Homeless Management Information
System (HMIS) Data and Technical
Standards: Comply with the Security
Requirements in the Final Notice
Prepared by Abt Associates for the U.S. Department of Housing and Urban Development
HMIS Data and Technical Standards Training
• This is training module 4 of a 4 part series addressing the
following components of the Final HMIS Data and
Technical Standards
– Training 1: Overview
– Training 2: Participation and Data Collection Requirements
– Training 3: Privacy Standards
– Training 4: Security and Technical Standards
• Other training modules are available at: www.hmis.info
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Companion Training Materials
• This training module features an accompanying set of
training materials that includes:
– Data Standards Compliance Checklist for Agencies
– CoC/Implementing Jurisdictions Data Standards
Compliance Assessment Checklist
– System Monitoring Guidelines
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Overview
• Security standards for HMIS users
• Security standards for HMIS computers
• System/Server level security standards
• Monitoring security at the system level
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Defining Security
• Security refers to the protection of client personal
protected information and sensitive program information
from unauthorized access, use or modification.
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Security Standards Framework
• Two-tiered: required baseline standards and additional
recommended protocols
• Provide for technical controls to protect client data
• Require covered homeless organizations (CHO) to assess
their current technical infrastructure and make changes as
needed
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Applicability
• All workstations, desktops, laptops, and servers that
connect to the CHO network or access the HMIS through
a Virtual Private Network (VPN) must comply with the
baseline security requirements.
• Handout: Agency Data Standards Checklist
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What is a Virtual Private Network (VPN)?
• A private communications network that uses a public
network to connect remote sites or users
• VPN allows an employee to access his/her agency’s local
network from an off-site location using the Internet.
• VPN users typically have software that allows them to
access their network through the internet using a secure
site
• Learn more about VPNs:
http://computer.howstuffworks.com/vpn.htm
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Baseline HMIS Agency Security Requirements
• HMIS users
– Unique username and password
– Signed receipt of privacy notice
• HMIS computers and networks
– Secure location
– Workstation username and password
– Virus protection with automatic update
– Locking password protected screen saver
– Individual or network firewall
– Public Key Infrastructure (PKI) to prevent unauthorized
access
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Baseline HMIS User and HMIS Computer
Requirements
Baseline HMIS User and HMIS Computer Requirements
Firewall
Internet Access – Dial up,
Cable, DSL, etc.
Transmission
Encryption (SSL)
Certificate Template
USER REQUIREMENTS
1) Unique Username and Password
2) Signed Receipt of Privacy Notice
(i.e. consent protocol)
COMPUTER REQUIREMENTS
1) Secure Location
2) Workstation Username and Password
3) Virus Protection with Auto Update
4) Locking Screen Saver
5) PKI- Certification Installation or Static IP
6) Individual or Network Firewall
Prepared by Abt Associates for the U.S. Department of Housing and Urban Development
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HMIS Computer Requirements
• Computers in public areas used to collect and store HMIS
data must be staffed at all times
• Password protected screen savers must be automatically
enabled when workstation is not in use
• CHOs may decide to automatically log users off the
system after a period of inactivity
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HMIS Computer Requirements
• Virus protection
– Must automatically scan files; and
– User must regularly update software to detect new viruses.
– Free virus protection is available at:
• www.free-av.com
• www.nonprofit-tech.org
• Individual or network firewall:
– Network firewall = baseline requirement if internet is accessed
through central server; and
– Individual firewall needed if internet is accessed through a
modem.
• Additional spyware software is strongly recommended
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User Training (Strongly Recommended)
• Although not a baseline requirement, all users should participate in:
– Data and Technical Standards Training
• Participation and Data Collection Requirements; and
• Privacy and Security Protocols to Protect Client Data.
– Software training
• How to enter, edit, change, and delete data; and
• User and computer security requirements.
– Ethics and privacy training
• Consent protocol and privacy protocols; and
• How to interview clients in a sensitive manner.
– User groups are strongly encouraged to develop peer support
opportunities
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Baseline HMIS System / Server Requirements
• Authentication;
• Multiple Access;
• Virus Protection with Auto Update;
• Firewalls - Individual workstations or network;
• Encryption transmission;
• Public Access – PKI – Public Key Infrastructure;
• Location Control;
• Back Up and Disaster Recovery;
• System Monitoring; and
• Secure Disposal.
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Web Security Model
Web Security Model
Application Service Provider
(ASP) or Hosting Location
HMIS Data Entry Agency
Local Area Network
Network Server
User PC
Internet
Firewall
Firewall
PKI: Public/Private
Key Server
`
Certificate Template
HMIS Application Server
Router
Transmission Encryption
SSL (128 Bit)
User PC
Certificate Template
User PC
`
Certificate Template
`
Laptop with Wireless
Internet and Personal
Firewall
-Authentication
-Backup/Disaster Recover
-Location Control
-Virus Protection w/Auto Update
-System Monitoring
-Secure Disposal
-Session Timeout
Certificate Template
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User Authentication
• Every user accessing the HMIS system must have a
unique username and password.
• Passwords must:
– Include at least one number and one letter;
– Be at least 8 characters long;
– Not be based on user’s name, organization, or software;
and
– Not be based on common words.
• Good: [Na$car#39]
• Bad: bobclark99
• Terrible: hmis
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User Authentication (cont.)
• Both the workstation and the software used to access
HMIS data should require user authentication (e.g.,
username/passwords).
• Logging on to the HMIS computer alone is not sufficient.
• Written information pertaining to user access should not
be stored or displayed in any publicly accessible location.
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Multiple Access
• An individual user must NOT be allowed access to the
HMIS from multiple workstations on the network at the
same time.
• An individual user must NOT be allowed to log onto the
local network from more than one location at a time.
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System Level Virus Protection
• All systems on the network (including remote and VPN
users) must have anti-virus software installed and updated
regularly that automatically scans files.
Old Anti-Virus Software = No Anti-Virus Software
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Firewalls
• All machines accessing HMIS must have firewall
protection from public networks (i.e., the Internet), typically
via hardware.
• Any machines accessing the Internet via dial-up modem
must have a personal firewall.
• Individual or network firewall:
– If you use Windows XP you can install a firewall using
Windows XP Service Pack 2; and
– Free or low cost firewall software can be downloaded at:
• www.zonelabs.com
• www.techsoup.org
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Firewall Behind a Network
Image found at: http://www.integration1.com.au/pages/default.cfm?page_id=21925
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Encryption
• A CHO must encrypt all HMIS data that are electrically
transmitted over the internet
• Encryption is the conversion of plain text into encrypted
data (code)
• Encryption is used to protect a client’s sensitive personal
information from unauthorized viewing
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Data Transmission Encryption
• Two options
– 128 bit encryption over the wire; and
• Secure Socket Layer (SSL): A communications protocol used
to secure all sensitive data. SSL is normally described as
wrapping an encrypted envelope around message
transmissions over the Internet.
– Secure direct connections.
• Virtual Private Network (VPN)
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Public Access
• HMIS that use public forums for data collection/reporting
must have additional security to limit access using Public
Key Infrastructure (PKI) or through IP filtering.
• Translation: Any Web-based HMIS accessed over the
Internet, needs digital certificates installed on all browsers
on all computers accessing the HMIS (PKI) or an extranet
to limit access based on IP address.
Prepared by Abt Associates for the U.S. Department of Housing and Urban Development
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IP Addresses
• Everything on the internet (servers, desktops,
blackberries) is assigned an internet protocol (IP) address;
• The internet uses IP addresses to move information from
one place to another;
• An IP address looks like this: 10.141.215.223; and
• Firewalls block suspicious IP addresses from accessing
your computer.
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What is Public Key Infrastructure?
• Each user is issued a private key to encrypt messages
and a public key to decode messages;
• Private key is kept secret and known only to user;
• Public key uses a digital certificate to authenticate the
identity of the user;
• Digital certificates must be issued by a recognized
Certificate Authority; and
• Secure socket layer “SSL” encryption does not meet the
baseline PKI requirements.
Prepared by Abt Associates for the U.S. Department of Housing and Urban Development
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PKI: Public Key Infrastructure
• Options for implementing PKI:
– Self issued certificate authority-Example: Microsoft
Certification Authority;
– Third party certificate authority Example: Verisign or
Thawte;
– Seattle USB token; or
Certificate Template
• Alternative to PKI: Limiting access to HMIS through IP
filtering. Community examples:
– Los Angeles-filtering by IP address.
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Physical Access/Location
• Access to workstations must be controlled and monitored.
– Options: locked offices, privacy screens, etc.
• Access to servers must be controlled to a greater degree.
– Options: locked cabinet or cage; secure facilities.
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Backup and Disaster Recovery
• All HMIS data must be regularly backed up and stored in a
secure off-site location:
– Backup your data and applications;
– Save them to tape;
– Test the tapes;
– A Backup tape laying next to a server won’t help if the
server room catches fire!; and
– Alternatively, consider secure network-based offsite
backup solutions.
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Secure Disposal
• Tapes, disks and hard drives must be properly formatted
and erased before disposal.
– At least two erasure passes (three or more is
recommended).
• Free and commercial software is available to prepare old
workstation hard drives, tapes, and floppies before
discarding.
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System Monitoring
• Most security breaches are carried out by authorized
users of client record systems.
• All systems including central servers must be monitored
and “routinely” reviewed by staff.
• Monitoring decisions:
– Who monitors?;
– What is normal and what is abnormal usage and access?;
– How do I access the information?; and
– What variables to monitor?
• Handout: Security Monitoring
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System Monitoring (cont.)
• What variables to monitor:
– Logon success/failure;
– Account management;
– Policy changes;
– Privilege use;
– Process tracking;
– System events; and
– Connection attempts (IP and port).
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Additional security protocols
• Options:
– Designating a Chief Security Officer to supervise
implementation;
– Applying a firewall to all HMIS workstations where a
network firewall is installed; and
– Destroying HMIS media at a bonded vendor.
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Key Security Points
• Applies to all machines on the CHO network or accessing
the network through a VPN;
• All computers must have virus protection;
• All servers or computers directly accessing the internet
must be protected by a firewall;
• Web-based HMIS must use PKI or IP filtering to limit
public access to data;
• Physical access to computers and servers must be
restricted;
• Regular back-up and storage of HMIS data; and
• Regular monitoring of HMIS at the system level.
Prepared by Abt Associates for the U.S. Department of Housing and Urban Development
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Summary
• HMIS Data and Technical Standards set requirements for:
– Data Elements and Data Collection Requirements (Training
2);
– Privacy Standards (Training 3); and
– Security and Technical Standards (Training 4).
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Security Resources
• National Institute of Standards and Technology Computer
and Security Resource Center
– http://csrc.ncsl.nist.gov
• Carnegie Mellon/CERT: Connecting to the Internet
– http://www.cert.org/tech_tips/before_you_plug_in.html
• CERT Implementation Tips for Servers and Networks
– http://www.cert.org/tech_tips/
• National Institutes of Health Center for Information
Technology Security Site
– http://www.alw.nih.gov/Security/security.html
• Forum of Incident Response and Security Reform
– http://first.org
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Additional Resources
• Final Notice:
– http://www.hud.gov/offices/cpd/homeless/hmis/standards/index.cfm
• HMIS Related Info:
– http://www.hud.gov/offices/cpd/homeless/hmis/index.cfm
– www.hmis.info
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