Protecting Patient Health Information in the HITECH EraRapid7
The American Healthcare system is getting a complete facelift thanks to incentives to adopt Health Information Technology introduced by the Health Information Technology for Economic and Clinical Health (HITECH) Act. The HITECH Act contains tools for the enforcement of HIPAA regulations, as well as incentives to accelerate the adoption of information systems that reduce costs, gain efficiencies, and ultimately improve patient care while keeping patient health information secure. This paper examines the HITECH Act, the enforcement mechanisms the HITECH Act provides for HIPAA, and the key security challenges healthcare services face in order to protect patient health information as part of becoming HIPAA compliant.
Rapid7 Report: Data Breaches in the Government SectorRapid7
Rapid7, the leading provider of security risk intelligence solutions, analyzed data collected and categorized by the Privacy Rights Clearinghouse Chronology of Data Breaches. Using this data, the company outlined patterns for government data breaches, including year, month, location and breach type patterns. This information and tips for protecting infrastructure can ensure that government IT environments stay protected against malicious attacks and unintended disclosure.
Privacy and Information Security: What Every New Business Needs to KnowThe Capital Network
Reports of data security breaches conjure up images of anonymous computer hackers sitting in a darkened room,
fingers flying over a key board in an effort to hack into a computer system to find valuable information to exploit.
Not long ago, most of us considered these breaches to be infrequent and likely targeted at information much more
commercially unique than the average consumer data stored by most businesses.
Protecting Patient Health Information in the HITECH EraRapid7
The American Healthcare system is getting a complete facelift thanks to incentives to adopt Health Information Technology introduced by the Health Information Technology for Economic and Clinical Health (HITECH) Act. The HITECH Act contains tools for the enforcement of HIPAA regulations, as well as incentives to accelerate the adoption of information systems that reduce costs, gain efficiencies, and ultimately improve patient care while keeping patient health information secure. This paper examines the HITECH Act, the enforcement mechanisms the HITECH Act provides for HIPAA, and the key security challenges healthcare services face in order to protect patient health information as part of becoming HIPAA compliant.
Rapid7 Report: Data Breaches in the Government SectorRapid7
Rapid7, the leading provider of security risk intelligence solutions, analyzed data collected and categorized by the Privacy Rights Clearinghouse Chronology of Data Breaches. Using this data, the company outlined patterns for government data breaches, including year, month, location and breach type patterns. This information and tips for protecting infrastructure can ensure that government IT environments stay protected against malicious attacks and unintended disclosure.
Privacy and Information Security: What Every New Business Needs to KnowThe Capital Network
Reports of data security breaches conjure up images of anonymous computer hackers sitting in a darkened room,
fingers flying over a key board in an effort to hack into a computer system to find valuable information to exploit.
Not long ago, most of us considered these breaches to be infrequent and likely targeted at information much more
commercially unique than the average consumer data stored by most businesses.
Many healthcare organizations assume that patient data, as covered under HIPAA,
is the primary target of hackers. However, cybercriminals operate with the objective of
attaining as much valuable data as possible. This data is usually in the form of
employee HR data like direct deposit, social security and any other information that
would enable identity theft.
Health care providers have become prime targets of cyber criminals, since they hold a treasure trove of irresistible data, including Social Security numbers and medical records (think access to prescription painkillers). As cyber criminals become more sophisticated, medical practices are more vulnerable than ever.
In this webinar "Data Breach: It Can Happen To You," hosted by the Cooperative of American Physicians, Inc. (CAP), viewers will learn:
+ What a data breach is
+ Its economic impact
+ Why the threat is growing
+ Steps to take to protect yourself
+ The must-dos in the event of a breach
Watch the webinar here —> https://youtu.be/mqdMA-UZNy0
About Our Presenters:
Melvin Osswald, Vice President Program Underwriting, NAS Insurance — Ms. Osswald joined NAS in 2002 and specializes in health care, cyber liability, employment practice, directors and officers coverage. Ms. Osswald currently supports NAS’ reinsurance programs and oversees the underwriting and product development of Billing Errors and Omissions, Cyber Liability, Employment Practices Liability, and Directors and Officers programs created to address the new exposures facing health care providers. She has been featured as a guest speaker at various industry conferences addressing the evolving professional liability risks in health care, and served on the Steering Committee of the Southern California Chapter of the Professional Liability Underwriting Society.
Chris Reese, Vice President, Director of Underwriting, NAS Insurance — As part of NAS’ key management team, Ms. Reese provides insurance solutions for clients in the health care industry. She has held leadership positions on both the underwriting and retail broker sides of the business, and has worked in the London market for a reinsurance intermediary. Ms. Reese has been involved with cyber risk insurance for the health care industry since 2004, providing coverage to physicians, medical groups, and integrated delivery systems.
MORE SLIDESHARE PRESENTATIONS
http://www.slideshare.net/capphysicians/presentations
VISIT OUR WEBSITE
http://www.cappphysicians.com
LET'S CONNECT
Twitter: http://www.twitter.com/CAPphysicians
LinkedIn: https://www.linkedin.com/company/cooperative-of-american-physicians-inc-
Facebook: http://www.facebook.com/CooperativeofAmericanPhysiciansInc
Youtube: http://youtube.com/CAPphysicians
Google+: http://www.google.com/+Capphysicians
HIPAA Security Trends and Future ExpectationsPYA, P.C.
PYA Principal Barry Mathis, a former CIO, CTO, senior IT audit manager, and IT risk management consultant, presented at teh TSCPA Health Care Conference. His presentation, “HIPAA Security Trends and Future Expectations” will focuses on:
- Current HIPAA enforcement activities and future developments.
- Case studies that highlight the changing HIPAA landscape.
- Cyber threats that impact covered entities and business associates.
What Is Security Risk Analysis? By: MedSafeMedSafe
What exactly is a Security Risk Analysis? Most practices ask, we deliver. This presentation covers all you should be concerned with. Go to www.MedSafe.com for more information!
Establishing CCPA Compliance in Legacy PeopleSoft SystemsAppsian
July 1st represented the beginning of enforcement for The California Consumer Privacy Act (CCPA.) This could not come at a worse time, as COVID-19 has created a myriad of new data security and compliance risks that are taxing already extended resources.
HCOs need to consider a more holistic and efficient approach to information management based on a strategic data classification program that discovers and controls PHI wherever it is stored.
HEALTHCARE IT: IS YOUR INFORMATION AT RISK? IJNSA Journal
Healthcare Information Technology (IT) has made great advances over the past few years and while these advances have enable healthcare professionals to provide higher quality healthcare to a larger number of individuals it also provides the criminal element more opportunities to access sensitive information, such as patient protected health information (PHI) and Personal identification Information (PII). Having an Information Assurance (IA) programallows for the protection of information and information systems andensures the organization is in compliance with all requires regulations, laws and directive is essential. While most organizations have such a policy in place, often it is inadequate to ensure the proper protection to prevent security breaches. The increase of data breaches in the last few years demonstrates the importance of an effective IA program. To ensure an effective IA policy, the
policy must manage the operational risk, including identifying risks, assessment and mitigation of identified risks and ongoing monitoring to ensure compliance.
Unit 6 Privacy and Data Protection 8 hrTushar Rajput
Right to Privacy and its Legal Framework, The Concept of Privacy, National Legal
Framework for Protecting Privacy, International Legal Framework for Protecting Privacy, Privacy Related Wrongs and Remedies, Data Security, The Concept of Security in Cyberspace, Technological Vulnerabilities, Legal Response to Technological
Vulnerabilities, Security Audit (VA/PT), Data Protection, Data Protection Position in
India, Privacy Policy, Emerging Issues in Data Protection and Privacy, BPOs and
Legal Regime in India, Protect Kids' Privacy Online, Evolving Trends in Data Protection and Information Security
An Overview of the Major Compliance RequirementsDoubleHorn
In this blog, we will explore some of the US government’s compliance standards that are helpful for many federal, state and local agencies while procuring technology and related services.
Many healthcare organizations assume that patient data, as covered under HIPAA,
is the primary target of hackers. However, cybercriminals operate with the objective of
attaining as much valuable data as possible. This data is usually in the form of
employee HR data like direct deposit, social security and any other information that
would enable identity theft.
Health care providers have become prime targets of cyber criminals, since they hold a treasure trove of irresistible data, including Social Security numbers and medical records (think access to prescription painkillers). As cyber criminals become more sophisticated, medical practices are more vulnerable than ever.
In this webinar "Data Breach: It Can Happen To You," hosted by the Cooperative of American Physicians, Inc. (CAP), viewers will learn:
+ What a data breach is
+ Its economic impact
+ Why the threat is growing
+ Steps to take to protect yourself
+ The must-dos in the event of a breach
Watch the webinar here —> https://youtu.be/mqdMA-UZNy0
About Our Presenters:
Melvin Osswald, Vice President Program Underwriting, NAS Insurance — Ms. Osswald joined NAS in 2002 and specializes in health care, cyber liability, employment practice, directors and officers coverage. Ms. Osswald currently supports NAS’ reinsurance programs and oversees the underwriting and product development of Billing Errors and Omissions, Cyber Liability, Employment Practices Liability, and Directors and Officers programs created to address the new exposures facing health care providers. She has been featured as a guest speaker at various industry conferences addressing the evolving professional liability risks in health care, and served on the Steering Committee of the Southern California Chapter of the Professional Liability Underwriting Society.
Chris Reese, Vice President, Director of Underwriting, NAS Insurance — As part of NAS’ key management team, Ms. Reese provides insurance solutions for clients in the health care industry. She has held leadership positions on both the underwriting and retail broker sides of the business, and has worked in the London market for a reinsurance intermediary. Ms. Reese has been involved with cyber risk insurance for the health care industry since 2004, providing coverage to physicians, medical groups, and integrated delivery systems.
MORE SLIDESHARE PRESENTATIONS
http://www.slideshare.net/capphysicians/presentations
VISIT OUR WEBSITE
http://www.cappphysicians.com
LET'S CONNECT
Twitter: http://www.twitter.com/CAPphysicians
LinkedIn: https://www.linkedin.com/company/cooperative-of-american-physicians-inc-
Facebook: http://www.facebook.com/CooperativeofAmericanPhysiciansInc
Youtube: http://youtube.com/CAPphysicians
Google+: http://www.google.com/+Capphysicians
HIPAA Security Trends and Future ExpectationsPYA, P.C.
PYA Principal Barry Mathis, a former CIO, CTO, senior IT audit manager, and IT risk management consultant, presented at teh TSCPA Health Care Conference. His presentation, “HIPAA Security Trends and Future Expectations” will focuses on:
- Current HIPAA enforcement activities and future developments.
- Case studies that highlight the changing HIPAA landscape.
- Cyber threats that impact covered entities and business associates.
What Is Security Risk Analysis? By: MedSafeMedSafe
What exactly is a Security Risk Analysis? Most practices ask, we deliver. This presentation covers all you should be concerned with. Go to www.MedSafe.com for more information!
Establishing CCPA Compliance in Legacy PeopleSoft SystemsAppsian
July 1st represented the beginning of enforcement for The California Consumer Privacy Act (CCPA.) This could not come at a worse time, as COVID-19 has created a myriad of new data security and compliance risks that are taxing already extended resources.
HCOs need to consider a more holistic and efficient approach to information management based on a strategic data classification program that discovers and controls PHI wherever it is stored.
HEALTHCARE IT: IS YOUR INFORMATION AT RISK? IJNSA Journal
Healthcare Information Technology (IT) has made great advances over the past few years and while these advances have enable healthcare professionals to provide higher quality healthcare to a larger number of individuals it also provides the criminal element more opportunities to access sensitive information, such as patient protected health information (PHI) and Personal identification Information (PII). Having an Information Assurance (IA) programallows for the protection of information and information systems andensures the organization is in compliance with all requires regulations, laws and directive is essential. While most organizations have such a policy in place, often it is inadequate to ensure the proper protection to prevent security breaches. The increase of data breaches in the last few years demonstrates the importance of an effective IA program. To ensure an effective IA policy, the
policy must manage the operational risk, including identifying risks, assessment and mitigation of identified risks and ongoing monitoring to ensure compliance.
Unit 6 Privacy and Data Protection 8 hrTushar Rajput
Right to Privacy and its Legal Framework, The Concept of Privacy, National Legal
Framework for Protecting Privacy, International Legal Framework for Protecting Privacy, Privacy Related Wrongs and Remedies, Data Security, The Concept of Security in Cyberspace, Technological Vulnerabilities, Legal Response to Technological
Vulnerabilities, Security Audit (VA/PT), Data Protection, Data Protection Position in
India, Privacy Policy, Emerging Issues in Data Protection and Privacy, BPOs and
Legal Regime in India, Protect Kids' Privacy Online, Evolving Trends in Data Protection and Information Security
An Overview of the Major Compliance RequirementsDoubleHorn
In this blog, we will explore some of the US government’s compliance standards that are helpful for many federal, state and local agencies while procuring technology and related services.
Identity Theft ResponseYou have successfully presented an expaLizbethQuinonez813
Identity Theft Response
You have successfully presented an expanded Mobile Device Management Policy, which was approved by the CEO. He now wants you to work on a response plan for identity theft, which you proposed a few weeks earlier as part of a series of four cybersecurity projects.
The CEO says to you, "The Incident Response Plan will be our company's action plan to recover should the 'worst' occur. In our case, the 'worst' would be a breach of the company's security that could occur through the theft of customers' personally identifiable information, possibly through an individual's mobile device. Such a breach could compromise the integrity of the financial institution's data."
The CEO continues: “It is your responsibility to be fully prepared, and I want you to ask your team some ‘What if’ questions.”
“Specifically, I want you to ask: What if our customer information system is compromised internally by a misguided employee? What do we do? And, What if the system is breached by an external hacker and all our customer records are exfiltrated and/or deleted? How would we respond?”
You know that any stolen identity might be that of an employee and/or the identities within the customer information module, which would affect a large number of accounts. Either way, even the slightest breach would be serious, and not having an approved, executable plan of action would only compound the problem. Any lack of regulatory compliance by the organization could also be brought to light.
The CEO closes by saying, “A comprehensive plan for identity theft response is mandatory, and it will receive a lot of scrutiny from senior leadership. Everyone in the company realizes it is a critical component of our success and continued operation. I’m counting on you to do it well.”
Identity theft is becoming more common as technology continues to advance exponentially. Mobile devices, applications, and email make it more convenient for individuals to access records and financial accounts, but also increase the risk of identity theft.
As the CISO, you will be drafting an incident response plan to address identity theft for your financial organization.
Identity Theft Response is the second of four sequential projects in this course. The final plan will be about 10-12 pages in length. There are 16 steps in this project and it should take about 14 days to complete. Begin with Step 1, where you will identify types of cyberattacks in which personally identifiable information could be vulnerable.Competencies
Your work will be evaluated using the competencies listed below.
· 1.3: Provide sufficient, correctly cited support that substantiates the writer's ideas.
· 2.2: Locate and access sufficient information to investigate the issue or problem.
· 8.4: Design an enterprise cybersecurity incident response plan.
Project 2: Identity Theft Response
Step 1: Identify Potential PII Attacks
Since this project will require an enterprise cybersecurity incident response plan with ...
INCIDENT RESPONSE PLAN FOR A SMALL TO MEDIUM SIZED HOSPITALIJNSA Journal
Most small to medium health care organizations do not have the capability to address cyber incidents within the organization. Those that do are poorly trained and ill equipped. These health care organizations are subject to various laws that address privacy concerns, proper handling of financial information, and Personally Identifiable Information. Currently an IT staff handles responses to these incidents in an Ad Hoc manner. A properly trained, staffed, and equipped Cyber Incident Response Team is needed to quickly respond to these incidents to minimize data loss, and provide forensic data for the purpose of notification, disciplinary action, legal action, and to remove the risk vector. This paper1 will use the proven Incident Command System model used in emergency services to show any sized agency can have an adequate CIRT.
Running head Information security threats 1Information secur.docxwlynn1
Running head: Information security threats 1
Information security threats 7
Information security threats
Khaleem Pasha Mohammad
Campbellsville University
Introduction
The development of technology has been greatly embraced in hospitals, saved innumerable lives, and improved the quality of care provision. Not exclusively has technology changed patients knowledgeable and of their families but further consideration has had a significant impact on the strategy and practices of practitioners. One in every five of the areas that have greatly embraced technology is care data. Technology has helped inside the treatment of care records through the introduction of electronic health records, that's exchange paper records. With the availability of electronic care record (EHR) systems, a nurse can merely check for patients’ allergies, case history, weight, age, and prescription through the press of a button. However, the most quantity as institutions are clasp technology to stay up their health records, there are series of risks associated with these technologies. Since the start of technology inside the upkeep of care records, the care trade has been a primary target for cyber crimes. The motives behind cyber-attacks on care are clear as insurance firms, hospitals, care clinics, and totally different care suppliers keep health records that contain valuable information. The use of America Department of Health and Human Services for Civil Rights has acknowledged that over 100 million people square measure suffering from care data security breach. Gregorian calendar month 2015 was a foul month for electronic data jointly of the most important hacks on health care records on Anthem Blue Cross resulting in over seventy-eight million patients’ health data was taken. The cyber-attack scarf sensitive data that contained social securities, names, and residential addresses of people. Constant year, Premera Blue Cross reported that a cyber-attack has exposed medical information of over eleven million customers. Back in 2011, over 4.9 million health records were taken electronically from Science Application International Corporation. These are few cases of a care data breach with sensitive data falling into the hands of third parties. In guaranteeing that there are privacy and security in care records, bureau insurance mobility and responsibility (HIPPA) is providing legislation that hospital and totally different institutions that handle patient’s data to adopt in guaranteeing that varied security measures are enforced in protecting data.
HIPPA and Security Compliance
As much as institutions are clasp technology in storing care data, it is vital for institutions like HIPPA to regulate these bodies to substantiate that shopper rights are protected. The HIPAA Security Rule provides that electronic records of patients got to be protected in any respect times from any unauthorized access nonetheless the information being at rest or in transit.
Information security principles to the private versus public sector.pdfinfo401595
Information security principles to the private versus public sector
Own information is reserved secure be mention by 60 percent of public sector, compare with
only 48 percent of private sector. Also, an extra dreadful split can found the knowledge of the
ICO existence: 42% of private firms have not heard at all, a percentage essentially improved
before years this be not the case for public sector, wherever only 3 percent be not awake of the
UK’s self-governing ability set up to information privileges the public concern. A lack of
wakefulness, though, does not avoid the best part of private sector firm from have more staff
members keen to in order security related duty, compare a normal of two in public sector
organizations. Amount is not openly comparative to value, it seem.
Private organizations to hold responsive and secret data such as bank and law firm ought to get
these outcomes as wake-up call and chance to study since the public sector. They are, in reality,
the mainly at danger of pain major penalty in case of a violate of the DPA. Seriously, it’s
important to know the steps for civilizing information security. Primary, it’s crucial that
organizations be conscious of information possessions and connected risk. They canister do this
conduct an estimation of this information security system, in exacting the control nearby the in
sequence possessions of the organization. Once these contain been recognized, it is likely to plan
corrective work that cover policy, events and knowledge, employees teaching and
responsiveness, implement it on a constant cycle. It is essential to message that documents and
knowledge only are not enough to pledge a development. They can, though, minimize
information security risk. Staff assurance, from senior administration to the most junior staff, is
key to creation the control and events work. If staff be not complete conscious of new policy and
actions, or are not eager to team up after that no amount of knowledge can stay an organization
in line with the suitable principles and regulations. Information security is not a last intention.
Instead, it is an infinite trip anywhere each one from senior management to check desk engineers
commit to a culture in order to defend own in order from loss, leak and robbery in a way that is
relative to the recognized risks.
Sharing knowledge is a vital component in the enlargement and advancement of our society in a
sustainable and responsible way. Through Open Access, AIU and other directing institutions
throughout the world are tearing down the barriers to access and use research literature. Our
association is interested in the dissemination of go forwards in scientific research fundamental to
the proper operation of a modern society, in words of community awareness, empowerment,
health and wellness, sustainable growth,
Financial progression and best performance of fitness, teaching and other essential
service
This listing includes laws, regulations plus manufacturing r.
The uncontrollable flow of change in technology these days and use of data, information and knowledge is creating a huge challenges in the front of application User and developer both. Data breaches are happening in every sector and every level of all sectors. These challenges are countless starting from operational to strategic and becoming more challengeable day by day as the penetration of Information technology application among the common man is increasing. Therefore the threat is become real. Everybody customers or companies, retailer or stakeholders , distributor or dealer need assurance; from the provider. corporate face up reputational risks among the user at every step. So there is a need to understand the information technology, a frame work or body which can manage , risks and controls. A body or a system of Privacy management system is which can build a frame work for protection of the data and at the same time can maintain , privacy and agreement issues. This can be done by adoption of a scalable risk-based method which can determine what to be secured and how by performing the certain action.
Consumers rely on businesses to keep their personal information safe. Too few of those businesses are actively protecting that data. Here’s what’s gone wrong, and how businesses should be responding. Full blog here: http://bit.ly/1Jtzym5
The Student Data Privacy Manifesto begins a reasonable conversation among parents, education leaders, and technology providers on the future of student data privacy protection and transparency.
Virtual Mentor American Medical Association Journal of Ethi.docxsheronlewthwaite
Virtual Mentor
American Medical Association Journal of Ethics
September 2012, Volume 14, Number 9: 712-719.
STATE OF THE ART AND SCIENCE
Electronic Health Records: Privacy, Confidentiality, and Security
Laurinda B. Harman, PhD, RHIA, Cathy A. Flite, MEd, RHIA, and Kesa Bond, MS,
MA, RHIA, PMP
Health Information Systems: Past and Present
To understand the complexities of the emerging electronic health record system, it is
helpful to know what the health information system has been, is now, and needs to
become. The medical record, either paper-based or electronic, is a communication
tool that supports clinical decision making, coordination of services, evaluation of
the quality and efficacy of care, research, legal protection, education, and
accreditation and regulatory processes. It is the business record of the health care
system, documented in the normal course of its activities. The documentation must
be authenticated and, if it is handwritten, the entries must be legible.
In the past, the medical record was a paper repository of information that was
reviewed or used for clinical, research, administrative, and financial purposes. It was
severely limited in terms of accessibility, available to only one user at a time. The
paper-based record was updated manually, resulting in delays for record completion
that lasted anywhere from 1 to 6 months or more. Most medical record departments
were housed in institutions’ basements because the weight of the paper precluded
other locations. The physician was in control of the care and documentation
processes and authorized the release of information. Patients rarely viewed their
medical records.
A second limitation of the paper-based medical record was the lack of security.
Access was controlled by doors, locks, identification cards, and tedious sign-out
procedures for authorized users. Unauthorized access to patient information triggered
no alerts, nor was it known what information had been viewed.
Today, the primary purpose of the documentation remains the same—support of
patient care. Clinical documentation is often scanned into an electronic system
immediately and is typically completed by the time the patient is discharged. Record
completion times must meet accrediting and regulatory requirements. The electronic
health record is interactive, and there are many stakeholders, reviewers, and users of
the documentation. Because the government is increasingly involved with funding
health care, agencies actively review documentation of care.
The electronic health record (EHR) can be viewed by many users simultaneously and
utilizes a host of information technology tools. Patients routinely review their
electronic medical records and are keeping personal health records (PHR), which
Virtual Mentor, September 2012—Vol 14 www.virtualmentor.org 712
contain clinical documentation about their diagnoses (from the physician or health
care websites).
The.
This report solely belongs to Symantec. Credit is due to all original authors and no financial gain was made from the report, Simply sharing for educational purposes,
The FBI is the lead federal agency for investigating malicious cyber activity by criminals, nation-state adversaries, and terrorists. To fulfill this mission, the FBI often develops resources to enhance operations and collaboration. One such resource is the FBI’s Internet Crime Complaint Center (IC3) which provides the public with a trustworthy and convenient mechanism for reporting information concerning suspected Internet-facilitated criminal activity. At the end of every year, the IC3 collates information collected into an annual report.
Credit is due to all original authors and no financial gain was made from the blog, Simply sharing an interesting story for educational purposes,
This guide aims to help journalists understand their rights at protests and avoid arrest when reporting on these events. It summarizes the legal landscape and provides strategies and tools to help journalists avoid incidents with police and navigate them successfully should they arise. Credit RCFP.Org
Credit is due to all original authors and no financial gain was made from the blog, Simply sharing an interesting story for educational purposes,
Verizon Publishes 2020 Data Breach Investigation Report (DBIR) With Insights From Thousands of Confirmed Breaches. Verizon's 2020 Data Breach Investigations Report (DBIR) is the most extensive yet, with 81 contributing organizations, and more than 32,000 incidents analyzed (of which 3,950 were confirmed breaches). Credit:Verizon
Credit is due to all original authors and no financial gain was made from the report, Simply sharing an interesting story for educational purposes,
A Resource Guide to theU.S. Foreign Corrupt Practices Act
Credit is due to all original authors and no financial gain was made from the report, Simply sharing an interesting story for educational purposes,
The FTC takes in reports from consumers about problems they experience in the marketplace. The reportsare stored in the Consumer Sentinel Network (Sentinel), a secure online database available only to lawenforcement. While the FTC does not intervene in individual consumer disputes, its law enforcementpartners – whether they are down the street, across the nation, or around the world – can use informationin the database to spot trends, identify questionable business practices and targets, and enforce the law.
Credit is due to all original authors and no financial gain was made from the report, Simply sharing an interesting story for educational purposes,
Below is a list of consumer reporting companies updated for 2019.1 Consumer reporting companies collect information and provide reports to other companies about you. These companies use these reports to inform decisions about providing you with credit, employment, residential rental housing, insurance, and in other decision making situations. The list below includes the three nationwide consumer reporting companies and several other reporting companies that focus on certain market areas and consumer segments. The list gives you tips so you can determine which of these companies may be important to you. It also makes it easier for you to take advantage of your legal rights to (1) obtain the information in your consumer reports, and (2) dispute suspected inaccuracies in your reports with companies as needed.
Advisory to Financial Institutions on Illicit Financial Schemes and Methods R...- Mark - Fullbright
Transnational criminal organizations (TCOs), foreign fentanyl suppliers, and Internet purchasers located in the United States engage in the trafficking of fentanyl, fentanyl analogues, and other synthetic opioids and the subsequent laundering of the proceeds from such illegal sales.
The mission of the IC3 is to provide the public with a reliable and convenient reporting mechanism to submit information to the FBI concerning suspected Internet-facilitated criminal activity, and to develop effective alliances with industry partners. Information is analyzed and disseminated for investigative and intelligence purposes, for law enforcement, and for public awareness.
Credit is due to all original authors and no financial gain was made from the report, Simply sharing an interesting story for educational purposes,
This report is built upon analysis of 41,686 security incidents, of which 2,013 were confirmed data breaches. We will take a look at how results are changing (or not) over the years as well as digging into the overall threat landscape and the actors, actions, and assets that are present in breaches. Windows into the most common pairs of threat actions and affected assets also are provided.
The Federal Trade Commission (FTC or Commission) is an independent U.S. law enforcement agency charged with protecting consumers and enhancing competition across broad sectors of the economy. The FTC’s primary legal authority comes from Section 5 of the Federal Trade Commission Act, which prohibits unfair or deceptive practices in the marketplace. The FTC also has authority to enforce a variety of sector specific laws, including the Truth in Lending Act, the CAN-SPAM Act, the Children’s Online Privacy Protection Act, the Equal Credit Opportunity Act, the Fair Credit Reporting Act, the Fair Debt Collection Practices Act, and the Telemarketing and Consumer Fraud and Abuse Prevention Act. This broad authority allows the Commission
to address a wide array of practices affecting consumers, including those that emerge with the development of new technologies and business models.
Sentinel sorts consumer reports into 29 top categories. Appendices B1 – B3 describe the categories,providing details, and three year figures. To reflect marketplace changes, new categories or subcategories are created or deleted over time.The Consumer Sentinel Network Data Book excludes the National Do Not Call Registry. A separate report about these complaint statistics is available at: https://www.ftc.gov/reports/national-do-not-call-registry-data-book-fiscal-year-2018. The Sentinel Data Book also excludes reports about unsolicited commercial email.Consumers can report as much or as little detail as they wish when they file a report. For the Sentinel Data Book graphics, percentages are based on the total number of Sentinel fraud, identity theft, and other report types in 2018 in which consumers provided the information displayed on each chart.Reports to Sentinel sometimes indicate money was lost, and sometimes indicate no money was lost.Often, people make these reports after they experience something problematic in the marketplace,avoid losing any money, and wish to alert others. Except where otherwise stated, numbers are based on reports both from people who indicated a loss and people who did not.Calculations of dollar amounts lost are based on reports in which consumers indicated they lost between $1 and $999,999. Prior to 2017, reported “amount paid” included values of $0 to $999,999.States and Metropolitan Areas are ranked based on the number of reports per 100,000 population.State rankings are based on 2017 U.S. Census population estimates (Annual Estimates of the Resident Population: April 1, 2010 to July 1, 2017). Metropolitan Area rankings are based on 2016 U.S. Census population estimates (Annual Estimates of the Resident Population: April 1, 2010 to July 1, 2016).This Sentinel Data Book identifies Metropolitan Areas (Metropolitan and Micropolitan Statistical Areas)with a population of 100,000 or more except where otherwise noted. Metropolitan areas are defined by Office of Management and Budget Bulletin No. 15-01, “Revised Delineations of Metropolitan Statistical Areas, Micropolitan Statistical Areas, and Combined Statistical Areas, and Guidance on Uses of the Delineations of These Areas” (July 15, 2015). Numbers change over time. The Sentinel Data Book sorts consumer reports by year, based on the date of the consumer’s report. Some data contributors transfer their complaints to Sentinel after the end of the calendar year, and new data providers often contribute reports from prior years. As a result, the total number of reports for 2018 will likely change during the next few months, and totals from previous years may differ from prior Consumer Sentinel Network Data Books. The most up to date information can be found online at ftc.gov/data
A credit score is a three -digit number that predicts how likely you are to pay back a loan on time, based on information from your credit reports.
Company names mentioned herein are the property of, and may be trademarks of, their respective owners and are for educational purposes only.
Company names mentioned herein are the property of, and may be trademarks of, their respective owners and are for educational purposes only. - Medical identity theft has existed in various forms for decades, but it was in 2006 that World Privacy Forum published the first major report about the crime. The report called for medical data breach notification laws and more research about medical identity theft and its impacts. Since that time, medical data breach notification laws have been enacted, and other progress has been made, particularly in the quality of consumer complaint datasets gathered around identity theft, including medical forms of the crime. This report uses new data arising from consumer medical identity theft complaint reporting and medical data breach reporting to analyze and document the geography of medical identity theft and its growth patterns. The report also discusses new aspects of consumer harm resulting from the crime that the data has brought to light
The FTC takes in reports from consumers about problems they experience in the marketplace. The reports are stored in the Consumer Sentinel Network (Sentinel), a secure online database available only to law enforcement. While the FTC does not intervene in individual consumer disputes, its law enforcement partners – whether they are down the street, across the nation, or around the world – can use information in the database to spot trends, identify questionable business practices and targets, and enforce the law.
Since 1997, Sentinel has collected tens of millions of reports from consumers about fraud, identity theft, and other consumer protection topics. During 2017, Sentinel received nearly 2.7 million consumer reports, which the FTC has sorted into 30 top categories. The 2017 Consumer Sentinel Network Data Book (Sentinel Data Book) has a vibrant new look, and a lot more information about what consumers told us last year. You'll know more about how much money people lost in the aggregate, the median amount they paid, and what frauds were most costly. And you'll know much more about complaints of identity theft, fraud, and other types of problems in each state, too. The Sentinel Data Book is based on unverified reports filed by consumers. The data is not based on a consumer survey. Sentinel has a five-year data retention policy, with reports older than five years purged biannually.
This guide addresses the steps to take once a
breach has occured. For advice on implementing a
plan to protect consumers’ personal information, to
prevent breaches and unauthorized access, check
out the FTC’s Protecting Personal Information: A
Guide for Business and Start with Security: A Guide
for Business.
*Company names mentioned herein are the property of, and may be trademarks of, their respective owners and are for educational purposes only.
Consumer Sentinel Network Data Book for January 2016 - December 2016- Mark - Fullbright
FTC Consumer Sentinel Network Law enforcement's source for consumer complaints.
All information, data, and material contained, presented, or provided on is for educational purposes only.
Company names mentioned herein are the property of, and may be trademarks of, their respective owners.
It is not to be construed or intended as providing legal advice.
June 3, 2024 Anti-Semitism Letter Sent to MIT President Kornbluth and MIT Cor...Levi Shapiro
Letter from the Congress of the United States regarding Anti-Semitism sent June 3rd to MIT President Sally Kornbluth, MIT Corp Chair, Mark Gorenberg
Dear Dr. Kornbluth and Mr. Gorenberg,
The US House of Representatives is deeply concerned by ongoing and pervasive acts of antisemitic
harassment and intimidation at the Massachusetts Institute of Technology (MIT). Failing to act decisively to ensure a safe learning environment for all students would be a grave dereliction of your responsibilities as President of MIT and Chair of the MIT Corporation.
This Congress will not stand idly by and allow an environment hostile to Jewish students to persist. The House believes that your institution is in violation of Title VI of the Civil Rights Act, and the inability or
unwillingness to rectify this violation through action requires accountability.
Postsecondary education is a unique opportunity for students to learn and have their ideas and beliefs challenged. However, universities receiving hundreds of millions of federal funds annually have denied
students that opportunity and have been hijacked to become venues for the promotion of terrorism, antisemitic harassment and intimidation, unlawful encampments, and in some cases, assaults and riots.
The House of Representatives will not countenance the use of federal funds to indoctrinate students into hateful, antisemitic, anti-American supporters of terrorism. Investigations into campus antisemitism by the Committee on Education and the Workforce and the Committee on Ways and Means have been expanded into a Congress-wide probe across all relevant jurisdictions to address this national crisis. The undersigned Committees will conduct oversight into the use of federal funds at MIT and its learning environment under authorities granted to each Committee.
• The Committee on Education and the Workforce has been investigating your institution since December 7, 2023. The Committee has broad jurisdiction over postsecondary education, including its compliance with Title VI of the Civil Rights Act, campus safety concerns over disruptions to the learning environment, and the awarding of federal student aid under the Higher Education Act.
• The Committee on Oversight and Accountability is investigating the sources of funding and other support flowing to groups espousing pro-Hamas propaganda and engaged in antisemitic harassment and intimidation of students. The Committee on Oversight and Accountability is the principal oversight committee of the US House of Representatives and has broad authority to investigate “any matter” at “any time” under House Rule X.
• The Committee on Ways and Means has been investigating several universities since November 15, 2023, when the Committee held a hearing entitled From Ivory Towers to Dark Corners: Investigating the Nexus Between Antisemitism, Tax-Exempt Universities, and Terror Financing. The Committee followed the hearing with letters to those institutions on January 10, 202
2024.06.01 Introducing a competency framework for languag learning materials ...Sandy Millin
http://sandymillin.wordpress.com/iateflwebinar2024
Published classroom materials form the basis of syllabuses, drive teacher professional development, and have a potentially huge influence on learners, teachers and education systems. All teachers also create their own materials, whether a few sentences on a blackboard, a highly-structured fully-realised online course, or anything in between. Despite this, the knowledge and skills needed to create effective language learning materials are rarely part of teacher training, and are mostly learnt by trial and error.
Knowledge and skills frameworks, generally called competency frameworks, for ELT teachers, trainers and managers have existed for a few years now. However, until I created one for my MA dissertation, there wasn’t one drawing together what we need to know and do to be able to effectively produce language learning materials.
This webinar will introduce you to my framework, highlighting the key competencies I identified from my research. It will also show how anybody involved in language teaching (any language, not just English!), teacher training, managing schools or developing language learning materials can benefit from using the framework.
Welcome to TechSoup New Member Orientation and Q&A (May 2024).pdfTechSoup
In this webinar you will learn how your organization can access TechSoup's wide variety of product discount and donation programs. From hardware to software, we'll give you a tour of the tools available to help your nonprofit with productivity, collaboration, financial management, donor tracking, security, and more.
Macroeconomics- Movie Location
This will be used as part of your Personal Professional Portfolio once graded.
Objective:
Prepare a presentation or a paper using research, basic comparative analysis, data organization and application of economic information. You will make an informed assessment of an economic climate outside of the United States to accomplish an entertainment industry objective.
A Strategic Approach: GenAI in EducationPeter Windle
Artificial Intelligence (AI) technologies such as Generative AI, Image Generators and Large Language Models have had a dramatic impact on teaching, learning and assessment over the past 18 months. The most immediate threat AI posed was to Academic Integrity with Higher Education Institutes (HEIs) focusing their efforts on combating the use of GenAI in assessment. Guidelines were developed for staff and students, policies put in place too. Innovative educators have forged paths in the use of Generative AI for teaching, learning and assessments leading to pockets of transformation springing up across HEIs, often with little or no top-down guidance, support or direction.
This Gasta posits a strategic approach to integrating AI into HEIs to prepare staff, students and the curriculum for an evolving world and workplace. We will highlight the advantages of working with these technologies beyond the realm of teaching, learning and assessment by considering prompt engineering skills, industry impact, curriculum changes, and the need for staff upskilling. In contrast, not engaging strategically with Generative AI poses risks, including falling behind peers, missed opportunities and failing to ensure our graduates remain employable. The rapid evolution of AI technologies necessitates a proactive and strategic approach if we are to remain relevant.
1. Data Breach Response Checklist
Overview
The U.S. Department of Education established the Privacy Technical Assistance Center (PTAC)
as a “one-stop” resource for education stakeholders to learn about data privacy, confidentiality,
and security practices related to student-level longitudinal data systems. PTAC provides timely
information and updated guidance on privacy, confidentiality, and security practices through a variety
of resources, including training materials and opportunities to receive direct assistance with privacy,
security, and confidentiality of longitudinal data systems. More PTAC information is available on
www.ed.gov/ptac.
Purpose
Many educational agencies and institutions have moved away from paper records toward electronic
data systems and web-based applications to store, process, and deliver education data to internal
customers and external partners. These systems have grown to encompass not only P-12 (prekindergarten through grade 12), but also post-secondary, and workforce data. They contain
significant amounts of personally identifiable information (PII) from education records that must be
appropriately protected and managed.
Educational organizations have a legal and ethical responsibility to protect the privacy and security of
education data, including PII. The Family Educational Rights and Privacy Act (FERPA) protects PII from
education records regardless of whether student records are paper or electronic; however, the best
practices to protect the data do differ depending on the technology used to maintain the records.
Data breaches of electronically-stored data are a growing concern affecting industry, non-profit
organizations, civilian government, and defense organizations. Educational agencies and institutions
at all levels should implement privacy and security best practices targeted to their unique concerns
and data systems. Establishing and implementing a clear data breach response plan outlining
organizational policies and procedures for addressing a potential breach is an essential step in
protecting the privacy of student data. This document provides educational agencies and institutions
with a checklist of critical breach response components and steps to assist them in building a
comprehensive data breach response capability.
Establishing a plan for responding to a data breach, complete with clearly defined roles and
responsibilities, will promote better response coordination and help educational organizations
shorten their incident response time. Prompt response is essential for minimizing the risk of any
further data loss and, therefore, plays an important role in mitigating any negative consequences of
the breach, including potential harm to affected individuals. Efficient incident handling will also help
PTAC-CL, Sep 2012
2. reduce organizational liability associated with late or delayed actions and/or reporting, as required by
applicable federal, State, or local statues.
NOTE: The checklist discussed in this document is meant to be used as a general example illustrating
some current industry best practices in data breach response and mitigation applicable to education
community. This list is not exhaustive and organizations are encouraged to tailor the checklist to
reflect their individual needs and priorities. Further, note that educational agencies and institutions
are responsible for ensuring that their breach response plan addresses all applicable federal, State,
and local data breach notification and other legal requirements. Therefore, we advise that you always
consult with your organization’s legal counsel to determine your organization’s full responsibilities
regarding applicable privacy laws.
What is a Data Breach?
A data breach is any instance in which there is an unauthorized release or access of PII or other
information not suitable for public release. This definition applies regardless of whether an
organization stores and manages its data directly or through a contractor, such as a cloud service
provider. Data breaches can take many forms including
• hackers gaining access to data through a malicious attack;
• lost, stolen, or temporary misplaced equipment (e.g., laptops, mobile phones, portable
thumb drives, etc.);
• employee negligence (e.g., leaving a password list in a publicly accessible location, technical
staff misconfiguring a security service or device, etc.); and
• policy and/or system failure (e.g., a policy that doesn’t require multiple overlapping security
measures—if backup security measures are absent, failure of a single protective system can
leave data vulnerable).
In some cases, an organization may discover that control over PII, medical information, or other
sensitive information has been lost for an unspecified period of time, but there is no evidence that
data have been compromised. In such an instance, unless applicable federal, State, or local data
breach notification laws would define this as constituting a breach, it would be up to the organization
to determine whether to treat the incident as a full-scale breach or as inadequate security practice
requiring immediate correction.
For educational agencies and institutions, breaches resulting in unauthorized access to PII are
especially serious, as the leaked information can be used by criminals to make fraudulent purchases,
obtain loans or establish lines of credit, and even obtain false identification documents. Children’s
data are particularly vulnerable—wrongdoers are often interested in using children’s social security
numbers (SSNs), permanent resident card (green card) serial numbers, naturalization document
control numbers, and other PII to obtain credit or apply for benefits fraudulently, as parents or
affected youth themselves may not be monitoring their credit histories until children are older.
PTAC-CL, Sep 2012
Page 2 of 14
3. Although electronic attacks by hackers and other cyber-criminals are a common cause of data
breaches, other types of breaches occur regularly as well. “Insider threats,” or threats coming from
inside the organization, are also common and often involve employees accidentally, unknowingly, or
maliciously mishandling, exposing, or losing sensitive data. All breaches can be equally dangerous
regardless of the cause, as they leave PII and other sensitive data vulnerable to exploitation. Every
educational agency and institution should, therefore, be prepared to detect and respond to the
eventuality of a breach.
A part of the preparation for an effective breach response involves evaluating your organization’s
legal responsibilities to notify affected parties. Depending on the systems or data that are
compromised, there may be legal requirements regarding notification of data owners and/or other
stakeholders. Most states have some form of data breach notification laws. Federal laws, including,
but not limited to, the Gramm-Leach-Bliley Act, the Federal Trade Commission Act, the Health
Information Technology for Economic and Clinical Health (HITECH) Act, and FERPA, all address the
importance of protecting sensitive student information and may potentially apply in an event of a
breach. These laws vary in their requirements regarding the right of the individual to be notified of
any potential loss or access to their sensitive information. (See Resources section for a reference
to the list of State Security Breach Notification Laws compiled by the National Conference of State
Legislatures.)
While FERPA itself does not contain specific breach notification requirements, it protects the
confidentiality of education records by requiring recordation of each incidence of data disclosure.
As stated in the preamble of the 2008 amendment to the FERPA regulations: “The [U.S.] Department
[of Education] does not have the authority under FERPA to require that agencies or institutions issue
a direct notice to a parent or student upon an unauthorized disclosure of education records. FERPA
only requires that the agency or institution record the disclosure so that a parent or student will
become aware of the disclosure during an inspection of the student’s education record. … FERPA
does not require an educational agency or institution to notify students that information from their
education records was stolen or otherwise subject to an unauthorized release, although it does
require the agency or institution to maintain a record of each disclosure. 34 CFR 99.32(a)(1). In any
case, direct student notification may be advisable if the compromised data includes student SSNs and
other identifying information that could lead to identity theft” (Family Educational Rights and Privacy,
Final Rule, 73 Federal Register 74843-74844 [December 9, 2008]).
It is critical that educational agencies and institutions clearly understand which federal, State, and
local breach notification laws apply to them, and maintain compliance with all the requirements on
data breach response, reporting, and internal and external notification. To be able to fulfill breach
notification requirements quickly and effectively in the event of a breach, each agency should design
and implement a comprehensive data breach response plan. The plan should be kept up-to-date by
conducting regular data threat assessments and by staying abreast of any changes in the relevant
privacy laws.
PTAC-CL, Sep 2012
Page 3 of 14
4. Data Breach Checklist
While FERPA does not contain specific requirements relating to data breach, PTAC offers educational
organizations a breach response checklist to help them prepare for security incidents and data
breaches before they happen. Attacks against computer systems are often targeted at PII, and being
able to detect, respond to, and recover from these incidents as quickly as possible can limit the
amount of damage that such attacks can do. Having a robust data breach response plan, documented
in writing, as part of an overarching incident response program provides an organization the tools
and structure necessary to efficiently assess, manage, and mitigate a breach, while maintaining
compliance with the privacy laws.
Each educational agency and institution is different and faces a unique blend of requirements and
threats, which make a single prescription for data breach response impossible and undesirable.
Instead, we encourage organizations to conduct their own risk assessment to identify potential
threats to their data systems and to sensitive student information. To ensure effective and consistent
incident response, we recommend building your response strategy around the following core
components (for a more in-depth discussion and a list of specific elements within each component,
see section 2.3, NIST special publication 800-61 rev.2):
• Policy―Each educational organization should create a data breach response policy, approved
by the organization’s leadership, that is germane to its environment. The purpose of the policy
is to establish goals and vision for the breach response process. Policy should have a clearly
defined scope (to whom it applies and under what circumstances), and it should include the
definition of a breach, staff roles and responsibilities, standards and metrics (e.g., to enable
prioritization of the incidents), as well as reporting, remediation, and feedback mechanisms.
The policy should be well publicized and made easily available to all personnel whose duties
involve data privacy and security protection.
• Plan―A data breach response plan is a high-level strategy for implementing the data breach
policy. Individual elements of the plan should cover all phases of the incident response,
from reporting the breach and the initial response activities to strategies for notification of
affected parties, to breach response review and remediation process. The plan should identify
the necessary organizational resources and required management support, such as senior
management approval. It is important that the plan is highly tailored to your organization’s
unique context and is in alignment with your organization’s overall mission and goals.
• Procedure―Procedures are derived from the breach response plan and codify specific tasks,
actions, and activities that are a part of the data breach response effort. Procedures are
designed to standardize behavior to ensure that response activities are handled in an efficient,
documented, and repeatable way, while minimizing the introduction of errors. Breach
response procedures should be periodically reviewed and tested in conjunction with other
business continuity and disaster recovery procedures to test their effectiveness and identify
areas for improvement.
PTAC-CL, Sep 2012
Page 4 of 14
5. Response activities are typically fast-paced and stressful. Issues, questions, and decisions may all have
potentially serious consequences on the response effort and the privacy of those affected by the
breach. Therefore, staff and organizational leaders charged with responding to a breach need to be
prepared to make potentially very serious decisions quickly. Establishing a robust response capability
well in advance decreases the pressure on the responders and reduces errors as a result of having
to “make it up as you go.” As a best practice, consider conducting recurring tests, drills, and incident
response exercises to help ensure your organization is prepared to respond to a breach swiftly and
efficiently.
In addition to planning a data breach response, your organization should consider other preparatory
steps as a part of a broader data management strategy, such as conducting regular risk assessments.
These topics, however, are outside the scope of this document, which focuses specifically on the data
breach response process. The remainder of this document is a checklist that incorporates current
industry best practices in privacy and security. The list is tailored to the education community to assist
educational organizations with creating a robust data breach response capability suitable for their
environment. The two-part checklist provides suggestions on what actions to take and key issues to
consider, both in preparation for a breach and after a breach has been detected. It is designed to be
used as a framework to help structure internal data breach response activities, assign staff roles and
responsibilities, and make appropriate policy decisions; it also provides general guidance on what
actions to take in the event of a breach.
PTAC-CL, Sep 2012
Page 5 of 14
6. Before the Breach:
The items in this checklist are the essential building blocks of an effective and efficient data breach response plan. Addressing
these items prior to a data breach incident will help educational agencies and institutions to efficiently and quickly detect and
mitigate data breaches. The list below is not exhaustive and should only be used as a general guide, meant to be expanded
and tailored to your organization’s unique operational security needs.
……
Establish and implement a written data breach response policy. The key steps involve
• incorporating applicable breach notification legal requirements;
• addressing data breach response strategy, goals, and requirements;
• specifying incident handling procedures, strategy for deciding on the course of action in
a given situation, and procedures for communicating with organizational leadership and
outside parties/law enforcement;
• establishing employee expectations in conjunction with Human Resources (HR) policy and/or
employee agreements;
• identifying the incident response team;
• conducting regular reviews of the policy to include any necessary improvements and ensure
that it reflects up-to-date federal, State, and local requirements;
• identifying a team manager who will be in charge of the incident response (with at least one
other person designated to assume authority in the absence of the manager); and
• assigning and establishing team roles and responsibilities, along with specifying access
credentials.
……
Review your information system(s) and data and identify where PII and other sensitive
information resides. This can be done by
• documenting what PII and other sensitive information is maintained by your organization,
where it is stored (including backup storage and archived data), and how it is kept secure;
• conducting regular risk assessments and evaluating privacy threats for your organization, as
well as any contractors, vendors, and other business partners;
• reviewing who is approved for access to PII and/or other sensitive information and checking
user activity status to determine which accounts should be deactivated after a predetermined period of inactivity;
• reviewing separation of duties to help ensure integrity of security checks and balances;
• implementing mitigation controls designed to prevent and detect unauthorized access, theft,
or misuse of PII and/or other sensitive data
• implementing security controls, such as encryption of sensitive data in motion and at rest
(where feasible); and
• regularly reviewing and keeping up-to-date your data destruction policies, to minimize the
risk of data breaches through unauthorized access to archived media or computers that are
no longer in use.
PTAC-CL, Sep 2012
Page 6 of 14
7. ……
Continuously monitor for PII and other sensitive data leakage and loss. This includes
• employing automated tools, like Intrusion Detection/Prevention Systems, next generation
firewalls, and anti-virus and anti-malware tools, to monitor and alert about suspicious or
anomalous activity;
• using Data Loss Prevention solutions to track the movement and use of information within
your system, to detect and prevent the unintentional disclosure of PII and/or other sensitive
data, for both data at rest and data in motion;
• conducting regular searches of the information system and physical storage areas to identify
PII that may be outside of approved areas (e.g., scan your network for policy violations or
occasionally police open areas for PII left unattended on desks);
• conducting internet searches to locate (and, whenever possible, remove) information that is
already in the public domain or visible to the public; and
• periodically testing and checking privacy and information security controls (e.g., through
the use of “real-life” exercises) to validate their effectiveness as part of a risk management
program.
……
Conduct frequent privacy and security awareness trainings as part of an on-going training and
awareness program. This includes
• providing mandatory privacy and information security training on a recurring basis to
all employees, school officials, contractors, and any other staff involved in data-related
activities;
• posting and communicating privacy policies to customers and users (for instance, on the
agency web page or on a bulletin board at the office, through statements inserted in
documents or emails, etc.); and
• clearly defining and making easily accessible processes for reporting privacy incidents
and complaints (depending on the nature of the event, this may include reporting to the
authorities, public, and/or individuals affected).
PTAC-CL, Sep 2012
Page 7 of 14
8. Responding to the Breach:
The following checklist provides best practice recommendations to help educational agencies and institutions create a robust
data breach response plan. The list also makes recommendations regarding critical decision-making activities organizations
commonly face during the breach response. Note that the checklist is not linear; some response activities may happen
concurrently. The checklist is general in nature and should be adapted to meet security needs and legal requirements specific to
your organization. Educational agencies and institutions should always seek legal counsel when planning for and responding to
a data breach, to ensure compliance with all applicable federal, State, and local regulations.
……
Validate the data breach
• Do not assume that every identified incident is actually a breach of PII.
• Examine the initial information and available logs to confirm that a breach has occurred.
• If possible, identify the type of information disclosed and estimate the method of disclosure
(internal/external disclosure, malicious attack, or accidental).
……
Once a breach has been validated, immediately assign an incident manager to be responsible
for the investigation
• Assign a senior level manager, such as the Chief Information Security Officer or an individual
at an equivalent director level position, to serve as an incident manager to coordinate
multiple organizational units and the overall incident response. (Typically, the team manager
is the incident manager; alternatively, the team manager assigns another individual to lead
the response activities.)
• Begin breach response documentation and reporting process.
• Coordinate the flow of information and manage public message about the breach.
……
Assemble incident response team
• Include representatives from management, information technology, legal, public affairs/
media relations, risk management, finance, and audit departments (and possibly HR, for
internal incidents) in the incident response team.
• Immediately determine the status of the breach (on-going, active, or post breach).
• If the breach is active or on-going, take action to prevent further data loss by securing and
blocking unauthorized access to systems/data and preserve evidence for investigation.
• Document all mitigation efforts for later analysis.
• Advise staff who are informed of the breach to keep breach details in confidence until
notified otherwise.
PTAC-CL, Sep 2012
Page 8 of 14
9. ……
Determine the scope and composition of the breach
• If criminal activity is suspected, notify law enforcement and follow any applicable federal,
State, or local legal requirements relating to the notification of law enforcement. (The
decision to involve outside entities, including law enforcement, should generally be made in
consultation with executive leadership and legal counsel.)
• Identify all affected data, machines, and devices.
• Conduct interviews with key personnel and document facts (if criminal activity is suspected,
coordinate these interviews with law enforcement).
• When possible, preserve evidence (backups, images, hardware, etc.) for later forensic
examination. Some best practices for the collection and handling of digital evidence can be
found in the Resources section below.
• Locate, obtain, and preserve (when possible) all written and electronic logs and records
applicable to the breach for examination.
……
Notify the data owners
• Reach out to data owners as soon as possible to notify them about the breach.
• Foster a cooperative relationship between the incident response team and data owners.
• Work collaboratively with data owners to secure sensitive data, mitigate the damage
that may arise from the breach, and determine the root cause(s) of the breach to devise
mitigating strategies and prevent future occurrences.
……
Consider notifying FPCO and seeking technical assistance from PTAC
• Consider notifying Family Policy Compliance Office (FPCO) about the breach. (FERPA does
not require that you notify FPCO of the breach; however, the U.S. Department of Education
considers it a best practice. While FPCO has the discretion under 34 CFR §99.64(b) to
conduct its own investigation of a breach, it will take into consideration an effort to
proactively come into compliance demonstrated by voluntarily notifying FPCO about the
breach.) FPCO can assist educational agencies and institutions by
99 helping to determine the potential for harm resulting from the release of the
information; and
99 assisting with coming into compliance with FERPA.
• After notifying data owners about the breach, consider seeking technical assistance from
PTAC for informal help with security and breach prevention. PTAC can assist educational
agencies and institutions by
99 providing real-word advice and best practices for responding to privacy and security
incidents, notification, and data recovery;
99 assisting technical staff in conducting investigation and fact-finding activities; and
99 helping organizational decision-makers with developing a strategy for incident mitigation
and data recovery.
PTAC-CL, Sep 2012
Page 9 of 14
10. ……
Determine whether to notify the authorities/law enforcement (situation dependent)
• Consult your legal counsel to examine any applicable federal, State, and local breach
reporting requirements to determine which additional authorities or entities must be
notified in order to satisfy compliance requirements.
• Seek involvement of law enforcement when there is a reason to believe that a crime has
been committed or to maintain compliance with federal, State, or local legal requirements
for breach notification.
• In concert with executive leadership and legal counsel, designate a single organizational
representative (typically incident manager) authorized to initiate and/or communicate
breach details to any party, including law enforcement.
……
Decide how to investigate the data breach to ensure that the investigative evidence is
appropriately handled and preserved
• Decide in advance whether you will investigate a potential breach using in-house resources
or an outside service provider.
• Seek advice from your legal counsel on the approved methods for protecting digital
evidence, so that you are prepared and are able to properly preserve and document all
evidence to ensure it can be used in a court of law, if necessary. This requires detailed
recording and following proper collection, handling, storage, custody documentation, and
destruction procedures (if applicable).
• If law enforcement is involved, collaborate with them to help ensure that in-house
investigations do not interfere with law enforcement activities.
• Once investigative activities have been completed, safely store, record, and/or destroy
(where appropriate) all evidence.
• Consider all alternatives to replacing or clearing compromised resources and machines,
including the cost of remediation or rebuilding of the assets to an acceptable security level.
……
Determine whether notification of affected individuals is appropriate and, if so, when and how
to provide such notification
• Determine whether notification is warranted and when it should be made. Executive
leadership at the senior technical and/or administrative level, in coordination with legal
counsel, is the authority that should generally make this decision (for instance, at a
postsecondary institution, Chief Information Officer or delegate, in consultation with the
General Counsel’s Office, may have the right to exert such authority).
• Notify affected individuals whose sensitive information, including PII, has been
compromised, as required by applicable federal, State, and local laws.
• Provide notification in a straightforward and honest manner; avoid evasive or incomplete
notifications.
• If the breach represents a threat to affected individuals’ identity security, consider providing
credit monitoring or identity theft protection services to mitigate the risk of negative
consequences for those affected.
PTAC-CL, Sep 2012
Page 10 of 14
11. • Make every attempt to avoid news of the breach reaching the media before you notify
affected individuals.
• Work closely with public affairs or media relations staff to craft the appropriate media
notification (mailings, emails, phone calls, etc.).
……
Collect and review any breach response documentation and analyses reports
• Assess the data breach to determine the probable cause(s) and minimize the risk of future
occurrence.
• Address and/or mitigate the cause(s) of the data breach.
• Solicit feedback from the responders and any affected entities.
• Review breach response activities and feedback from involved parties to determine response
effectiveness.
• Make necessary modifications to your breach response strategy to improve the response
process.
• Enhance and modify your information security and training programs, which includes
developing countermeasures to mitigate and remediate pervious breaches; lessons learned
must be integrated so that past breaches do not reoccur.
PTAC-CL, Sep 2012
Page 11 of 14
12. Additional Resources
References below provide best practice recommendations regarding data breach response process
and tips on general information systems security. These resources include federal regulations,
organizational web pages, and guidance documents prepared by third-party security experts. Please
note that private sector resources (marked accordingly) should not be relied upon for legal guidance
regarding data breach response. The U.S. Department of Education does not provide endorsement
for private-sector resources; it simply refers them to readers for consideration.
• Congressional Research Service, Federal Information Security and Data Breach Notification
Laws (2010): www.fas.org/sgp/crs/secrecy/RL34120.pdf
• DigiCert, Protecting the Security of Education Records (2009) (private sector resource):
www.digicert.com/news/2009-10-13-digicert-education-white-paper.pdf
• EDUCASE, Library—Data Breach resources (private sector resource):
www.educause.edu/library/data-breach
• Federal Trade Commission, Dealing With A Data Breach:
www.ftc.gov/bcp/edu/microsites/idtheft/business/data-breach.html
• FERPA regulations amendment (2011):
www.gpo.gov/fdsys/pkg/FR-2011-12-02/pdf/2011-30683.pdf
• FERPA regulations amendment (2008):
www.ed.gov/legislation/FedRegister/finrule/2008-4/120908a.pdf
• National Conference of State Legislatures, State Breach Notification Laws (last updated
February 6, 2012):
www.ncsl.org/issues-research/telecom/security-breach-notification-laws.aspx
• National Institute of Standards and Technology (NIST), NIST SP 800-61, Computer Security
Incident Handling Guide (2012):
http://csrc.nist.gov/publications/drafts/800-61-rev2/draft-sp800-61rev2.pdf
• National Institute of Standards and Technology (NIST), NIST SP 800-30, Guide for
Conducting Risk Assessments (2011) (initial public draft):
http://csrc.nist.gov/publications/drafts/800-30-rev1/SP800-30-Rev1-ipd.pdf
• National Institute of Standards and Technology (NIST), FIPS Pub 199, Standards for Security
Categorization of Federal Information and Information Systems (2004):
http://csrc.nist.gov/publications/fips/fips199/FIPS-PUB-199-final.pdf
• National Institute of Standards and Technology (NIST), NIST SP 800-30, Risk Management
Guide for Information Technology Systems (2002):
http://csrc.nist.gov/publications/nistpubs/800-30/sp800-30.pdf
• U.S. Department of Education, Departmental Directive OM:6-107, External Breach
Notification Policy and Plan (2008):
www.ed.gov/policy/gen/leg/foia/acsom6107.pdf
• U.S. Department of Education, Family Policy Compliance Office (FPCO):
www.ed.gov/policy/gen/guid/fpco/index.html
PTAC-CL, Sep 2012
Page 12 of 14
13. • U.S. Department of Education, Privacy Technical Assistance Center (PTAC):
www.ed.gov/ptac/
• U.S. Department of Justice, Electronic Crime Scene Investigation: A Guide for First
Responders, Second Edition (2008): www.ncjrs.gov/pdffiles1/nij/219941.pdf
• U.S. Department of Justice, Incident Response Procedures for Data Breaches Involving
Personally Identifiable Information, Version 1.6 (2008):
www.justice.gov/opcl/breach-procedures.pdf
PTAC-CL, Sep 2012
Page 13 of 14
14. Glossary
Data Loss Prevention solutions encompass a spectrum of software and hardware solutions,
employed to protect sensitive data at rest and in motion from being stored, moved, or accessed in an
unauthorized manner through the application of identification and filtering mechanisms.
Data owner is a term that can be used in many ways, depending on the context. For the purposes of
this document, it is used to refer to an individual within an organization who is in direct control of the
data and is responsible for authorizing access to or dissemination, integrity, and accuracy of the data.
Education records means records directly related to a student and maintained by an educational
agency or institution, or by a party acting on behalf of the agency or institution. For more information,
see the Family Educational Rights and Privacy Act regulations, 34 CFR §99.3.
Encryption is the process of transforming information using a cryptographic algorithm (called a cipher)
to make it unreadable to anyone except those possessing special knowledge, usually referred to as an
encryption/decryption key.
Incident manager is a key leadership role within an incident response process, typically filled by a
senior level manager. The incident manager activates the incident response team, appropriates the
necessary resources to investigate and manage the incident, and acts as a bridge between executive
leadership (e.g., institution president, superintendent, provost, chancellor, principal, etc.), legal counsel,
and information technology and law enforcement, when appropriate.
Incident response plan is a document, which establishes specific procedures for detecting, responding,
mitigating, and recovering from incidents affecting organization’s information systems.
Incident response team is a group of key people within an organization who are responsible for
responding to computer security-related incidents.
Intrusion Detection/Prevention System is a software and hardware system, which automates
monitoring of computer systems and networks for indications of security violations.
Personally identifiable information (PII) from education records includes information, such as a
student’s name or identification number, that can be used to distinguish or trace an individual’s identity
either directly or indirectly through linkages with other information. See Family Educational Rights and
Privacy Act regulations, 34 CFR §99.3, for a complete definition of PII specific to education records and
for examples of other data elements that are defined to constitute PII.
Sensitive data are data that carry the risk for adverse effects from an unauthorized or inadvertent
disclosure. This includes any negative or unwanted effects experienced by an individual whose
personally identifiable information (PII) from education records was the subject of a loss of
confidentiality that may be socially, physically, or financially damaging, as well as any adverse effects
experienced by the organization that maintains the PII. See Guide to Protecting the Confidentiality of
Personally Identifiable Information (PII), 2010, NIST Special Publication 800-122, for more information.
PTAC-CL, Sep 2012
Page 14 of 14