Onboarding, and the case for supported services

“There is an awkward inverse in the relationship between technology, cost, and risk. While ever more sophisticated services come to market at ever lower costs, the inherent risks associated with these software solutions increase while user awareness remains behind the curve”.

Steve Galloway discusses the evolving nature of professional IT network support/administration and the changing risks that small businesses face.

Where “fast” broadband and “cloud” were once the marketing buzz words of marketing types in search of fertile sales pastures, today “onboarding” is the fashionably coined phrase, which describes a process where businesses migrate their data and other IT resources to mature cloud solutions like Office 365. Two years ago onboarding was a leading edge concept in commercial terms. The principle was not in fact, a new concept  to IT. The only changes were those associated with the bandwidth and computing availability to make services possible.

Today, onboarding’s trickle has turned into a tidal swell. The economies of scale that cloud services bring to businesses large and small are compelling, yet organisations struggle to keep up with toxic hazards lurking in data protection laws and proliferating accessibility.

This is not just a problem for big business. It is worth sitting up for: apart from legal liabilities which small businesses face for negligent treatment of customers’ personal data, the financial and reputational consequences following “leakage” of a firm’s own sensitive data can be ruinous, and the source could be as seemingly innocuous as your own mobile phone.

Historically, the network engineer’s bête noir was the office printer, and email. Even in the era of “cloud”, when the paperless office’s Promised Land has finally dawned, printers are still the benchmark that bookeepers and office managers use to guage network performance. Still, office printers vex users and support teams alike: printers jam when you need them most and for all the remote tools in the world you still have to hear them and the see the printer output to know that they are fixed.

Yet, printers stand a distant second to email. There are two ends of this spectrum for engineers. The first is the impossible support request along the lines of “somebody (read: “unknown person”) sent me an email and I didn’t get it (potentially as long as a year or more ago)”. The second is the ominous portent that heralds a black day for server room teams with the first “an email I just sent to (an important trading partner) has just bounced with the message “return to sender”, IP address blacklisted”. Somewhere in between lies the web site contact form that quietly ceases to work, and everything falls somewhere in between.

Workgroup printers were designed with critical performance in mind, but machines are just that, and it is perhaps easier for users to live with frustrating printer failures. After all, like cats and dogs, mechanical failure is a human condition. Ditto, snail mail: if the postman is late, the staff I remembered employing in the 1980’s went to the pastry shop and fired up the percolator for a morning of “R and R”, and if I was brave I would admit a few transgressions of my own. After all, how could anyone work without the morning post?

That culture changed forever with email. Email is not really more important than snail mail. However, something does appear to award them a significantly higher value. Perhaps it is a sense of entitlement. Perhaps its ethereal or “virtual” state leading us to imagine that it is not “machinery” that is capable of failing.

The problem with email really goes back to its genesis: email was not designed to be a critical business tool.  It just happened to become the most transformative business tool of the “Knowledge Revolution”. Email is fundamentally flawed for the business purposes we use it for today because by definition it is an unreliable service. Its design is founded in the quantum proposition that in chaos all paths between two points are possible. “Quantum” is an interesting term. It is a scientific proposition, but some scientists fall out with it because conventional science likes the idea that predictable things happen in predictable circumstances and if they could order the world there would be answers for all circumstances. Since quantum theory says there is no order in the first place, it understandably nags at the realm of science which requires order. The world is not very predictable though, and when one stops to imagine how many thousands or millions of random routes that the fragments which comprise one email take to reconstitute at another end, it is amazing that email works at all. Sometimes things do break down, and when it comes to email the user reaction is more often than not disproportinately robust.

So, email is a broken wheel in many respects, but by the time anyone realised how important email was and despite other technologies like social networking, the world was stuck with something we love to hate, unless that hate is directed at a network engineer by proxy. Instead, computer science has tried to construct orderly solutions to encapsulate a chaotic process at incredible costs. Ultimately, and in the debate over the virtues of science versus philoposphy, chaos prevails and the “quantumistas” and philosphers have devised some clarification: it is possible for the same thing to materialise elsewhere almost instantly, but not always. Is that not email?

Whatever, the reality is that in answering an email user’s defensively simple demand (“I just want my email to work”), an industry as ubiquitous as the energy industry itself has evolved in a fraction of the time to try to make it possible and subsequently  email is not the only issue in the context of this article. The problem for small business is that the tools big business have utilised in the past to make email viable are only now becoming available to small businesses thanks to the economies of scale that come with cloud computing, and with it some serious headaches.

Which brings us to the point. In bringing big business “reliability” to email and other chaotic Internet services for the small business market, the solutions themselves pose evolving threats to small businesses which only big businesses have typically feared – namely the risk of loss or leakage of an organisation’s sensitve data and its customers’ personal data.

Businesses face any number of risks, from malicious hacking to internal espionage, and even more worldly risks like flooding and storms. We live in a chaotic world. In terms of IT, though, there is a more pervasive problem for organisations which comes from an unexpected corner – mobile devices like tablets and mobile phones. By connecting users with laptops, tablets, and mobile phones to organisational email and electronic document libraries, small businesses unwittingly double and triple the size of their IT networks at a stroke, incrementally increasing the risk of data protection breaches. Arguably, even a doubling of a conventional network would once have prompted a planned development. Instead, individuals now own enough devices to constitute a small business network of its own:


Giving email and document access to employees 24/7 is a compelling proposition whichever way one considers it. So, let’s consider what happens when a boss asks his IT engineer to connect his manager’s personally owned mobile phone to company email services. Despite the fact that the company may have good control of its IT policies to comply with its obligation under data protection laws, by connecting third party assets to the company network, the company is now at risk of compromise: the mobile phone may have been left at a restuarant, or perhaps the manager has installed an app on his mobile phone which might have nothing to do with business processes at face value, but which subsequently trawls business information on the employee’s phone for information, which could possibly lead to data protection breaches and consequently, catastrophic consequences. These things can happen in unpredictable ways. The fate of US retailer Target’s headline-busting customer credit card theft in 2013 is well documented. The loss happened not by hacking the company’s “conventional” and well ordered IT network, but by compromising its cash tills.

Another pertinent example is the enormous institutional damage caused with the systemic “hacking” of mobile phones by journalists over several years in Britain. So simple was the technique that real hackers are (probably) offended at the thought that the technique could even be called hacking in the first place. The point is just that – overwhelmingly, personal and business information is wide open to abuse via employee-connected devices, whether by the family computer at home, a portable tablet, or simplistically, a mobile phone. As businesses use new technologies such as voice services, the nature of risk changes again and extends beyond just email and contact lists.

Small business users often tell me, “but those cases are examples of big businesses getting what they deserve, won’t happen to me”. This may be seen as a feasible argument, but the victim is the public in both cases, and unfortunately the risk to small businesses ceding data through compromise to malicious parties is no less. While big business devotes resources to governance policies and managing peripheral equipment, small business usually makes no effort at all while regularly getting caught out in the process.

Small business users will alternately say that responsibility lies with cloud providers to which they migrate services to. They even cite this as a reason for onboarding. In the UK, there is already a track record of legal precedent to say that that does not wash either. Legal responsibility of customer data remains absolutely with the business who takes custody of it in the first place – the data handler in UK parlance, the “responsible party” elsewhere.

What should small businesses do? What about professional services like Office 365? At the point of sale customers are told that there are tools for managing conventional and portable devices – indeed, a major selling point of these kinds of services is the ability to connect users with as many as 5 devices to their centralised service. How does a network newcomer sort that out, though? When it is all businesses can do to get email off the flight deck in the first place, who spends time on academic issues like lost phones?

Moreover, in buying mature and proven services like Office 365, how many organisations have asked staff to modify mobile phone voicemail PIN numbers following the historic phone hacking scandal mentioned above? How many power users have developed a tested policy for dealing with broader issues concerning their organisation’s lost laptops and mobile devices?

The answer to all this and more is the old fashioned concept of the network admin who has been around the block a couple of times. The likelier truth is that by the time a power user understands how to remotely lock someone’s iPad or a mobile phone after it is lost (a telco SIM block does not stop a wifi connected device from continuing to collect business emails and sych documents), the damage has long been done, and the user’s business ends up underwriting reputational damage, statutory censure, and legal liability. Worse than that is the enemy within. Handsets, tablets, and any other connected device that is not subject to governance, leaves your business open to an ongoing risk with every app a user runs without the organisation’s knowledge. In Hollywood terms, the threat is present and real.

There is a beguiling appeal to the unbelievably low price points for sophisticated business services. It can appear to be that such low price points can somehow circumvent risks we face in the real world, as if the risks are not really there any more. For example, Microsoft’s Hosted Exchange email service offers email tools that only big businesses with immense IT departments could have afforded to fund as far back as 5 years ago. The application costs as little as £2.50 per month for one user at time of writing. Importantly, although it introduces a Pandora’s box, the expertise to operate Exchange safely is still commensurate with the engineering skill crucially required for efficient management of  sizeable IT departments.

Today, there is an awkward inverse in the relationship between technology, cost, and risk. It is a difficult reality that is standing the world on its head far beyond the IT world itself. Increasingly sophisticated services come to market at ever lower costs, providing services which drive labour costs down. Although these technologies reduce a lot of operational costs too, other risks persist and broader exposure increases yet more risks. The inherent risks associated with evolving technologies like “onboarding” increase while user awareness remains behind the curve, and so the case for professionally consolidating and supporting devices within an organisation’s conventional and extended IT network remains stronger than ever.

decreasing versus increasing risk

Desreasing software costs do not diminish risks which increase with the proliferation of mobile devices in business networks.

ComStat is a certified Microsoft partner and accredited network adminstrator, capable of coping with organisations small and large. For advice about establishing and managing an “compliant” network policy, please call Steve Galloway on 07834 461 266.

Data Loss Prevention Policies (DLP)

Exchange 2013  provides comprehensive capabilities to help organisations identify, monitor, and protect sensitive information from leaking to third parties.Microsoft provides standardised regional libraries of policies to cope with management of credit card and financial information, personal information, and a variety of other metrics to help organisations comply with data protection laws according to the countries in which users are situated.

Office 365 is the only “off the shelf” product acceptable to US Federal Government and EU Covernment purchasing departments, and Microsoft’s DLP provisioning i relied on overwhelmingly by instititions large and small to establish data protection policies with the minimum of additional cost.

In Exchange 2013 Micorosoft introduced Document Fingerprinting and Policy Tips in Outlook Web App (OWA) to enhance document control and user education. Document Fingerprinting enables you to match documents that are derived from the same template.

This can be useful for organizations that frequently use standard forms or templates, for instance a law firm that uses a standard template to draft patent applications that it files on behalf of its clients.

Policy tips are designed to notify users in your organization when they are sending sensitive information over email. Policy Tips are similar to MailTips, and you can use them in Outlook in several different ways to help users avoid sending sensitive information in email. For example, you can use Policy Tips to:

  • Inform users of the presence of sensitive information and optionally block the email from being sent.
  • Educate your users through a Notify Policy Tip when sensitive content is present in their emails.
  • Empower your users to make case by case decisions by allowing them to override the sensitive information policy—with the option of including a business justification for the override.

Apps for Outlook

There is a growing inventory of Microsoft and third party apps for integration into Outlook Web App and Outlook for desktop, ranging from in-line adress detection and mapping/directions to email routing analysis and routing.

Organisations face increasing risks to data leakage. Data leakage happens when organisations allow data about their customers or even their own organisation to “leak” into the public domain, quite often unwittingly. For instance, employees who have mobile phones to connect to Exchange services can sometimes download third party apps which assume access rights to information an organisation holds which isneverthless prohibited under data protection laws.

Among tools available to ComStat’s engineers to help educate users and organisations alike, our network administrators are able to define policies for organisations which manage availability and distribution of apps to users who have access to organisational services.

Exchange Online Protection – EOP

Microsoft Exchange Online Protection (EOP) is a cloud-based email filtering service that helps protect Exchange users against spam and malware. EOP includes tools to safeguard organizations from messaging-policy violations. EOP runs within Microsoft data centres as a bundled provision for licensed Office 365 and Exchange users reducing problematic customer bandwidth risks, protecting email before delivery to all user devices, and simplifying the management of on-premise messaging environments and alleviating inherent costs that come with maintaining conventional on-premises hardware and software.

Microsoft Exchange EOP Features:

  • Eliminates threats before they reach your business firewall with multi-layered, real-time anti-spam and multi-engine anti-malware protection.
  • No extra hardware or software installation – EOP is a bundled service and runs from data centre, managing email before it is delivered to user devices.
  • Protects your company’s IP reputation by using separate outbound delivery pools for high-risk email.
  • Provides 5 financially backed SLAs, including protection from 100% of known viruses and 99% of spam.
  • Active content, connection, and flexible policy-based filtering enables compliance with corporate policies and public sector/IT departmental governance.
  • Leverages a globally load-balanced network of data centres helps to ensure a 99.999% network uptime.
  • Managed and administered from the Exchange Administration Centre with a single web-based interface.
  • Near real-time reporting and message trace capabilities provide insight into email environments by retrieving the status of any message that Exchange Online Protection processes.
  • Available to non-Exchange users.




Public Cloud & Data Protection

The accelerating trend of organisations to move data, including customers’ personal data to public cloud environments or other off premises services, raises an important question about who is responsible for the protection of a customer’s personal data.

The principle behind data privacy is that the information we occasionally give to others about ourselves is ours. If we give information to other entitities, like companies we buy goods and services from, the information we give should only be used for the purpose we gave it for.

Optionally, we can expand the scope of that remit, but let’s keep this simple. If we give our personal information to an appliance company when buying a washing machine, the company should only use that communication to talk to us about washing machines, and when the washing machine is dead, the data should also be deleted. If the washing machine company gives our information to another party without our permission, or if the company uses it for another purpose, then they are in breach of data protection laws.

The standard applies not only to large businesses, but equally to small businesses who hold data about their customers. So the question is, when small businesses use external email suppliers and public cloud services, who is responsible for keeping this data secure?

To understand the answer, we need to understand two concepts – data privacy, and data security.

Data privacy is a concept. Data privacy is the concept we use to explain our entitlement. It is an academic, or intellectual proposition. As property owners, our house is our castle. However, this intellectualisation does not mean that our house is safe. To enforce the concept, we have to secure it with locks.

This leads us to data security. This is a physical process, like securing our house with locks or other systems. Data security provides the tools that give us the confidence to know that our rights are protected. Data privacy and data security are interchangeably used, but they really account for two different propositions, and this brings us to the crux of the issue about who is responsible for the protection of data that individuals submit to the small business owner. Until now, many small business owners maintained customer data on premises, so the responsibility is apparently more clear cut. The data rests with the small business, therefore the business is responsible for it.

As small businesses use free email services and storage like GMail, Live, and Yahoo, and others increasingly move towards professional public cloud services, there is a tendancy for small businesses to imagine that the responsibility migrates with the data to the public services they use. Unfortunately, this is not the case.

In the case of the washing machine example, the company who holds a person’s information is what is called in the UK a “data controller”. Responsibility for protection of that data rests exclusively with the data controller, even if that information is stored with a third party elsewhere.

By way of example, Theo Watson, an attorney for Microsoft, recently cited a case where an NHS trust awarded a contract to an IT firm to dispose of computer equipment. Unknown to the Trust, the IT firm subcontracted the disposal to a third party who sold the computer equipment instead. However, the computers had not been purged and sensitive patient information made its way into the public domain. UK authorities determined that the responsible party was neither the contractor, nor the subcontractor, but the NHS. Although the NHS had delegated a job to a contractor, the NHS was ultimately responsible for knowing what happened to the data it held on behalf of its patients. If that meant watching hard drives being physically destroyed, it should have made sure that that happened.

The responsibilities of data controllers is absolute, and draws the role of free email services and public cloud services into sharp resolution. Small businesses often outsource IT work because they do not have expertise or financials to handle IT in-house. Yet, large suppliers like Google will be quick to point out that breaches arising from data that they hold on behalf of small businesses are not their responsibility. So, how does a small business protect itself?

In the final analysis, the answer lies in small business owners understanding the role that they play in handling customer data, and having confidence in the suppliers they use who provide the security necessary to protect data privacy rights on their behalf as an incentive to encourage business, rather than a contractual offering.

Premium suppliers like Micorosoft are certified to ISO 27001, HIPAA, FISMA, FERPA for their Office 365 solutions. Their participation in the “Safe Harbour” protocols enables the company to transfer data between EU and US jurisdictions within the confines of regional legal governance. At time of writing, Office 365 is the only email product supplied “off the shelf” that meets the regulatory governance required by US Federal Government department buyers and EU agencies. The same products are available for public purchase and include Microsoft’s extensive libraries of transport rules to help not only with observance of data privacy, but also tools for automated management of data leakage like credit card numbers, National Health Insurance numbers, and financial services information. Consequently, IT pros recommend services like MS Exchange, Office 365, because there is confidence in Microsoft’s efficacy as far as observance of data protection principles are concerned.

Rather than relying on ISO certifications etc. Micorosoft makes notable efforts to inform users about issues which are increasingly relevant as businesses move services online. Valuable resources are available at their Office 365 Trust Centre.

On the other hand, services like GMail, Yahoo, and others appear to sail closer to the wind. One reason is that many of the services small businesses use are not designed for business use in the first place. Whatever Google’s relationship with regulators over its evolving data policies, the weight of litigation by British, French, European, American, and other regulators hardly lends endorsement to Google’s ethical efficacy. Consequently, its growth in the business world is stunted compared to Office 365’s performance.

Regardless, responsibility for the execution of securing your customers’ personal information rests with you. In choosing your supplier, choose wisely, and choose an IT supplier who can inform you.


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