bambenek (Version: 1)
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It’s not much discussed in the United States, but the EU’s landmark General Data Privacy Regulation will soon become the law that governs how data must be protected, stored, and processed for European citizens. This, of course, has great effect for those organizations doing business in Europe but it has had and will have a myriad of side-effects that we’ll be dealing with for years to come. This is especially true for cybersecurity professionals and those who investigate crime on the internet.

For almost 2 years, debate has gone on at an ICANN working group on the future of Whois, the protocol that allows anyone to see registrant information for any domain on the internet (unless otherwise protected). Whois has been under fire from time to time by privacy activists and data protection authorities and now that conflict has reached a boiling point over GDPR. On the one hand, in a subset of cases personal information (unless you buy privacy protection) is published with phone numbers, emails, and mailing addresses. On the other hand, security investigators, researchers, and data scientists use this data in a variety of ways to find malicious domains and protect their constituents.

The debate at times has been heated with a registrar infamously calling anti-spam groups “blackhats” but after spending months in this group, it’s pretty clear that free and meaningful access to full whois data is going away. So the question becomes, now what? And what does this mean for other forms of data useful for threat research?

Whois, and certainly the commercial services built on top of that data, are useful for correlating malicious activity. During the French Presidential campaign (and the upcoming midterm elections in the United States), it is possible to find other domains with the same registrant details to identify multiple resources used by the adversary. It makes it possible to identify if domains are owned by who they purport to be, or provide essential contact information to resolve problems.

One of the problems I have, from time to time, is how to contact victims when I see their resources are compromised as often they won’t list data on their website. Whois data can, of course, be wrong… but even in those situations it is useful.

Luckily, for the broader class of threat data, it seems others are taking a more nuanced approach. This guide from the MISP Project talks about the implications in detail and points out recital 49 of GDPR encourages these kinds of sharing arrangements to continue.

If Whois does go away, how will it impact your organization and what plans do you have to accommodate those needs if it does?

John Bambenek
bambenek \at\ gmail /dot/ com
Fidelis Cybersecurity

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