Thu, Jun
3 New Articles

Does Compliance Guarantee Privacy?

Compliance / Privacy
  • Smaller Small Medium Big Bigger
  • Default Helvetica Segoe Georgia Times

In this article, security expert Carol Woodbury discusses whether being in compliance guarantees the privacy of your data.


When I was asked to write this article, I had to take a few minutes to determine the answer to the question. My initial reaction was, "Yes, of course. If you're in compliance, the data privacy is ensured." But as I thought about it a bit more, doubts began to crowd out my initial reaction. Join me in my thought process as I derive my final answer.


Before I describe my thought process on this subject, let me define what I mean by privacy. Simply put, I define data privacy as giving out personally identifiable information (PII) only to individuals with a "right to know." In a business setting, that translates into giving access only to individuals with a defined business need to use the data. For example, there should be very few, if any, individuals in an organization who can decrypt and see the full credit card information for all transactions in a database. Given this configuration, I would consider that the credit card information—as it resides in this database—to be private.

Compliance with What?

The first doubt that came to me immediately was: compliant with what? Before we can assert data privacy, we need to understand what we are in compliance with: the Payment Card Industry's Data Security Standards (PCI DSS), Health Insurance Portability and Accountability Act (HIPAA), Personal Information Privacy and Electronic Documents Act (PIPEDA) Sarbanes-Oxley Act (SOX), various state breach notification laws, ISO 27000 series, Basel II, and so forth. All of these laws or regulations have been lumped into the security compliance arena. The problem is, some of these laws and regulations have a great deal of detail on how data should be secured, but most just assert that the data should be secured and don't make demands or recommendations; therefore, it's up to you to decide the best method for implementing the security referred to in the law or regulation. If you choose a flawed method for securing the data, you might be in compliance with the law or reg (because you've met the intent), but the result is that the data isn't secure and, therefore, privacy cannot be assured For example, HIPAA—the law that's supposed to ensure the privacy of our healthcare data—is rather vague on how data is to be protected and is extremely vague on the system and network configurations on which healthcare information is stored and transmitted. 


Let me digress for one moment. Unless data is secured, it cannot be private. For example, if a database containing healthcare information is left with its default access controls set such that everyone on the system can read the data, the information is not secure…nor is it private. Data must be secured if it is to be private; therefore, if the law or regulation does not have specific security requirements or its security requirements are weak (that is, not based on security best practices), compliance does not ensure privacy.


Even if the law or regulation does have a complete set of security requirements—such as the PCI DSS—compliance may not guarantee privacy. Why not? Because the regulation is not complete and does not cover every eventuality. Take the Hannaford Foods security breach in which more than 4 million accounts were compromised. This grocery store chain was supposedly in PCI compliance at the time of the breach. So even the most detailed regulation does not guarantee privacy. Is there a higher likelihood that the cardholder information (that is, the credit card information retailers retain) will remain private because of the PCI DSS? Yes. Is it guaranteed? No.

What Type of Data?

The next thought cast another doubt. What type of data are we referring to? Depending on the type of data, there are more- restrictive or less-restrictive laws and regulations covering that data. As I said earlier, cardholder data is more likely to be private because of the restrictive nature of the PCI DSS. One might assume the same about healthcare data. But did you know that HIPAA does not cover healthcare information associated with workers' compensation? Strange but true. And, until California broadened its definition of "personal information" to include medical information and health insurance information, this type of data could be lost or stolen and no one needed to be notified. (Hopefully, other states will follow California's lead and expand their definition as well.) In other words, there are several cases in which some of your most sensitive information may not even be covered by a law or regulation.

Is There No Hope?

By now, the answer to the question "Does compliance ensure privacy?" looks pretty grim. Is there any case where compliance can ensure privacy? Yes. But only if security best practices are implemented throughout an organization, at every turn and every juncture. Remember, security is only as good as your weakest link. From ensuring physical security to performing hiring screenings to implementing "deny by default" access controls to logging to monitoring to executing security assessments—everything has to be in place to ensure data privacy. Is this unrealistic? Well, I must admit that I've never seen an organization fully implement security best practices throughout the entire organization, but I've seen organizations come close. I've also seen organizations make informed decisions about the risks to their information and take steps to implement several layers of protection around that data. And that's what I'd recommend that you do: implement security best practices wherever possible. You may not be able to ensure data privacy, but the likelihood of achieving it by using best practices is far greater than the likelihood of achieving it by relying solely on compliance with laws and regulations.



Carol Woodbury


Carol Woodbury is IBM i Security SME and Senior Advisor to Kisco Systems, a firm focused on providing IBM i security solutions. Carol has over 30 years’ experience with IBM i security, starting her career as Security Team Leader and Chief Engineering Manager for iSeries Security at IBM in Rochester, MN. Since leaving IBM, she has co-founded two companies: SkyView Partners and DXR Security. Her practical experience and her intimate knowledge of the system combine for a unique viewpoint and experience level that cannot be matched.

Carol is known worldwide as an author and award-winning speaker on security technology, specializing in IBM i security topics. She has written seven books on IBM i security, including her two current books, IBM i Security Administration and Compliance, 3rd Edition and Mastering IBM i Security, A Modern, Step-by-Step Approach. Carol has been named an IBM Champion since 2018 and holds her CISSP and CRISC security certifications.

MC Press books written by Carol Woodbury available now on the MC Press Bookstore.

IBM i Security Administration and Compliance: Third Edition
Don't miss the newest edition by the industry’s #1 IBM i security expert.
List Price $71.95

Now On Sale

Mastering IBM i Security Mastering IBM i Security
Get the must-have guide by the industry’s #1 security authority.
List Price $49.95

Now On Sale



Support MC Press Online

$0.00 Raised:

Book Reviews

Resource Center

  • SB Profound WC 5536 Have you been wondering about Node.js? Our free Node.js Webinar Series takes you from total beginner to creating a fully-functional IBM i Node.js business application. You can find Part 1 here. In Part 2 of our free Node.js Webinar Series, Brian May teaches you the different tooling options available for writing code, debugging, and using Git for version control. Brian will briefly discuss the different tools available, and demonstrate his preferred setup for Node development on IBM i or any platform. Attend this webinar to learn:

  • SB Profound WP 5539More than ever, there is a demand for IT to deliver innovation. Your IBM i has been an essential part of your business operations for years. However, your organization may struggle to maintain the current system and implement new projects. The thousands of customers we've worked with and surveyed state that expectations regarding the digital footprint and vision of the company are not aligned with the current IT environment.

  • SB HelpSystems ROBOT Generic IBM announced the E1080 servers using the latest Power10 processor in September 2021. The most powerful processor from IBM to date, Power10 is designed to handle the demands of doing business in today’s high-tech atmosphere, including running cloud applications, supporting big data, and managing AI workloads. But what does Power10 mean for your data center? In this recorded webinar, IBMers Dan Sundt and Dylan Boday join IBM Power Champion Tom Huntington for a discussion on why Power10 technology is the right strategic investment if you run IBM i, AIX, or Linux. In this action-packed hour, Tom will share trends from the IBM i and AIX user communities while Dan and Dylan dive into the tech specs for key hardware, including:

  • Magic MarkTRY the one package that solves all your document design and printing challenges on all your platforms. Produce bar code labels, electronic forms, ad hoc reports, and RFID tags – without programming! MarkMagic is the only document design and print solution that combines report writing, WYSIWYG label and forms design, and conditional printing in one integrated product. Make sure your data survives when catastrophe hits. Request your trial now!  Request Now.

  • SB HelpSystems ROBOT GenericForms of ransomware has been around for over 30 years, and with more and more organizations suffering attacks each year, it continues to endure. What has made ransomware such a durable threat and what is the best way to combat it? In order to prevent ransomware, organizations must first understand how it works.

  • SB HelpSystems ROBOT GenericIT security is a top priority for businesses around the world, but most IBM i pros don’t know where to begin—and most cybersecurity experts don’t know IBM i. In this session, Robin Tatam explores the business impact of lax IBM i security, the top vulnerabilities putting IBM i at risk, and the steps you can take to protect your organization. If you’re looking to avoid unexpected downtime or corrupted data, you don’t want to miss this session.

  • SB HelpSystems ROBOT GenericCan you trust all of your users all of the time? A typical end user receives 16 malicious emails each month, but only 17 percent of these phishing campaigns are reported to IT. Once an attack is underway, most organizations won’t discover the breach until six months later. A staggering amount of damage can occur in that time. Despite these risks, 93 percent of organizations are leaving their IBM i systems vulnerable to cybercrime. In this on-demand webinar, IBM i security experts Robin Tatam and Sandi Moore will reveal:

  • FORTRA Disaster protection is vital to every business. Yet, it often consists of patched together procedures that are prone to error. From automatic backups to data encryption to media management, Robot automates the routine (yet often complex) tasks of iSeries backup and recovery, saving you time and money and making the process safer and more reliable. Automate your backups with the Robot Backup and Recovery Solution. Key features include:

  • FORTRAManaging messages on your IBM i can be more than a full-time job if you have to do it manually. Messages need a response and resources must be monitored—often over multiple systems and across platforms. How can you be sure you won’t miss important system events? Automate your message center with the Robot Message Management Solution. Key features include:

  • FORTRAThe thought of printing, distributing, and storing iSeries reports manually may reduce you to tears. Paper and labor costs associated with report generation can spiral out of control. Mountains of paper threaten to swamp your files. Robot automates report bursting, distribution, bundling, and archiving, and offers secure, selective online report viewing. Manage your reports with the Robot Report Management Solution. Key features include:

  • FORTRAFor over 30 years, Robot has been a leader in systems management for IBM i. With batch job creation and scheduling at its core, the Robot Job Scheduling Solution reduces the opportunity for human error and helps you maintain service levels, automating even the biggest, most complex runbooks. Manage your job schedule with the Robot Job Scheduling Solution. Key features include:

  • LANSA Business users want new applications now. Market and regulatory pressures require faster application updates and delivery into production. Your IBM i developers may be approaching retirement, and you see no sure way to fill their positions with experienced developers. In addition, you may be caught between maintaining your existing applications and the uncertainty of moving to something new.

  • LANSAWhen it comes to creating your business applications, there are hundreds of coding platforms and programming languages to choose from. These options range from very complex traditional programming languages to Low-Code platforms where sometimes no traditional coding experience is needed. Download our whitepaper, The Power of Writing Code in a Low-Code Solution, and:

  • LANSASupply Chain is becoming increasingly complex and unpredictable. From raw materials for manufacturing to food supply chains, the journey from source to production to delivery to consumers is marred with inefficiencies, manual processes, shortages, recalls, counterfeits, and scandals. In this webinar, we discuss how:

  • The MC Resource Centers bring you the widest selection of white papers, trial software, and on-demand webcasts for you to choose from. >> Review the list of White Papers, Trial Software or On-Demand Webcast at the MC Press Resource Center. >> Add the items to yru Cart and complet he checkout process and submit

  • Profound Logic Have you been wondering about Node.js? Our free Node.js Webinar Series takes you from total beginner to creating a fully-functional IBM i Node.js business application.

  • SB Profound WC 5536Join us for this hour-long webcast that will explore:

  • Fortra IT managers hoping to find new IBM i talent are discovering that the pool of experienced RPG programmers and operators or administrators with intimate knowledge of the operating system and the applications that run on it is small. This begs the question: How will you manage the platform that supports such a big part of your business? This guide offers strategies and software suggestions to help you plan IT staffing and resources and smooth the transition after your AS/400 talent retires. Read on to learn: