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Sensitive Data Exposure Risks & Response at Indiana University Jonny Sweeny IT Incident Response Manager Indiana University IHETS Tech Summit 30 March.

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Presentation on theme: "Sensitive Data Exposure Risks & Response at Indiana University Jonny Sweeny IT Incident Response Manager Indiana University IHETS Tech Summit 30 March."— Presentation transcript:

1 Sensitive Data Exposure Risks & Response at Indiana University Jonny Sweeny IT Incident Response Manager Indiana University IHETS Tech Summit 30 March 2007 Copyright 2007, The Trustees of Indiana University. This work is the intellectual property of the author. Permission is granted for this material to be shared for non-commercial, educational purposes, provided that this copyright statement appears on the reproduced materials and notice is given that the copying is by permission of the author. To disseminate otherwise or to republish requires written permission from the author.

2 Overview Indianas New State Data Protection Laws (and a few other data protection laws and regulations) Indiana Universitys Preparation Indiana Universitys Incident Response What Weve Learned Questions

3 Indianas New State Data Protection Laws

4 Three Data Protection Laws Ill Review Release of SSN Disposal of Sensitive Data Notice of Security Breach

5 #1 - Release of Social Security Number Law Indiana Code (IC) Effective July 1, 2006, it is a crime for an Indiana state agency to disclose an individuals Social Security Number to a party outside of the agency, unless the disclosure is authorized under Indiana state law

6 What is a State Agency? For the purposes of this law, a state agency includes the following: –A state elected officials office –A state educational institution –A body corporate and politic of the state created by state statute –The Indiana lobby registration commission

7 Types of Disclosures Covered Any individuals SSN (doesnt have to be a customer), in any format: –Electronic –Paper –Oral

8 What SSN Disclosures are Authorized? Disclosures for which we have the individuals express written consent Disclosures of only the last four (4) digits of the SSN Disclosures for the purpose of administering health benefits of an employee or the employees dependent(s) Except where prohibited by state or federal law or a court order: –Disclosures to a local, state, or federal agency –Disclosures by our Police Department to an individual, entity, or local, state or federal agency, for the purpose of furthering an investigation Disclosures that are expressly required (not just permitted) by state or federal law or a court order Disclosures made in the context of certain counterterrorism investigations Disclosures to commercial entities for use in certain activities authorized under 3 federal laws

9 Penalties for Unauthorized Disclosures – State Agency Enforced by the State Attorney General who can bring action against Agency Possibility of civil suit filed by affected individual(s) Costs associated –Constituent trust, time and other resources needed to notify as required by the third law we are going to discuss

10 Penalties for Unauthorized Disclosures – Employees Knowing, intentional, or reckless violations are felonies: Up to 3 years jail time Up to $10,000 fines Negligent violations are infractions are misdemeanors: Up to 1 year jail time Up to $5,000 fines Possibility of civil suit filed by affected individual(s)

11 What Constitutes Negligence? It is not clear whether negligent disclosure under the law covers only affirmative transfer of an SSN… or also covers inadvertent exposure of SSNs to unauthorized access due to inadequate security measures.

12 #2--Personal Information Secure Disposal Law Indiana Code (IC) Effective July 1, 2006, it is a crime for a person to dispose of certain personal information of a customer in a non- secure manner

13 What is a Person? For the purposes of this law, a "person" means: –an individual –a partnership –a corporation –a limited liability company –or another organization

14 What Does Dispose of Mean? Discarding or abandoning the personal information of a customer in an area accessible to the public Includes placing the personal information in a container for trash collection Dont forget about disposal of computer drives and disks…

15 What Types of Personal Information are Covered? Social Security Numbers, OR First initial or name PLUS last name AND: –Credit card number –Financial account number or debit card number in combination with a security code, password, or access code that permits account access –Drivers license number –State identification number

16 When is PI Not Covered? The law only applies to personal information that is neither encrypted nor redacted –Encrypted: transformed through the use of an algorithmic process into a form in which there is a low probability of assigning meaning without use of a confidential process or key; or secured by another method that renders the personal information unreadable or unusable –Redacted: information is altered or truncated so no more than the last 5 digits of SSN or last 4 of other personal information are accessible

17 Who are Customers? Anyone who has received or contracted for the direct or indirect provision of goods or services and whose personal information you store, and Anyone who has given you their personal information in connection with a transaction with you For IU: –Includes students, parents, employees, bookstore and theater customers, vendors who give us personal information, etc….

18 What Types of Disposal are Secure Enough? Shredding Incinerating Mutilating Erasing Methods that otherwise render the information illegible or unusable

19 Relationship to Other Data Security Laws… State disposal law EXEMPTS persons who are already maintaining and complying with disposal program under: –HIPAA –Gramm-Leach-Bliley –Fair Credit Reporting Act –Drivers Privacy Protection Act –USA Patriot Act/Executive Order 13224

20 #3 – Notice of Security Breach Law Indiana Code (IC) Effective July 1, 2006, a State Agency must notify individuals whose unencrypted personal information was or is reasonably believed to have been acquired by an unauthorized person as a result of a system security breach

21 What Types of Personal Information are Covered? First initial or name PLUS last name AND at least one of the following: –SSN (> last 4 digits) –Drivers license number –State identification card number –Credit card number –Debit card number –Financial Account number –Security code, access code, or password of financial account

22 What Does Unencrypted Mean? Its not defined in this law – best to assume the definition in the disposal law would apply

23 Some Exceptions This law only addresses computerized (electronic) data, not paper data Also, the law doesnt cover theft of portable electronic devices with personal information stored on them, if access is protected by a password that has not been disclosed Of course, IU can still give notice as a policy matter if we had these types of disclosures…

24 When Does Notice Have to be Given? without unreasonable delay Consistent with –legitimate needs of law enforcement, and –measures needed to determine scope of breach and restore system integrity Notice may be delayed if law enforcement determines notice will impede criminal investigation

25 How May Notice Be Given? In writing By By conspicuous posting on IU website and notice to major statewide media, if –Cost of notice to individuals is $250K or more, –More than 500,000 people must be notified, or –We have insufficient contact information for personal notice

26 Who Else Must Be Notified? The Indiana Attorney General If more than 1,000 individuals information involved, must notify all consumer reporting agencies –Equifax, TransUnion, Experian –Heads up to them that individuals may be requesting credit reports to monitor for attempted identity theft

27 Review and Compare: Release of SSN Disposal of Sensitive Data Notice of Security Breach

28 Other Regulations Many other privacy/security rules and regulations dealing with specific categories of data to be protected: –FERPA: student education records –GLB: nonpublic customer information of financial institutions –HIPAA: personal health information –FACTA: consumer report data –PCI DSS: credit card transaction information

29 Payment Card Industry Data Security Standards (PCI DSS) Merchant bank agreements impose payment card data security standards Extensive and rigorous requirements that apply to all components of IT system involved with cardholder data access, retention and processing Requires immediate notice to payment card company in case of security breach Noncompliance may lead to fines, revocation of right to accept cards for payment

30 Indiana Universitys Preparation

31 Indiana University Indiana University has eight campuses: –the original campus in Bloomington; –an urban campus in Indianapolis, which also includes the IU Medical Center; –and six regional campuses in the cities of Gary, South Bend, Fort Wayne, Kokomo, Richmond, and New Albany. Total students: ~ 98,000 Total faculty and staff: ~22,000

32 Decentralized Environment Data Stewards responsible for policy and practice concerning their data –Including granting access to their systems, and training about use of their data Colleges, departments, & units are responsible for local technology and security of that technology Individuals responsible for following policy

33 Strategy IT Security & Policy Office partnered with University Counsel and Internal Audit to devise plan: –Composed a letter, sent by President to all faculty and staff –Gave presentations on new laws and what to do, to the Chancellors, to departmental staff, and everyone in between! –Created web page to compile information and resources in one place –Ensured Incident Response was ready –Advise as needed

34 Indiana Universitys Incident Response

35 Prior Preparation Already had procedures and Kit in place prior to the law being passed, due to existing industry best practice of notifying individuals Revised Kit to include new requirements of the Indiana law Presentations and Letter educated about how to report these incidents

36 Incident Response Overview Unit takes immediate action to report incident to IT Security & Policy Office (ITSPO) An Incident Team is immediately assembled to advise and assist in : –containing and limiting the exposure –investigating the attack –ensuring appropriate approvals –handling notification to the affected individuals and agencies Incident belongs to the unit that caused it, but is coordinated by the ITSPO Post mortem held 2-6 weeks afterwards

37 What Kind of Breaches? Prior to new law: –Faculty member kept old computer when new ones were distributed, patches were not kept up to date, had grade rosters on it –Outsourced server not properly secured Since July, 2006: –Secretary mistakenly ed to wrong address, with spreadsheet attached –Laptop of faculty member stolen from his locked car in his garage, had grade rosters on it –Library posted archive data on web –Flash drive lost, with programmers data on it No damages yet reported – but we err on the side of caution

38 IUs Sensitive Data Exposure Incident Kit I. Checklist II. Sample Notification Letters III. Template for Web Page and FAQ IV. Sample Press Releases V.Dealing with Contacts from Press (with Sample Talking Points) VI. Dealing with Contacts from Individuals

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41 What Weve Learned

42 Experience Tells Us… TIME IS CRITICAL Unit will not have experience to handle on their own –Important to have coordination by one unit, sharing materials and knowledge gained Focus should be on the individuals affected, not the press The Attorney General has given us an A+! Not sure if that is good or bad…

43 Issues Can we proactively look for this data, or will we get in trouble with the AG? How to ensure every employee is trained appropriately, regardless of whether they have access to a data repository or not Staying up to date with legislation both at state and federal levels…

44 Issues (cont.) In proactively looking for this data, we are considering approaches that are: –Systematic –Manageable –Relatively Thorough

45 Questions?

46 Jonny Sweeny Indiana University IT Security & Policy Office Data Protection Web Page dataprotection.html


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