Safeguarding Personally Identifiable Information - tri

Report
Safeguarding
Personally Identifiable Information (PII)
It happens once every 4 seconds, thousands of times a day,
millions of times a year: That’s how many times experts
estimate there’s a phony charge made with a stolen credit
card number. …and this kind of fraud is just a fraction of the
identity theft problem!
Agenda
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What’s New With DON Privacy?
Definitions
Elements of a Great Privacy Program
The Basics about Identity Theft
PII Breach Trends and Recent PII Breaches
Phishing
The DON SSN Reduction Plan
Top 10 Privacy Lessons Learned
Final thoughts…
Privacy POC’s
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What’s New with DON Privacy?
• New DON CIO, Terry Halvorsen, Senior Military
Component Official for Privacy– oversees DON
Privacy Program
• SSN Reduction Plan Phase I for Forms
underway
• DoD requirement to discontinue posting of last
four of SSN to public facing web
sites (e.g. promotion messages)
What’s New Continued…
• Hard Drive Disposal Policy Message
• Hard Drive Disposal Poster
• In chop, Draft Reduction of SSN Use in DoD
Instruction
• Jan-Mar 2011 CHIPS Magazine with SSN focus
– available today
• Consolidation of DON Privacy functions/offices
under review
Privacy Awareness Posters
Personally Identifiable Information (PII)
Definition
PII Definition: “…information about an
individual that identifies, links, relates, or
is unique to, or describes him or her,
e.g., a SSN; age; rank; grade; marital
status; race; salary; home/office phone
numbers; other demographic, biometric,
personnel, medical and financial
information.” DoD Memo 21 Sep 07
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Sensitive and Non-Sensitive PII
Sensitive PII which may cause
harm to an individual if
lost/compromised
• Financial information- bank
account #, credit card #, bank
routing #
• Medical Data- diagnoses,
treatment, medical history
• Full Social Security Number
• NSPS/Personnel ratings and
pay pool information
• Place and date of birth
• Mother’s maiden name
• Passport #
• Numerous low risk PII
elements aggregated and
linked to a name
Non-Sensitive PII, all authorized
use under DON policy and
considered “low risk”
• Badge number
• Job title
• Pay grade
• Office phone number
• Office address
• Office email address *
• Lineal numbers
• Full name
* Cautionary note: Growing
problem with email phishing
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PII Breaches
• A breach is defined by Office of Management & Budget as:
“A known or suspected loss of control, compromise, unauthorized
disclosure, unauthorized acquisition, unauthorized access, or any
similar term referring to situations where persons other than authorized
users and for an other than authorized purpose have access or
potential access to personally identifiable information, whether physical
or electronic”
• Reporting required when a known or suspected loss, theft or
compromise of PII occurs:
– Use OPNAV Form 5211/13 to make initial and follow up reports
– Send to: US-CERT within 1 hour of discovering a breach has occurred (*United
States-Computer Emergency Readiness Team)
• To the DON CIO Privacy Office within 1 hour
• To the Defense Privacy Office
• To Navy, USMC, BUMED chain of command, as applicable
• DON CIO Privacy Office will determine within 1 working day the need to
notify affected personnel - weigh risk of identity fraud.
• Within 24 hours provide DON CIO follow up report.
• Within 30 days provide DON CIO lessons learned.
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Seven Elements of a
Great Privacy Program
Leadership
Risk Management and Compliance
Information Security
Incident Response
Notice and Redress for Individuals
Privacy Training and Awareness
Accountability
Information Security
 Privacy and security programs are
complementary – must work together
 Information security must be a priority
and message continually reinforced
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Build security and privacy controls in early
project development and all stages of
to know
lifecycle –– Need
Take a “less is more” approach with PII
collection
Incident Response
• If your office handles PII, written procedures must be in
place to:
– Detect, report and respond to privacy incidents
• Timely response and mitigation of risk are critical
• The discovering contractor/vendor has an obligation to
report the PII breach
• The accountable vendor has the responsibility of working
with DON command to notify affected personnel
• Applying lessons learned are key
Privacy Training and Awareness
• Training reinforces policy and best practices and
helps create a privacy culture
• All contractors under contract with DON must:
– Require all employees to complete annual PII training
• If responsible for causing a breach:
– Proposed policy will require each individual to take PII
Refresher training
Accountability
• Take “Big stick” approach or do nothing?
– Must be a balance
– Focus on correcting human error and malicious intent
• Ensure contracts include FAR PII language
• Take corrective action where there are program
deficiencies and follow up
• Consider Identity theft protection
I
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IS REAL!
Basic Facts About Identity Theft
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FTC reports 8M+ of U.S. adult population has experienced ID theft in ‘10,
expect to see that grow during economic decline; Most fraud costs are
passed to businesses.
In ’05 1.8M cases new account fraud; 6.5M cases existing account fraud.
Account fraud only 23% of the problem!
Crimes are still more often offline (90%) than online.
Consumer controls 63% of potential ID theft problem; detects 47% of cases.
Risk is greatest when information was stolen by someone targeting the data
e.g. hacker, burglar.
½ of known ID thieves were known by victim; ¼ were dishonest
employees.
Social Security numbers are "the most valuable commodity for an
identity thief.“ Can obtain from public records free or buy on internet for
$25 per SSN.
Phishing attacks aimed at ID theft a real and growing threat.
– Banks, Pay Pal, bogus job offers
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Generation X (25-34) highest fraud rate (5.4%); 65+ lowest.
ID theft of children and people who are deceased, a growing problem.
FYI, by law, consumer credit card liability is $ 50.00; Debit card is $50.00 if
reported within 48 hrs; $500.00 if reported w/in 60 days; after 60 days may
lose all $’s in account plus overdraft amount!
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ID Theft Trends
These statistics represent the growth from 2006 to 2007
- Arrest warrants issued in victims names due to
Financial Crimes – 24% to 62% increase*
- Fraudulent drivers licenses - 16% to 32% increase *
- Fraudulent employment - 13% to 41% increase *
- Fraudulent tax refunds - 11% to 59% increase *
-Received Government assistance with victims
information - 6% to 27% increase *
-Additional 250,000 to 500,000 Victims of Medical
Identity Theft reported each year *
*Information gathered by the IDTRC and Chicago Tribune
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What Are the Fixes To Reduce ID Theft?
Must have a comprehensive, multi faceted approach.
• Reduce/eliminate the supply of SSNs and “high risk” PII
available to thieves
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Remove SSNs from all public records
Remove the SSN from DoD and DON forms, when possible
Reduce the display, storage and transmission of SSNs and PII
Improve data and personnel security
Create strict laws that make the sale of SSNs a crime
• Reduce the demand for SSNs by minimizing their value to ID
thieves.
– Require/encourage adoption of more effective authentication
procedures by financial institutions
– Aggressively prosecute ID thieves
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TRENDS and PATTERNS
• Increase in number of “insider” caused breaches
• Confirmed identity theft cases remains low
• Rise in incidents involving recall roster and spreadsheet
attachments sent via email and shared drive disclosures
• Drop in incidents involving SSNs from 80% to 54% over
the past 12 month period
• Decrease in number of impacted personnel by 50% over
the past 12 months
Recent Breaches
• Used Navy copiers erroneously sold before hard drives
sanitized. Error realized before copiers were received by new
owner and recovered by DON. Contained PII and other
sensitive info. Sep 09
• Unencrypted laptop stolen/missing from Naval pharmacy
containing SSNs and patient names. Aug 09
• Employee downloaded PII to unencrypted CD, transferred to
new command, soon after arriving lost the CD and filed a
breach report. Oct 09.
• Sailor and his civilian girlfriend were allegedly attempting to
steal the identity of multiple staff members. Several staff
members had complained about attempts being made to take
out credit in their names. Jan 10
• PO2 sold PII of service members to group who created bogus
tax returns. All returns mailed to same address! Apr 10
• Laptops stolen as part of “tech refresh” process. Some DAR
protected, some not. Investigation ongoing. Sep 10
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PII Breach Media
Must have tight controls/permissions
Improving but
only takes one
Still # 1
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PII Breach Media
What happens to the digital images when
a copier is turned in?
Sent to recipients “without a need
to know” / unencrypted.
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Breach Causes
180
160
140
Number of Incidents
120
100
80
60
40
20
0
Human Error
Theft
Unknow n
Postal
Insider Threat
Hacker
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Type of PII Lost, Stolen or Compromised
200
180
160
Number of Incidents
140
120
100
80
60
40
20
0
SSN
Medical
Financial
NSPS
Passport
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Phishing
Phishing is the process of attempting to acquire sensitive
information such as usernames, passwords or financial account details by
masquerading as a trustworthy entity in an electronic communication.
 This is a growing activity within the DON.
 Perpetrators ask you to click a link back to a spoof web site. Doing so could
subject you to the installation of key logging software or viruses.
 They use fear to motivate you to respond – “your account has been temporarily
suspended due to recent fraudulent activity, we need you to verify your account
information…”
 Never open emails from unknown sources or institutions soliciting:
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Passwords
Credit card information
ATM/Debit Card number
Social Security Number
Bank/financial account number
 If in doubt about validity of the email, call their customer service number.
 Notify your network administrator. For NMCI go to:
https://www.homeport.navy.mil/support/articles/report-spam-phishing/
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Human error
Flash storage media
Budget and resources
Changing business processes
IT systems
Records management
Teleworking
DON culture
Hard drives
Hackers
Blogs
Disposal of storage media
Official and unofficial forms
Contractor services
Web portals and shared drives
Insider threat
Spreadsheets
Email
Malicious software
Data mining
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Acceptable SSN Uses
DoD Guidance lists 12 cases for Acceptable Uses of SSNs (Collection, Use,
or Retention):
- Geneva Conventions Serial Number (on a timeline to to change/eliminate
SSNs from ID cards)
- Law Enforcement, National Security, and Credentialing
- Security Clearance Investigation or Verification
- Interactions with Financial Institutions
- Confirmation of Employment Eligibility
- Administration of Federal Worker’s Compensation
- Federal Taxpayer Identification Number
- Computer Matching
- Foreign Travel
- Noncombatant Evacuation Operations
- Legacy System Interface
- Other Cases (with specified documentation)
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DRAFT DON SSN Reduction Plan
GOAL: Reduce or eliminate
the use, display, collection,
dissemination or storage of SSNs
across the DON.
• Phase 1 - focus on justifying continued use/collection of SSNs in
official Navy/Marine Corps forms and IT systems.
• Phase 2 – Where SSNs are still needed and where applicable,
substitute using the Electronic Data Interchange Personal Identifier
(EDIPI).
• Challenges:
– DoD must provide guidance on the use of the EDIPI-must have controls
or we create another SSN.
– Elimination of the SSN or substituting the SSN for another identifier will
incur unfunded program costs.
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Privacy Lessons Learned
• Support and involvement from senior leadership is key.
• Aggressive PII compliance spot checks with corrective action
taken are very effective.
• Eliminate/Reduce the use, display and storage of all PII
whenever possible.
• Mark all documents containing PII with FOUO Privacy Sensitive
warning.
• Ensure shared drive access permissions are established and
routinely checked.
• Special care must be taken when moving, closing or consolidating
offices that handle PII.
• Closely scrutinize employees/contractors that have access to PII.
• Paper documents and hard drive disposal methods must be better
defined and tightly controlled.
• A command records management program with records disposal
schedule is an effective tool to reducing PII.
• Campaign continuously to increase PII awareness.
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Some final thoughts…
• Penalties under the Privacy Act apply to
contractors
• Revisions to the FAR under discussion
• Consider credit monitoring for vendor caused
breaches
• Doncio.navy.mil web site is a great privacy
resource:
– FAQs, PIA Gouge, Breach Reporting Forms, Credit
Monitoring Info, Privacy Reading List, Table Of
Consequences, Posters, Tips of the Month
• PII Info Alert
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DON Privacy POCs
STEVE MUCK
ROBIN PATTERSON
SAM YOUSEF
DON CIO
DON Privacy Team Lead
Phone: (703) 601-0081
Email: [email protected]
OPNAV DNS-36
HQMC C4 CYBER SECURITY DIVISION
PII/PIA Analyst
Phone: (571) 256-8876
MICHELLE SCHMITH
DEBORAH CONTAOI
MAJOR PRASSERTH YANG
DON CIO
Phone: (703) 602-6110
Email: [email protected]
OPNAV DNS-36
Phone: (202) 685-6546
Email: [email protected]
HQMC C4 CYBER SECURITY DIVISION
Identity Management Branch Head
Phone: (571) 256-8862
Email: [email protected]
DON Privacy Act Program Manager
Phone: (202) 685-6545
Email: [email protected]
STEVE DAUGHETY
DON CIO
Phone: (703) 602-6393
Email: [email protected]
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