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Implementing an Information Security Program

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The basics of implementing an Information Security Program .

The basics of implementing an Information Security Program .

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  • 1. Implementing an Information Security Program Raymond K. Cunningham, Jr. CRM, CA, CIPP University of Illinois Foundation Session TU3-517
  • 2. Security Breaches
    • It is not a matter of if… but when.
  • 3.  
  • 4. Topics to be Discussed
    • Security and Privacy
    • Standards for Information Security
    • Implementing a Security Program
    • The University of Illinois Foundation Security Program
  • 5. Security and Privacy What is the difference?
    • Security is an action and a process - you implement security to insure privacy
    • Security is a strategy, privacy is the outcome
    • Enterprise privacy and security management must be integrated
    • Security maintains confidentiality and privacy
  • 6. Information Security It is not a technical issue
    • Often Security is viewed as a technical issue
    • Many information breaches occur in the paper world
  • 7. Information Privacy It is not a Legal issue
    • Often viewed as a legal issue handed to legal counsel as a compliance issue
    • While many privacy officers report to legal, it is not strictly a legal issue
    • Privacy is a concern of all and should be a priority of any organization
  • 8. Records Managers should be leaders in the Security and Privacy Arena
    • RIM should be central in the security and privacy arena
    • Records Managers possess a better knowledge of the assets to be protected, usage statistics and an understanding of access to records
    • IT manages the machines and software, RIM manages the records throughout the life cycle
  • 9. Standards for Information Security
  • 10. General Trends
    • Information Management Law is moving from the general to the specific
    • What was formerly ethical is now being required by law
    • Penalties are being strengthened and cases of theft/misuse are higher profile
    • The ethics of information management are evolving
  • 11. Security and Privacy
    • Canada – PIPEDA Personal Information and Electronic Documents Act 200
    • EU Directive 95/46/EC
    • US – 38 States now have disclosure laws for the loss of information, based on California 1386
    • Financial Modernization Act 1999 – Gramm Leach Bliley (GLBA)
  • 12. Gramm-Leach-Bliley What is it and why does it matter?
    • Financial Modernization Act 1999
    • Applicable to Financial Institutions
    • Higher education was included in 2003
    • GLBA security provisions are enforced by the FTC and are becoming a basic standard for protection of information in the USA
  • 13. Gramm-Leach-Bliley Act 1999
    • GLBA provides for the protection of personal financial information
    • Records containing financial information are to be protected.
      • Financial Institutions are to make disclosures regarding their privacy policies and release to third parties
      • Criminalizes certain practices of data collection services: obtaining financial and personal information by misrepresenting their right to such information
  • 14. Gramm-Leach-Bliley Act 1999
    • Financial Privacy Rule – governs the collection and disclosure of personal financial information. It applies to those who receive such information.
    • Pretexting Provisions – covers using false pretenses for obtaining personal financial information
    • Safeguards Rule – requires all financial institutions to design, implement and maintain safeguards to protect customer information
  • 15. GLBA - Privacy
    • GLBA protects consumers’ non-public information. Private information includes “personally identifiable financial information”
  • 16. GLBA Pretexting ORGANIZATION AFFILIATE AGENCY
  • 17. GLBA Safeguards Rule
    • The Safeguards Rule requires financial institutions to develop a written information security plan that describes their program to protect customer information.
      • Designate one or more employees to coordinate the safeguards
      • Identify and assess the risks to customer information relevant to the company’s operation
  • 18. GLBA – Safeguards Rule Compliance
    • Select service providers that can maintain appropriate safeguards
    • Evaluate and adjust the program in light of relevant circumstances including changes in business or the results of security testing
    • Customer data stored at any off-site location
  • 19. GLBA – Safeguards Rule Compliance
    • Check references on employees before hiring who have access to customer information
    • Sign a confidentiality agreement or NDA
    • Limiting access to customer information based on business need
    • Develop specific policies for the appropriate use of laptops, PDAs, cell phones
  • 20. GLBA – Safeguards Rule Compliance
    • Confidentiality training is required
    • Encrypting information when it is transmitted
    • Reporting suspicious attempts to obtain customer information
    • Dispose of customer information according to the FTC Disposal Rule
  • 21. Comparison of Legislative Mandates X X X USA Patriot Act X X FOIA X X Gramm-Leach-Bliley X X California Bill 1386 X X X HIPAA X X X X Sarbanes-Oxley Training Data Security and Privacy Records Management Processes and Risk Management Mandate
  • 22. Payment Card Industry (PCI) Digital Security Standard (DSS)
    • Visa, Master Card, Amex have enacted a DSS for merchants
    • This is a direct extension of the GLBA safeguard standards
    • The PCI DSS are over 170 specific standards divided into 12 areas
    • These are very specific for users of payment cards
  • 23. State Personal Information Laws Illinois
    • HB 1633 (PA 94-36) Effective January 1, 2006
    • Personal information is defined as: SSN, driver’s license number or State ID card, account number, credit card number
    • Breach of security should be made in the most expedient time possible without delay
  • 24. Illinois State Law
    • Illinois law more broadly applicable than California statute – data collectors provisions are more broad – includes public and private corporations, universities, financial institutions.
    • Violation of the law is Consumer Fraud under Deceptive Business Practices Act
  • 25. Implementing a Security Program
  • 26. Beginning a Security Program
    • Lay the groundwork – Gain support at the C level
    • Make the case for information security
    • The program is for all information regardless of format, not just information on servers or in record centers
  • 27. Six steps for creating a Security Program
    • Information Asset Inventory
    • Risk Assessment
    • Policy Review
    • Develop Policies and Practices
    • Conduct training
    • Monitoring
  • 28. Asset Management
    • Understand your information assets - inventory
    • Locate and identify what is to be protected
    • Differentiate between the “owner” and “user”
    • Record Retention Schedules – business need or regulatory requirements
  • 29. Asset Classification
    • Assets should be evaluated as to sensitivity and confidentiality, potential liability, intelligence value and criticality to the business
    • Classify assets – Confidential, Proprietary, Internal Use Only, Public
  • 30. Map the Organizational Data Flow
    • Map points of data collection – examine web forms, email collection, call centers, POS, Contests, Surveys, chat rooms, marketing lists
    • How does data move through the system?
    • Is the data held in-house or is storage outsourced?
    • Is any PII collected from outside the US?
  • 31. Risk Assessment
    • What are the risks with your storage practices?
    • What are the physical storage requirements?
    • Are personnel tasked with the protection of the information?
  • 32. Vulnerabilities
    • Recycling – paper, computers, any information storage device
    • Shredding – What are you sending?
    • Terminated employees with access to both servers and physical facilities
    • Off site storage
    • Printing of electronic confidential records
    • Who is tasked with security?
  • 33. Vulnerabilities - Solutions
    • Training – train your employees and tell them what is expected of them NO EXCEPTIONS
    • Recycling – Monitor recycling closely. Have each storage device wiped
    • Watch the trash
    • Shredding – inspect your vendor and examine your in-house shredding, use local shredders
    • Secure physical storage
    • Test your off site vendor
  • 34. Conduct a Policy Review
    • Develop the principles that will guide your strategy
    • Involve stakeholders, senior management and legal – Get Everyone on Board!
    • This is not an IT Problem
    • Review all applicable regulatory requirements particular to your industry
  • 35. Training
    • Training is one of the most often neglected piece of the program, yet it is one of the most important
    • Train your employees prior to exposure to information systems – supply handouts
    • Train employees to report information breaches - contacts
    • Train employees annually on your policies and compliance issues
    • Develop an ethical culture
  • 36. Monitor Compliance
    • Conduct audits of security procedures
    • Review systems annually
    • Conduct incident response drills – convene your incident response team
  • 37. How the University of Illinois Foundation implemented a Security Program
  • 38. What was at stake?
    • Donor information on 700,000 people and corporations, including SSNs, credit card numbers, bank account numbers, medical information and other personal information
    • A loss of this information could seriously compromise our ability to solicit donors during a $2 billion campaign
  • 39. We are all subject to information breaches
  • 40. How the University of Illinois Foundation implemented a program
    • The UIF serves three campuses in Chicago, Champaign-Urbana and Springfield and over 700 users of confidential information
    • Motivating factors: Fear, a review of present practices, audit findings, PCI DSS requirements, regulatory environment
    • In 2004 I began to ask why SSNs were used in fundraising
  • 41. How the University of Illinois Foundation implemented a program
    • In 2005 I secured all stakeholders in agreeing to remove SSNs from the donor database
    • During the summer and fall of 2006 I conducted sessions in information law
    • In March 2007 I certified as an IPP (IAPP)
    • A review of policies and job descriptions showed no one was in charge of security
    • Working with IT we began reviewing assets
    • Training became the core of our program
  • 42. How the University of Illinois Foundation implemented a program
    • Working with all stakeholders we drafted new security requirements, including confidentiality agreements and notice to all donors
    • We lobbied to make security training mandatory before users log into systems
    • We revised security procedures including a revision of our retention schedules
  • 43. Conclusions
  • 44. Ray’s Recommendations for Building and Information Security Program
    • Gain the Support of Senior Management
    • Encourage a culture of confidentiality
    • Have a policy in place and enforce it
    • Be specific on roles within the organization
    • Have mechanisms in place to sign on and sign off users efficiently
    • Train all users before log-on in confidentiality and security
  • 45. Ray’s Recommendations
    • Monitor users
    • Create an incident response group and provide a way for employees to report data loss
    • Tell customers what you are doing with their data
    • Dump SSNs where not needed
    • Monitor Third Party Contracts
  • 46. Ray’s Recommendations
    • Have background checks on hires
    • Integrate security with your retention schedules – have a page for privacy and security inventorying the private information held and showing the access to the information
  • 47.  
  • 48.  
  • 49. Ray’s Recommendations
    • Prepare for information loss through an information breach response group
    • Think of this as similar to the Disaster Response Group
    • Members are typically from IT, HR, Financial, Communications and Records Management
    • Learn from other’s breaches: www.privacyrights.org/ar/ChronDataBreaches.htm
  • 50. Resources
    • International Association of Privacy Professionals IAPP www.privacyassociation.org
    • Kahn, Randolph Privacy Nation 2006
    • ISO 17799 International Organization for Standardization www.iso.org
    • PCI www.pcisecuritystandards.org
  • 51. Contact information
    • Raymond K. Cunningham, Jr.
    • Manager of Records Services
    • University of Illinois Foundation
    • Urbana IL 61801
    • [email_address]
    • 217 244-0658