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Zoom Privacy Policy is a Risk

Updated 4/05/20

Updates:

  • 4/05/20: Zoom posted an updated Privacy Policy, back dated to 3/29/2020.  This policy clarifies Zoom’s actions and intents and changes some terms and conditions, indicating that Zoom is now doing the right thing with your personal data.  Zoom has also expanded users’ ability to use passwords and waiting rooms to control meeting access.  We still recommend reviewing the policy and using the “do not sell” process.  We also recommend using conferencing systems within your productivity suite, Office 365 or G Suite, as these are secure and integrate with your email, calendar, and file services.
  • 4/01/20: MIT Tech Review summarizes the security issues with Zoom, including information about a Class Action Lawsuit.
  • 3/31/20: Vice.com reports that Zoom is leaking personal emails and photos to strangers.
  • 3/31/20: The Intercept reports that Zoom is not using End to End Encryption as claimed in their marketing materials and user interface. 
  • 3/31/20: New York Times reports that Zoom, the videoconferencing app whose traffic has surged, is under scrutiny by the New York attorney general’s office for its data privacy and security practices.
  • 3/30/20: FBI Warns of Teleconferencing and Online Classroom Hijacking During COVID-19 Pandemic

On March 18, 2020, the Zoom.us posted changes to its privacy policy that impact all users, even those without accounts attending meetings as guests.  This change follows a dramatic increase in Zoom users (and stock price), as Zoom has been offering its services for free to many businesses and schools.

Under this version of the Zoom’s privacy policy, Zoom is collecting more information, in our assessment, than is necessary to provide users with the service. Zoom also acknowledges providing this information to third parties. The information Zoom is collecting includes, but is not limited to:

  • Name, physical address, and other similar personally identifying information
  • Information about your job, such as your title and employer
  • Your Facebook profile information (when you use Facebook to log-in to Zoom or to create a Zoom)
  • General information about your product and service preferences (including software installed and/or in use on your computer)
  • Information about your device

Per Zoom’s policy, downloading and using the Zoom app provides Zoom with consent to share any personal information they collect with third parties.

In reference to the use of third party services, the policy states

“We use these tools to help us improve your advertising experience (such as serving advertisements on our behalf across the Internet, serving personalized ads on our website, and providing analytics services).”

In other words, Zoom may use the personal information of any person using their services to market to that person across their use of the Internet.

Additionally, we do not see any effort by Zoom to determine the age of individuals using the service, so they are likely collecting and using the personal information of children.

Vice.com is reporting that Zoom’s iOS app sends data to Facebook even if you do not have a Facebook account.

Impact

Our current assessment of the impact is as follows:

  • Data collection is based on the way each meeting participant enters the meeting.  Even if the organizer is on a paid and secure business or education edition, meeting attendees using the free client or entering as a guest are subject to dating mining and sharing.
  • For businesses and schools, some of the data Zoom collects and shares is prohibited under the Children’s Online Privacy Protection Act (COPPA).
  • For schools and libraries, not using the K12 version of Zoom for faculty and students may result in violations of the Children’s Internet Protection Act (CIPA)
  • Zoom does provide a means for users to instruct Zoom to “Do not Sell” their personal information. This help with California Consumer Privacy Act (“CCPA”) and  EU’s General Data Protection Regulation (“GDPR”) compliance.  It may not be practical to advise all meeting attendees of this option.

In short, Zoom’s privacy policy may conflict with your business’ privacy policy and how you manage and respect your customers and their data. The policy may also create regulatory and legal issues.

Recommendations

If you organization uses G Suite or Microsoft Office 365, you already have the ability to securely conduct audio and video conferencing with services that do not mine and share attendee data.

  • G Suite
    • Hangouts Meet (the new service) is secure and HIPAA compliant.  Individuals outside your organization can join via shared URL, without providing personal information. Through June 2020, Google has enabled all G Suite users to conduct meetings with up to 250 participants and provided organizers with the ability to record meetings. Participants can mute their own audio/video and can present to the meeting. Meeting include dial-in numbers and pins to allow access from phones.
    • Participants can join via web browser or use the free iOS and Adroid Apps.
    • Traditional Hangouts and Chat, while not HIPAA compliant, are still secure and work within organizations and with guests.
  • Office 365
    • Teams (and formerly Skype for Business) is a secure video/audio conferencing service with screen sharing, waiting rooms, and other helpful features.  As with all of Office 365, Teams can be deployed to meet HIPAA compliance. Teams does not collect and share personal information.
    • Teams, by default is device-to-device conferencing.  You can add the ability for individuals to connect by phone for a small monthly fee for each meeting organizer that needs this function.
    • Participants can join via web browser, or use the free apps for Windows, Mac, iOS, and Android.

Before adding another service or tool for audio/video conferencing, take full advantage of the services you have. Contact us if you need help with user training and support.

If you are not using G Suite or Office 365, several communications and conferencing services are offering secure, free access for up to 90 days.  These include, but are not limited to, Dialpad, UberConference, Ring Central, and Cisco WebEx. Please contact us for help selecting and deploying the right service for you and your teams.

 

Data Protection

Customer Notice Update: Email Advanced Threat Protection

Data ProtectionGiven the demand and need to improve your protection from the devastating impact of ransomware, crypto attacks, and other forms of cyber attacks we are extending the Advanced Threat Protection Priority Opt-in discount period through March, 2020. We understand that adding a service, even a critical service, impacts your budget and costs. Our Priority Opt-In discounts, and other measures (see below), intend to minimize the impact.

Email Advanced Threat Protection (ATP) and Multi-factor authentication (MFA) are necessary, baseline services for protecting your business

Beginning April 1, 2020, we require Advanced Threat Protection for all of our customers’ email service, unless you specifically opt out. Opting out is appropriate if you already have an advanced threat protection service in place.

If you opt out, the cost of our data recovery efforts will not be covered under our unlimited support plans (See our Support Services SLA). When we add ATP to your service, we will discuss with you when we can add MFA.

We will mitigate the cost.

We are sensitive to your budget.

  • ATP requires a technical setup and typically incurs a setup fee along with the monthly or annual subscription.
  • We are discounting both the setup and subscription fees for all customers. For customers requesting Priority Opt-In, we will waive the ATP related setup fees completely.
  • MFA implementation is covered by our support plans as an administrative change.  If you do not have on of our support plans, we will provide an affordable, discounted quote for the project.
  • For customers without an unlimited support plan and/or those that choose to Opt-Out, we will discount our hourly fees for recovery work.

For more information on specific discounts and pricing, and to let us know if you want to Opt-In, to have Priority Opt-In, or to Opt-Out, please visit this web page and complete the form.

We realize that this is a significant change for most of our customers.  We also understand the importance of these protections.  Please contact us with questions or concerns

Thank you for being part of our community,
Allen Falcon
CEO & Pragmatic Evangelist

7 Ways Downtime Hurts Your Business

A recent survey found that 40% of small and midsize businesses (SMBs) experiences 8 or more hours of downtime due to a severe security breach within the past year. According to the National Cyber Security Alliance, 60% of SMBs who experience a significant data breach go out of business within six months. These statistics are sobering. For many SMBs, however, the risks still feel foreign and not something that warrants action. To protect your business requires some knowledge and good advice, intent, action, small investments.

It is easier to rely on myths such as, “We are not a target for cyber attackers”, “We can run on pen and paper until we recover”, and “Our customers will understand” than it is to assess your risks and take action. Nevertheless, the risks are real and the number of SMBs hurt by downtime continues to rise.

Here are seven ways downtime can damage your business:

  1. Monetary Cost — Downtime leads to lost sales and lost productivity impacting top-line revenue and your bottom line. These costs hit your pocket in addition to the cost of recovery and returning to normal operations.
  2. Customer Trust — When you are unable to serve your customers, they lose faith in your business. While downtime for natural disasters is understandable, today’s customers have little tolerance for disruptions due to cyber attacks and breaches. Lost trust means lost customers.
  3. Brand Damage — Your brand identity and reputation drives customer loyalty and growth. Service disruptions from technology failures or breaches sends a message that your business may be poorly managed and is unreliable. These messages lead to loss of goodwill and create negative impressions of your business in the minds of your customers.
  4. Employee Morale — Disasters due to data loss or breaches means employees need to perform double duties. Employees spend time on recovery while working to keep the business operational. It often requires additional work hours. Recovery can be stressful and demoralizing.
  5. Business Value — Businesses that suffer data breaches and service disruptions are perceived as poorly managed. With the potential financial liability, public companies can see stock prices fall. All companies can suffer a loss of business value.
  6. Legal Action — Downtime creates the risk of legal action. This is particularly true for downtime that is perceived as preventable. System failures, data loss, security breaches, and other incidents can put your business in breach of contract. You may also be in violation of state and federal regulations.
  7. Compliance Fines & Penalties — As information privacy and security regulations expand, data loss and breaches create the real potential for fines and penalties related to regulatory compliance, privacy, and data retention requirements.

These risks carry the potential for lasting damage. Whether by increased financial burdens or winning back customers, the impact of downtime extends well beyond getting yourself up and running again.

Is your business worth protecting?

Protecting your business will not break the bank. We offer practical, affordable solutions that help you and your team understand the risks, prevent problems from happening, and continue operating in the event something bad does happen.

If your business is worth protecting, contact us for a complimentary Cloud Advisor session to discuss how we can improve your business’ resiliency.


 

Data Protection

Customer Notice: Email Advanced Threat Protection

Data Protection

(Updated January 20, 2020)

We continue to witness the devastating impact of ransomware, crypto attacks, and other forms of cyber attacks on our customers.  The recovery cost and frequency of attacks are increasing at alarming rates. The average cost for a small or midsize business (SMB) to fully recovery from a cyber attack has increased to between $145,000 and $180,000. This includes loss of direct business, remediation costs, damage to reputation, and employee downtime.  At the same time, the number of ransomware attacks so far in 2019 has doubled when compared with the same period in 2018.

As a managed cloud service provider, you have heard from us that you “should” have more protections in place. Our position is changing: these protections are a “must”.

Multi-factor authentication (MFA) and email Advanced Threat Protection (ATP) are necessary, baseline services for protecting your business. 

Beginning April 1, 2020, we will require and will begin adding Advanced Threat Protection to all of our customers’ email service unless you specifically opt out. If you opt out, the cost of our data recovery efforts will not be covered under our unlimited support plans (See our Support Services SLA). When we add ATP to your service, we will discuss with you when we can add MFA.

We will mitigate the cost.

We are sensitive to your budget.

  • ATP requires a technical setup and typically incurs a setup fee along with the monthly or annual subscription.  We are discounting both the setup and subscription fees for all customers. For customers requesting Priority Opt-In, we will waive the ATP related setup fees completely.
  • MFA implementation is covered by our support plans as an administrative change.  If you do not have on of our support plans, we will provide an affordable, discounted quote for the project.
  • For customers without an unlimited support plan and/or those that choose to Opt-Out, we will discount our hourly fees for recovery work.

For more information on specific discounts and pricing, and to let us know if you want to Opt-In, to have Priority Opt-In, or to Opt-Out, please visit this web page and complete the form.

We realize that this is a significant change for most of our customers.  We also understand the importance of these protections.  Please contact us with questions or concerns

Thank you for being part of our community,
Allen Falcon
CEO & Pragmatic Evangelist

G Suite: Modern Security for Modern Threats

Google CloudIn multiple blog posts over the past 2+ years, we have covered the changing and growing nature of threats to your organization, systems, and people.  For us the answer is CPR

Communicate and Educate;

Prevent & Protect;

Recover & Review. 

Once you have these basics in place, the challenge becomes keeping up with the times.  As the nature of threats change, the protective capabilities of our key systems should evolve as well.

For those of us running G Suite, we may understand that Google has expanded the security footprint and capabilities, but have we altered our configuration to properly protect ourselves?

The first step in assessing your protections is to understand the risks.

  • 91% of attacks start with a phishing email
  • 66% of malware was installed via malicious emails or attachments
  • 90% of all reported breaches caused by employee negligence, extortion, and external threats

These statistics, while not unfamiliar, point to the change in risk from physical devices to data and human interactions.

As people can be your greatest risk, the best protections compensate for human behavior.

Step two is mapping your security needs to the right version of G Suite. Each version adds additional protections, allowing you to move up to the version that best meets your needs and priorities. Understand what each version offers and map them back to your regulatory and business requirements.

G Suite Basic

  • Encryption in transit and at rest, including policy-based TLS enforcement
  • 2-Step Verification via prompt, SMS, Security Key,or Authenticator app
  • Single Sign-on (SAML 2.0)
  • OAuth 2.0 and OpenID Connect
  • Restrict emails to authorized recipients
  • Drive audit logs

G Suite Business

  • Vault for compliant archiving and e-discovery for Gmail, Drive, and Hangouts Chat
  • Team Drives for centralized access controls and permissions management
  • Domain white-listing for Drive with alerts
  • Basic Information Rights Management (IRM) to manage scope of sharing by Organizational Units

G Suite Enterprise

  • G Suite Security Center with a unified security dashboard
  • Advanced Data Loss Prevention for Gmail and Drive files
  • Email content compliance and objectional content filters, with OCR
  • Security key enforcement
  • User S/MIME Certificates for Gmail encryption
  • App white-listing to control 3rd party data access
  • Sandboxing (pre-delivery deep scanning) or email attachments

Moving the right version of G Suite has never been easier.

While no one product or service will meet all of your security, privacy, and data management needs, moving to the right version of G Suite improves your security footprint and can mitigate the need for 3rd party solutions. To help you move, we are partnering with Google to offer pricing incentives.

Your next step is to contact us to schedule a complimentary Cloud Advisory Session to assess your needs, priorities, and options.


 

 

 

Partner for Productivity

Partnering for G Suite Productivity

Partner for ProductivityG Suite is more than an email, calendar, and simple file sharing service.  G Suite is a productivity suite that serves as a platform for a range of tools that helps your team, and your business, work more effectively.

9 ways your team can be more productive with G Suite:

  1. Share Files, Not Copies:
    Stop sending attachments. Stop wasting time figuring out of the copy of the file in you inbox, on your local drive, or on a shared folder is the most current. Whether you use Google Docs for creating documents, spreadsheets, and presentations or you continuing using Microsoft Office, Google Drive and Team Drives serves your files rather than just sharing them.  People share via link, so all comments, suggestions, and edits are made within a single copy of the file. Versioning keeps this orderly and gives you the ability to look back and compare.
  2. Serve Files, Not File Servers:
    Use Team Drives and Drive File Stream to provide users with “explorer” access to files from Macs, PCs, and local software. Store files under central ownership and managed permissions; avoid performance and capacity problems with unlimited storage. Allow team members to work remotely and securely on computers, tablets, and mobile devices without VPNs and remote desktop services slowing things down.
  3. Communicate, Don’t Just Text:
    Most laptops now have microphones, speakers, and Bluetooth features similar to your smartphones and tablets. Have face to face conversations using Hangouts Meet instead of long email threads, phone tag, or text messaging. Communication is 55% non-verbal. Let you employees see and hear each other, your vendors, and your customers. You can share screens to live document reviews and discussions. Why pay extra for a conferencing service?
  4. Collaboration, Don’t Just Comment:
    True, Google Docs allow contributors to comment and suggest edits. You can also collaborate in real-time or as each participant is able. Version history lets you look back at who contributed, when, and where. You can name versions to track official revisions or specific working copies of documents.
  5. Schedule Productivity, Not Just Appointments:
    Your personal and shared calendars track your time as well as project or team activities. Resource calendars let you book rooms or any scheduled resource. Integrated with Hangout Meets, automatically include voice and video conferencing for the human touch. Integrated with Chrome for Meetings and you have 1-click video conferencing with screen sharing in your conference rooms.
  6. Manage Customer Relationships, Not Data:
    Integrated CRM applications, automatically pull person and company data into your CRM records and automatically track inbound and outbound emails with your prospects. Side panel gives you “pane of glass” access and context from within your Gmail inbox.
  7. Manage Communications, Not Data:
    Integrated sales and marketing tools, empower you team to better manage marketing, sales, and service communications without leaving your Gmail inbox.  Templates, mail merge, and tracking save time and energy as you drive your sales pipeline forward.
  8. Automate Tasks, Not People:
    Automate workflows and repetitive tasks, and build simple apps to boost productivity with AppMaker. The Low-code/no-code tool means you don’t need a cadre of programmers. Free up task time for more valuable activities.
  9. Protect Your Business; Not Just Data:
    Compliant archiving and e-discovery covers your email communications and your documents. Integrated solutions provide third party backup/recovery protection from accidental or intentional damage and loss. Cloud-to-cloud backup is less costly and requires less admin effort than traditional file server protection services.

Get the most value from your G Suite platform:

  • Verify you are on the right version of G Suite, with the capabilities that best meet your needs
  • Help your team learn how to use the G Suite apps to their fullest
  • Integrate 3rd party solutions for line of business needs, such as marketing, sales, and service

Please contact us for a free Cloud Advisor session to discuss getting the most value from G Suite.


 

Echo of Non-Compliance

Everyday, we hear about new ways we can use our smart speakers. Retailers, radio stations, product companies, and others remind us that we can use our Amazon Echo or Google Home to buy, listen, or learn. The term “smart speaker”, however, is misleading.  These are microphones and they are always listening. They are also likely recording everything they hear.

If you are covered by HIPAA or other privacy regulations, do not talk about protected information within earshot of Alexa.

This warning stems from a 2015 murder case in Arkansas. Believing that the Amazon Echo may have “heard” a murder, the District Attorney subpoenaed any recordings that Amazon may keep from the device. Amazon fought the decision on First Amendment and privacy rights, not by claiming that it was not recording. Amazon did not deny having recordings.

The issue for data privacy compliance is that your smart speaker may be listening to and recording conversations you have about protected information.  Allowing this is a violation of HIPAA and other regulations protecting personal identifying information (PII).

When is your Amazon Echo recording?

The short answer is: we are not sure, but maybe always.

Looking at the Alexa Terms of Use, Amazon tells us “Alexa streams audio to the cloud when you interact with Alexa” and “Alexa uses recordings of your voice to create an acoustic profile of your voice characteristics.” Alexa use is also covered by the Amazon Privacy Notice, which states, “We receive and store any information you enter on our Web site or give us in any other way.”

While Amazon tells us they are recording your “Hey, Alexa” commands, the Terms of Use and Privacy Notice are a bit more ambiguous. Neither document tells us that Amazon records only when listing and processing commands. Nor do the policies limit Amazon’s recording to those commands. We do not know, for sure, when Amazon is not recording what it hears on your Echo.

Better Safe Than Sorry

When speaking about sensitive or protected information, stay away from your “smart speaker” or manually mute the device.


One more thought:  Ever notice how after certain conversations, you see ads on Facebook related to the topic discussed?  Unless you turn off microphone access, Facebook is using your phone to listen to your conversations, analyze what you say, and profile you. Letting Facebook listen is another potential HIPAA and PII breach.


 

Rules and Regulations

Rules, Regulations, and Results

Rules and RegulationsFor Small and Midsize Enterprises (SMEs), the regulatory landscape remains in a perpetual state of flux with changes originating at the Federal, state, and local levels. While some rules and regulations can severely impact your business’ operations, and profitability, many create requirements that you can easily satisfy at a nominal cost.

Three regulations with upcoming deadlines or increased enforcement include:

HIPAA

HIPAA compliance is a requirement for any organization that works with personal health information of individuals — not just medical offices and insurance firms. If you are sharing employee information about benefits, insurance coverage, medical leaves, or other items that involve personal health information (PHI), you have an obligation to protect the PHI. Failure to do so can result in heavy fines and, in a few instances, criminal charges.

Historically, HIPAA compliance has focused on medical practices, insurance, and brokers. We are starting to see audits of non-medical companies, along with fines for those not in compliance. 

Fortunately, you can protect PHI by focusing on the individuals that are authorized or likely to handle sensitive employee information.  By focusing on HR, payroll, and key executive and leadership roles, you can deploy services like message-level email encryption.

What to do:

  • For as little as $5 or $6 per user per month, you can ensure that specific individuals protect PHI and sensitive information while preventing accidental disclosure
  • Contact us for information about encryption, DLP, and other HIPAA solutions.

ELD

Starting December 18, 2017, all interstate trucks in the US must use an Electronic Logging Device (ELD) to track operations and required reporting.  According to the US Department of Transportation (USDOT), fewer than 1/3 of interstate trucks have installed ELDs as of mid-November. Failure to comply can result in heavy fines, impounding of vehicles, and disruption of delivery schedules.

While enforcement is not expected to impact small and midsize trucking firms until late spring or summer of next year, your business can still be at risk.

Here are a few things to note:

  • If you have your own truck(s), they may be classified or registered as Interstate Trucks, even if you only deliver within your state.
  • If you use third parties for shipping, their failure to comply can disrupt your deliveries if trucks are stopped or impounded, or if drivers are pulled off the road.

What to do:

  • Check your own vehicles:
    • Determine if they are properly registered as Interstate Trucks, or if they should be registered as such
    • If you do not have ELDs yet, please contact us for low cost, self-install ELDs with logging software subscriptions
  • Check with your shipper(s):
    • Confirm their trucks, those of their subcontractors, and any owner/operators are properly registered and have ELDs
    • If not, have them contact us for help

GDPR

Effective May 25, 2018, the European Union (EU) General Data Protection Regulation (GDPR) takes effect. While GDPR covers data protection and privacy for citizens of EU member states, treaties allow enforcement in action against US companies operating within the US.

If you have any personal data for citizens of EU member states, you are responsible for GDPR compliance.

GDPR means more than encrypting sensitive data.  GDPR includes processes and procedures for governance, including:

  • A named Data Protection Officer (DPO) responsible for oversight, compliance, and response to individual inquiries. The DPO role can be full time or part time, internal or contracted.
  • You must report suspected breaches within 72 hours of becoming aware of the issue.
  • You need to deploy privacy by design — any new system or change in systems requires primary consideration of privacy and information security.
  • You must be able to demonstrate that you mitigate risk, even in the absence of a privacy breach.

Fortunately for most SME’s the appropriate policy changes and the risk-mitigation technologies need not be expensive of complicated.

What to do:

  • Discuss GDPR with your team, and your legal counsel, to determine your required compliance
  • Provide training, education, and “cultural support” for a data privacy mindset within your organization
  • Review systems storing or processing personal information for security and privacy compliance
  • Select and deploy relevant data loss prevention (risk mitigation) solutions for your environment

Need help? Contact us for more information.


 

News from Cumulus Global

SMBs Benefit from Tech and Policy Mashup

Westborough, MA – Faced with increasing regulations and a changing technology landscape, small and midsize businesses (SMBs) struggle to ensure compliance and maintain data privacy. With the sophistication of rasonmware attacks and advanced persistent threats, employee awareness and behavior is more important than ever. Cloud technology makes it easier to share, even when sharing is not appropriate.

To help SMBs tackle these challenges, Cumulus Global (www.cumulusglobal.com) and Privacy Ref (www.privacyref.com) announced a unique partnership designed to help SMBs assess their needs and risks, plan and implement sound privacy practices, and respond to threats and potential breaches.

“Smaller businesses face the same regulations and requirements of large corporations,” noted Bob Siegel, Founder and President of Privacy Ref. “SMBs generally do not have the internal resources and expertise to create and manage a privacy program. This partnership gives SMBs a place to turn for guidance, expertise, and results.”

In addition to privacy assessments and policy updates, the Privacy Education Programs provides SMBs with the awareness education and training needed to ensure employees understand the risks and their role in preventing attacks and breaches.

“Our role is to ensure businesses can avoid and prevent malware attacks and data breaches,” noted Allen Falcon, CEO and Pragmatic Evangelist at Cumulus Global. “We ensure that the protecting technology, policies and procedures, and people are working together for the greatest level of protection.”

Through the partnership, SMBs also gain access to a range of data protection and recovery services and tools. These tools help prevent attacks and breaches and facilitate response and recovery if needed.

Our First eBook: 7 Policies for Every Company Using Drive

Cover.7 Policies for Every Company Using Drive
We are please to announce the launch of our new eBook series with the publication of 7 Policies for Every Company Using Drive. Based on one of our most popular 3T@3 Webcasts, this eBook discusses information privacy and security issues and policies that should be in place to protect your customers, your information, and your business.

Our new eBook series is part of our growing suite of resources intended to help educate and inform on topics related to Cloud Computing for Small and Mid-Size Businesses.

Click here to access the eBook.