Managing Sensitive Data Harvard Townsend Interim University IT Security Officer harv@k-state.edu 532-2985 College Court 114 Oct 4, 2006 Dept Security Contacts Training 1 “…as we know, there are known knowns; there are things we know we know. We also know there are known unknowns; that is to say we know there are some things we do not know. But there are also unknown unknowns - the ones we don't know we don't know.” Donald Rumsfeld, Secretary of Defense, 2002 Oct 4, 2006 Dept Security Contacts Training 2 Why Should We Care? • 93,998,906 and counting… … the approximate number of records with personal identity information that have been compromised due to security breaches since February 15, 2005 • Privacy Rights Clearing House www.privacyrights.org/ar/ChronDataBreaches.htm Oct 4, 2006 Dept Security Contacts Training 3 Why Should We Care? • Data entrusted to our care • Handling a breach very expensive • Damage to institution’s reputation Oct 4, 2006 Dept Security Contacts Training 4 Oct 4, 2006 Dept Security Contacts Training 5 Why Should We Care? • It is the law: – SB 196 Kansas Security Breach Law takes effect Jan. 1, 2007 • Protects personal identity information • Mandates prompt investigation and notification – – – – FERPA (student records) HIPAA (medical records) GLB (financial records) ECPA (electronic communications) Oct 4, 2006 Dept Security Contacts Training 6 Why Should We Care? • It is K-State policy – PPM 3495 “Collection, Use, and Protection of Social Security Numbers” – PPM 3415 “Information Security Plan” (GLB) – PPM 7010, section .430 “Intellectual Property Rights” – PPM 7010, section .440 “Data Access and Retention” – PPM 3485 “Protecting Sensitive Data by Desktop Search Products” – PPM 3060 “Kansas Open Records Act” – PPM 3090 “Retention of Records” – PPM 3430 “Security for Information, Computing and Network Resources” Oct 4, 2006 Dept Security Contacts Training 7 Oct 4, 2006 Dept Security Contacts Training 8 Oct 4, 2006 Dept Security Contacts Training 9 Spoofed Website Hosted on the server in China Legitimate Website Oct 4, 2006 Dept Security Contacts Training 10 Harvested Data Login from Romania Victim Source of Spam Oct 4, 2006 Dept Security Contacts Training Hosted in Germany 11 What is “Sensitive Data?” • Sensitivity = level of protection against disclosure and abuse • Criticality = level of importance to the institution • Risk = measure of negative impact of a event and probability it will occur Oct 4, 2006 Dept Security Contacts Training 12 Data Classification • • • • Public data Internal restricted data Confidential data National Security Interest data Oct 4, 2006 Dept Security Contacts Training 13 Public Data • • • • • Approved for distribution to the public No such thing as unauthorized disclosure Very low sensitivity Still needs protection Examples: – – – – – Course catalog Campus maps Online people directory Extension publications Press releases Oct 4, 2006 Dept Security Contacts Training 14 Internal Restricted Data • Intended for use only within K-State for University purposes • Requires access controls • Public disclosure could cause problems • Moderate sensitivity • Examples: – – – – Departmental intranet Transaction log files Budget data Purchase orders Oct 4, 2006 Dept Security Contacts Training 15 Confidential Data • Highly sensitive data that can only be disclosed to individuals with explicit authorization • Protection required by law (FERPA, HIPAA) • Unauthorized disclosure harmful or catastrophic to individual, group, or institution • High sensitivity, thus requires highest level of protection • Examples: SSN, credit card #s, personal identity data, student records, personnel records, medical records Oct 4, 2006 Dept Security Contacts Training 16 National Security Interest Data • Federal government classified data • Restrictions determined by the source agency • Moderate to high sensitivity, depending on federal classification • Examples: – Biosecurity Research Institute data – DoD contracts – Homeland Security contracts Oct 4, 2006 Dept Security Contacts Training 17 Managing Confidential Data General Guidelines • Data owner must approve access • Require strong authN/authZ for access • Understand and secure all interfaces (“trust relationships”) • Secure test and development systems • Secure developers’ desktops • Don’t use real data for test and development • Control printing • Encrypt stored data where feasible • Fear wireless! Oct 4, 2006 Dept Security Contacts Training 18 Managing Confidential Data General Guidelines • Transmit securely (SFTP and SSH, not FTP and Telnet) • Don’t send in e-mail • Store on a secure server, not desktop or laptop • Place systems behind firewall with restrictive ruleset • Restrict physical access and remote access to server(s) • Monitor 24x7x365 • Secure, frequent, off-site backups • Destroy data thoroughly upon disposal • Perform security audit at least annually Oct 4, 2006 Dept Security Contacts Training 19 Social Security Numbers • See policy on the “Collection, Use, and Protection of Social Security Numbers” http://www.k-state.edu/policies/ppm/3495.html#policy • Removal from ID cards July 1, 2006 • Replaced with Wildcat ID (WID) • Available in K-State Online, KATS, DARS, eID eprofile • Full conversion in new SIS Oct 4, 2006 Dept Security Contacts Training 20 What Should You Do About SSNs? • Read “Understanding K-State IDs” www.k-state.edu/infotech/personalid/understandingids.html • Communicate the issue with your department • Identify uses of SSNs and compare to policy requirements • Be paranoid! • Watch IT Tuesday for more info Oct 4, 2006 Dept Security Contacts Training 21 Credit Card Numbers • Never store credit card numbers • Use third party credit service company • If you handle credit cards, review Payment Card Industry Data Security Standards (PCI DSS) • K-State is currently level 3 merchant • Become level 1 if compromised Oct 4, 2006 Dept Security Contacts Training 22 Mobile Devices • • • • • Laptop or tablet PCs Smart phones like Blackberry, Palm Treo Personal Digital Assistants (PDAs) Portable media players (iPod) Storage media like USB flash drive, SD or CompactFlash cards Oct 4, 2006 Dept Security Contacts Training 23 Preventing Theft • Use tracking and recovery software like Computrace from Absolute Software (www.absolute.com) • Use lock cables • Apply tamper-resistant asset tag or engrave cover • Use a nondescript carrying case • Don’t let it out of your sight when you travel • Always take it in your carry-on luggage • Don’t leave it in view in your car • Lock it securely with a cable in your hotel room Oct 4, 2006 Dept Security Contacts Training 24 Data on Mobile Devices • DON’T store confidential data on mobile devices • If you must, encrypt it • Beware of managing encryption keys • Keep the original file(s) on a secure server • Diligently manage the security of the device (patches, antivirus software, firewalls, etc.) Oct 4, 2006 Dept Security Contacts Training 25 Rumsfeldisms on IT Security On interrogating hackers: “I don't know what the facts are but somebody's certainly going to sit down with him and find out what he knows that they may not know, and make sure he knows what they know that he may not know.” On communicating with the media after a compromise: “I believe what I said yesterday. I don't know what I said, but I know what I think, and, well, I assume it's what I said.” “If I said yes, that would then suggest that that might be the only place where it might be done which would not be accurate, necessarily accurate. It might also not be inaccurate, but I'm disinclined to mislead anyone.” “Learn to say 'I don't know.' If used when appropriate, it will be often.” “I am not going to give you a number for it because it's not my business to do intelligent work.” Questions? Oct 4, 2006 Dept Security Contacts Training 27