Compliance corner comprises a series of issues that have arisen in the
context of projects meeting technical standards. This page covers:
It is noted in the Technical Standards and Guidelines on security
that your project should be managed in accordance with the Information Security
Management guidelines laid out in BS7799: Part 1.We recognise that compliance
with BS 7799 part 1 is by no means a trivial undertaking and may in many instances
be inappropriate to the security needs of your website. However it is nonetheless
important that your site complies with certain minimum recommendations. Becta
"Although compliance with BS 7799 part 1 is not a "Must" requirement, projects
"must" adhere to the following:
- The machines used to deliver projects must be operated in as secure
a manner as possible
- The advice in operating system manuals concerning security must be
- All known security patches must be applied
If a project is not aiming for BS7799 part 1 compliance, they
should return in either their Section A or Section B report details of the security
arrangements that they will be implementing. These arrangements will need to
provide reassurance that the site is being delivered in as secure manner as
possible - for instance the project should:
- ensure arrangements are in place for the timely application of any security
- confirm that the server(s) and any associated computers have been correctly
configured to provide the optimum level of security
- confirm that a schedule of timely data backups is in place
- confirm its network is protected by a firewall with all unnecessary ports
- describe the physical security of the project's server(s)
- provide details of the people in the organisation who have administrator
rights to its machines
Part of the process of achieving compliance with regard to security is the
careful documentation of both the security measures you have set up and the
ongoing process of maintaining those security measures. For example, with regard
to security patches, it is important to keep a watch on announcements of new
security patch releases and apply them immediately; the latter is important
since they sometimes appear in response to a perceived and imminent threat.
Thereafter it is vital that you document the version and release date of the
patch applied and the date when applied. Such records build into documentary
evidence of your project's timely and effective implementation of your security
Should your site be externally hosted then it is important to provide the reassurances
noted above by quoting the relevant sections of your service level agreement
with the organisation that is hosting your site.
Data Protection Act
Note also the "Must" requirements in Technical Standards section
3.1.4 Security that relate to personal information:
" The management and use of any personal information must conform
to the Data Protection Act 1998."
This means that if your project is collecting personal information, such as
the personal details of users, emails, etc., you must confirm that management
of such information is carried out in accordance with the Data
Protection Act 1998.
Protection of Data Subjects' Email Details: A common pitfall
Where projects may, with users' consent, hold data on a body of people, termed
data subjects, care must be taken in the use of such data, particularly when
contacting data subjects. It should be noted that even a person's email address
constitutes personal data and a project has a duty of care with regard to the
disclosure of a person's email address, even where the latter is freely transmitted
to the project.
A common pitfall for projects and other organisations is the unwitting disclosure
of email addresses among the data subjects of a project. In other words, persons
who were previously unaware of the email address of other users of the site
are able to read and use the address. How does this happen?
Origin of the Problem
In seeking to contact the website's users, projects frequently use a groupname
in the to: or c.c. line of their mail client. The use of groupname will include
all the addresses of persons entered into the mail address groupname and so
avoid the need to send individual emails to possibly hundreds of people. Alternatively
on other occasions, the list of email addresses is entered in the c.c. line
Herein lies the pitfall: whether a groupname or a long list is entered in either
the to: or c.c. line of the email to be transmitted, when sent, that email will
expose the email addresses of all the other persons included in the mail header
to all its recipients. This arguably constitutes a breach of the rules about
disclosure. The data subjects have not expected their email address to be passed
round to many other persons. It will only take one of the persons to misuse
the email address by contacting the disclosed person for, say, commercial purposes,
for the accidental disclosure to cause annoyance.
While the use of b.c.c., blind carbon copy, is not possible with all email clients,
some, such as Microsoft systems, permit the addition of an extra mail header
called b.c.c. A simple way therefore to mail all recipients without disclosing
any address other than your own and the individual recipient's is by placing
all addresses to be contacted in the b.c.c. line.
In so doing it should be remembered that the text of the email message needs
to be phrased in such a way as to reflect the diverse audience. The message
equally should be written in a way that does not accidentally disclose information
On reception the email recipients will see at most your address, their own
address and no other. In this way, no accidental disclosure of personal data
Technical Standards: 3.1.4.Security
British Standards Institute
This site will permit you to search for the relevant standard but full access
does involve the payment of a not insignificant sum.
What is BS 7799?
A commercial site offering some FAQs
and a questionnaire
on usefulness of BS7799 to your project.
Data Protection Act 1998
The Principles of Data Protection
Anyone processing personal data must comply with the eight enforceable principles
of good practice. Personal data covers both facts and opinions about the individual.
It also includes information regarding the intentions of the data controller
towards the individual, although in some limited circumstances exemptions will
apply. With processing, the definition is far wider than before. For example,
it incorporates the concepts of 'obtaining', holding' and 'disclosing'.
The fuller explanation of the 8 principles is also available:
The Data Protection Act: A brief guide for data controllers
http://www.dataprotection.gov.uk/dpr/dpdoc.nsf then 'Compliance Advice' then 'Data controllers brief guide'.
It is vital that those who collect and use personal data maintain the confidence
of those who are asked to provide it by complying with the requirements of the
Data Protection Act.
The World Wide Web Security FAQ
This is a site maintained by volunteers and hosted by W3C as a service to the
Web Community; (however, it does not endorse its contents). It attempts to answer
some of the most frequently asked questions relating to the security implications
of running a Web server and using Web browsers.
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