How Public Exposure Impacts CTDPA Compliance

In this article we’re going to talk about external cyber risk and threat assessments in relation to the Connecticut Data Privacy Act (CTDPA).

We’ve written about this data privacy law a couple of times here, here, and here if you’d like to read to familiarize yourself with the CTDPA.

Before we continue, here’s our obligatory disclaimer. We are not attorneys and not your attorney. If you have questions about your legal exposure with this law, please seek a qualified lawyer/law firm that can assist you. Now let’s get back to the topic at hand.

If your organization is doing business in the state of Connecticut and you meet certain requirements, you must comply with the CTDPA.

In addition to providing Connecticut residents with the ability to exercise their legal rights, you must also have proper security controls in place to protect the data you collect, process, store, or transmit.

When it comes to compliance, it’s typically interpreted through legal and internal documentation. An attacker doesn’t care about that. What they’re doing, if they’re attacking from the outside, is viewing what risk you have. Then they’ll exploit any security gaps they discover to get into your assets.

One important thing a business needs is attack surface visibility.

Your attack surface is all the points a bad actor can exploit. Attack surface visibility is like having a map of what your assets are and discovering new attack vectors to clean up.

Your organization can no longer afford to just focus on understanding your internal environment.

If you don’t know what outsiders can see about your systems, services, and data, you can’t truly claim that you’re compliant with the CTDPA or that you’ve done thorough risk assessments.

Why External Risk Visibility Is Critical for CTDPA Compliance

The CTDPA doesn’t say “do OSINT,” but the law assumes you know where your data lives and how it’s secured.

In section 6(3) of the law, it states that a controller shall:

“… establish, implement and maintain reasonable administrative, technical and physical data security practices to protect the confidentiality, integrity and accessibility of personal data appropriate to the volume and nature of the personal data at issue.”

“Reasonable security” depends on knowing what assets are in play.

Attackers (and auditors/pentesters) use Open Source Intelligence to identify:

• Forgotten domain/subdomain names and test/dev servers

• Operating systems in use

• Exposed data bases or buckets

• Software used

• APIs

• Employees leaking information via social media platforms or forums by accident or intentionally

While this list is merely a drop in the bucket of what’s hiding in plain sight in the public domain, these exposures can lead to, or include, personal data (as defined by the CTDPA). This means that these exposures are a privacy and a security failure.

5 External Security Blind Spots That Threaten Your CTDPA Compliance

If your organization is required to comply with the CTDPA, reasonable security controls to protect personal data must be implemented. Some of these risks come in the form of assets that don’t show up in your internal documentation. Some of these assets are externally facing.

These overlooked or mismanaged assets are where an attacker may find something useful.

Here are a few of the most common blind spots:

Shadow IT
Employees sometimes adopt tools like CRMs, A.I. platforms, or cloud storage without approval of I.T. These tools can collect personal data. Some may lack adequate security controls causing blind spots in your asset inventory and compliance posture.

Forgotten Infrastructure
Unused domains/subdomains, test servers, or legacy environments may be exposed long after they’re needed. If they’re unpatched or contain real data, they’re easy targets.

Unsecured Cloud Storage
Misconfigured cloud storage, or shared folders, can unintentionally expose sensitive files like customer records, HR documents, or contracts to the public facing Internet.

Misconfigured SaaS
Platforms like help desks or form tools may publicly expose data if access settings aren’t properly configured and regularly checked.

Public Leaks
Exposed API keys, login pages, and internal tool mentions often show up in places like GitHub, social media platforms, or data breaches. These can reveal more about your environment than you realize.

If an attacker can find these, an auditor can too. Both may get there before you do.

Why Internal Asset Inventories Miss Key CTDPA Risks

Internal inventories are very important. Understanding what hardware/software is used, where it’s located, and who has access is key to helping you out when things go wrong.

Having an inventory for only internal assets misses third-party or forgotten assets. Teams and tools change, so this stuff is easy to slip through the cracks.

This is where our External Cyber Risk And Threat Assessments come into play. They bring to light what assets of yours exist on the public facing Internet that your internal teams might not know exist or forgot they did.

How External Cyber Risk and Threat Assessments Strengthen Your CTDPA Security Strategy

By leveraging our External Cyber Risk and Threat Assessments, our findings allow you to:

• Verify actual public exposure

• Prioritize assets that have highly sensitive data

• Linking visibility gaps to your compliance obligations (e.g. consumer rights, security controls, data minimization)

This is a proactive step to prevent any compliance issues before bad actors or auditors get to them before you do.

Our service also helps you update your asset inventory so that you have better visibility of your infrastructure. Better visibility means you can address any newly discovered security gaps and monitor what’s happening in order to adopt a better security posture.

Your Perimeter Is Public: Start CTDPA Compliance from the Outside-In

If your systems expose personal data, you’re out of compliance.

An organization’s perimeter shifted many years ago. No longer does it end at the four walls of your office. Your perimeter now includes the public facing Internet.

When you are working on asset management and reducing risk, start poking around online and see where your blind spots are. This will help you address any compliance issues among other things.

Wondering if your digital footprint could put CTDPA compliance at risk?

We help businesses like yours understand what matters most. Schedule a free strategy call today by using the contact form below.