How to Roll Out an Effective Data Loss Prevention (DLP) Solution

Introduction

It's no surprise that businesses handle vast amounts of sensitive data. Protecting this data from unauthorized access, leaks, or theft is paramount and even small to medium sized businesses are looking to ensure they are implementing multiple guard rails to defend themselves from these types of incidents. Data Loss Prevention (DLP) solutions are crucial for safeguarding your organization's confidential information.

They can help prevent accidental data loss that could result in GDPR fines or reputational damage, but they can also help prevent malicious exfiltration from an insider or an attacker. Vendor selection alone can be a complex task depending on your business needs. That's why I've listed the considerations you need to cover from a business perspective to select the vendor/tool that satisfies those requirements. This guide will then walk you through the detailed steps to roll out that tool effectively once you've selected a vendor.

Vendor Considerations & Business Requirements (understanding the problem)

• How many user licenses are needed? This will give a good indication of costs. (Note that some local legislations consider DLP to be a form of employee monitoring which is prohibited in some countrties).
• Consider the integration process. Does your business primarily use Microsoft Products? If so, consider Microsoft Purview for ease of integration but there may be limited features depending on your business needs.
• Do You know where your data is? If not, that's ok but you may need discovery tool features as part of the roleout process so you can determine where sensitive data is stored that you can apply DLP policies to in order to protect it.
• Consider CASB (Cloud Access Security Broker) solutions for your cloud environment(s).
• What are your businesses strategic goals for DLP and will you need a solution that protects your business from accidental data loss or malicious data loss. Both are achievable but approached very differently in DLP policies, false positive management and end user friction.
• Do you need OCR? (Object Character Recognition) to read screenshots and images in emails and file uploads? This can sometimes require specific licenses, costs or specialized hardware. It can even add latency in some cases.
• Do your timelines for the roll out allow for a 1-3 month period of audit mode (instead of blocking anything right away) to allow time to fully analyse real world data sharing within your business and drive high quality DLP policy creation based off of that behaviour?
• Does your business have an operational team to support the release of blocked emails or guide users through secure file uploads (web DLP) or does the business trust its users enough to make the call and allow them to self release?
• Does your business label data already or is this needed? DLP policy creation is a lot easier when you have guidelines on how the different classifications of data is handled internally.
• Will DLP be a big culture shift? Awareness & Training can help diffuse DLPs importance into company culture. If users are made aware of DLPs value they will be more inclined to let it protect them from themselves.
• Is there someone (or the same operational team mentioned before) that can build and maintain the DLP policies? They’re not just set and forget, a DLP solution needs nourishment if it is to succeed.
• Is it just email DLP that’s needed or does the business need web DLP also? For example, if a user gets blocked emailing confidential data off the network can they just upload it to Dropbox, G-Drive or WeTransfer? Blocking at the web/proxy level can help here.
• Do your third parties and vendors go through a due diligence process that covers data sharing agreements before data is shared with them? If so, how will this list of approved vendors be managed within the DLP tool and how will it be kept up to date? If a contract expires after two years and your DLP solution is still permitting data sharing this would pose a risk. Auditing the approved third parties should be supported to keep your DLP solution efficient.
• Continuous monitoring - This will help with any ISO 27001 audits when asked to produce evidence for control effectiveness monitoring. Your DLP solution needs to be up and running 24/7/365 so consider how you'll test it's working and the frequency of these tests as well as if they will be automated or manual.

DLP Rollout Steps

Step 1: Define Objectives and Scope

Most of these will have been covered by the above but in case you skipped that part here's the crucial objectives. Begin by establishing clear objectives and the scope of your DLP implementation. Determine what sensitive data you need to protect, where it's located, and who should have access to it. Consider regulatory compliance requirements, industry-specific standards, and your organization's unique needs.

Step 2: Identify Key Stakeholders

Engage key stakeholders across your organization, including IT, legal, compliance, HR, and business units. Their input and cooperation are crucial for a successful DLP rollout. The business units list will also make DLP policy building easier as each business unit can be added or excluded from the policies you build. For example you might want Marketing to be able to email anything to personal email addresses for Influencer initiatives but you don't want your Customer Operations team to be able to do this, or maybe you do as long as there's no attachments etc.

Step 3: Vendor Selection

Select a reputable DLP vendor that aligns with your organization's requirements. Consider factors such as scalability, integration capabilities, reporting features, and cost-effectiveness. Ensure that the vendor can support your industry-specific compliance needs as well as your specific needs outlined by the vendor considerations & business reuirements exercise above.

Step 4: Conduct a Data Inventory

Catalog all sensitive data within your organization. Identify where it's stored, who has access, and how it's currently protected (if at all). This inventory will serve as the foundation for your DLP policies.

Step 5: Develop DLP Policies

Create clear and comprehensive DLP policies that define how sensitive data should be handled, stored, and transmitted. Policies should address various scenarios, including data at rest, in transit, and in use. Ensure that policies are aligned with your organization's data handling policies, risk tolerance and compliance requirements. This can be overwhelming at first, so try to break it down into the highest classification of data and how to protect that. A good rule of thumb is the highest classification of data must always be encrypted and only sent to approved vendors if it must be sent off network.

Step 6: Classify Data

Categorize your sensitive data into different levels based on its importance and sensitivity. This classification will help you enforce policies effectively and prioritize incident response. Another tip is to set thresholds for unencrypted data like credit card numbers = 1 or more should block but maybe full names and dates of birth you want to only look at 10 or more (depending on your risk appetite).

Step 7: Implement The DLP Solution

Deploy DLP solutions across your organization's network, endpoints, and cloud services. Configure the DLP system to monitor and enforce your policies consistently. Refer to your strategy on if you need to set it to audit mode for a few months which will make the deployment a lot smoother or if you want to block immediately after the endpoint has the solution enabled. (this approach will need comms to users for awareness on what the tool is, why it's needed and where they can go for support in case of false positives).

Step 8: Fine-Tune DLP Rules

Continuously monitor and fine-tune DLP rules to reduce false positives and adapt to changing threats. Regularly review policy effectiveness and update them as needed. This is the nourishment I referred to earlier that is often overlooked. A stale DLP solution can cause a huge impact on growing business. New third parties need to be added to approved lists, old ones might need to be removed. New SAAS tooling might need file uploads permitted to specific URLs and new policies, rules or exceptions will be needed as the business changes.

Step 9: Employee Training and Awareness

Educate your employees about DLP policies, best practices, and the importance of safeguarding sensitive data. Conduct regular awareness training sessions to keep security top of mind. This is very important to cover in inductions but just as important to include in annual training to keep it fresh in employee minds when handling data.

Step 10: Monitor and Analyze

Implement robust monitoring and reporting tools to track data movement and policy violations. Set up alerts for suspicious activities and conduct regular audits to assess DLP effectiveness.

Step 11: Incident Response Plan

Develop a detailed incident response plan to address DLP violations swiftly and effectively. Ensure that your response plan complies with legal and regulatory requirements. Consider if you want to block the data until the user requests support or if you'd rather users approach the operations team when they need support and by reaching out they are then confirming it wasn't just an accident and they are trying to complete a task.

Step 12: Compliance and Reporting

Use your DLP solution to generate compliance reports required by regulators and internal stakeholders. Maintain detailed records of incidents and responses for auditing purposes.

Step 13: Continuous Improvement

Regularly review and improve your DLP program. Stay updated with emerging threats and adjust your policies and technology accordingly. Use the reporting capabilities to drive change in the repeat offender teams but make it educational or even try to gamify it (your Data Protection team will thank you for that).

Step 14: Compliance Audits

I touched on this briefly earlier when it comes to ISO 27001 but this is also relevant for SOX compliance too. Periodically assess your DLP program's effectiveness through internal and external audits. Address any identified deficiencies promptly. Automate any testing and create alerts for instances where the tests fail.

Step 15: Documentation

Maintain thorough documentation of your DLP program, including policies, configurations, incident reports, and audit records. This documentation is essential for compliance and future reference as well as any new joiners in the team that will be supporting DLP.

Conclusion

Implementing an effective Data Loss Prevention solution is a complex undertaking but it protects your data and business reputation, contributes to compliance requirements and improves business reputation by showing maturity in cyber security posture. Remember that DLP is an ongoing process that requires constant monitoring, adjustment, and improvement to stay effective.

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