CYBERSECURITY REVIEW8 FEBRUARY - APRIL 2024IN MY OPINIONThe world is ever-changing. During the past 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 recent 5 years, China market has becoming more and more unique, even separated from the rest of the world, due to some geo-political reason, high-tech competition, data sovereignty and localization requirement, and end-to-end supply chain security. etc.But the only thing that has not changed is that China is still 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. I believe no global consumer product company is willing to give up China 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 its unique and comprehensive cybersecurity law and regulation, including data security and privacy protection. What's our strategy to comply to these requirements while keeping our global strategy and visibility? What kind of bottom line should we hold for both sides? I believe this is the part where cybersecurity, legal, even government affairs need to work very closely, and keep updated of the political climate, understand government's legislation and enforcement trends, even benchmark with industry peers, then we can formulate our own executable compliance strategy and plans. From technical perspective, neither global centralization nor China localization technology and data residency strategy will be fitting for both sides simultaneously, we definitely need to source for an intermediate solution like geographically partitioned or distributed solution to meet China data residency requirement while allowing only necessary aggregated or pseudonymized data to be transferred cross-border to keep a global consolidated view. For selling the consumer products well in China market, you can never ignore the major Chinese E-Commerce platforms. Yes, we can have our own Direct-to-Consumer or loyalty programs, but it is crucial to embrace and integrate to China major E-Commerce walled garden, and make use of China's digital advertisement channels by leverage 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 of the E-Stores on E-Commerce platforms become critical to us, there is high volume of operation accounts to be managed on those E-Stores, sometimes with high turnover and complex roles. Our successful experience is to build an E-Commerce platform account management system to be integrated with our own HR system, automate the check-in/check-out/rotate process, enable the role-based authorization and entitlement review control, and of course enable audit logging to have abnormal activity alerts based on the pre-defined risk scenario rule. There will also be some privilege accounts for managing the key functionalities of E-Stores, we do have successful story to create a secure and centralized environment for business to access their E-Stores via privileged accounts, and enable the visibility, By James He, Cybersecurity Director, L'OréalCYBERSECURITY STRATEGY FOR GLOBAL CONSUMER PRODUCTS COMPANY IN CHINA MARKETJames He
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