CYBERSECURITY REVIEW8 AUGUST - 2023IN MY OPINIONThe world is ever-changing; during the last 20 years, China has become the factory of the world for multiple industries, even for some high-technology industries, through the process of globalization. However, in the recent five years, China market has become more and more unique, even separated from the rest of the world, due to some geo-political reasons, high-tech competition, data sovereignty and localization requirement, and end-to-end supply chain security. Etc. But the only thing that has stayed the same is that China is one of the biggest consumer markets in the world due to the key factors: population, purchasing power and government policy support for the internal circulation of China's economy. No global consumer product company is willing to give up the Chinese market. The only thing we need to study is how to adapt our Chinese organization to this unique market and unique digital world, and the same to our Cybersecurity strategy in China, as a cybersecurity practitioner.First of all, China has unique and comprehensive cybersecurity laws and regulations, including data security and privacy protection. What's our strategy to comply with these requirements while keeping our global strategy and visibility? What kind of bottom line should we hold from either side? I believe this is the part where cybersecurity, legal, and even government affairs need to work very closely, and keep updated on the political climate, understand the government's legislation and enforcement trends, and even benchmark with industry peers; then we can formulate our executable compliance strategy and plans. From a technical perspective, neither global centralization nor China localization technology and data residency strategy will be fitting for both side; we definitely need to source for an intermediate solution like a geographically partitioned or distributed solution to meet China data localization requirements while allowing only the necessary aggregated or pseudonymized data to be transferred cross-border to keep a consolidated global view. You must always pay attention to the major Chinese E-Commerce platforms for selling consumer products well in China market. Yes, we can have our own Direct-to-Consumer or loyalty programs, but it is crucial to embrace and integrate into China's major E-Commerce walled garden, and make use of China's digital advertising channels by leveraging interesting marketing content and KOLs, even legitimately use 1st, 2nd and 3rd party data, social and search marketing touchpoint to target potential customers. That's why operational risk on the E-Stores on E-Commerce platforms become critical to us; there is a high volume of operation accounts to be managed on those E-Stores, sometimes with high turnover and complex roles; our successful experience is in building an E-Commerce platform account management system to be integrated with our HR onboard/transfer/offboard process, automate the check-in/check-out/rotate process, enable the role-based authorization and entitlement review control, of course enabling audit logging to enable abnormal activity alert based on the pre-defined risk scenario rule. There will also be some privileged accounts for managing some key functionality of E-Stores; we have a success story of creating a secure and centralized environment for business to access their E-Stores via privileged accounts, and enable the visibility, accountability and traceability around the usage, completely avoid sharing credentials of privilege accounts.By: James He, Cybersecurity Director, L'OréalCYBERSECURITY STRATEGY FOR GLOBAL CONSUMER PRODUCTS COMPANY IN CHINA MARKETJames He
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