data protection practices 2008 nsaa it conference nathan abbott, tn joe moore, az doug peterson, nv
TRANSCRIPT
Agenda
• Introduction• Why? Our recent experiences• What? Technology solutions• How else?• Questions
Why…
• Contractor with DMV:– Lost USB Flash drive– Contained names of 109 individuals
• University of Nevada, Reno professor lost a flash drive that contained the names and Social Security numbers of 16,000 incoming freshmen from 2001 to 2007current and former students
Why…
• DMV Audit– Prior to audit--Truck drives through front
of DMV building and steals computer. Contained personal information on 8,700 Nevada residents.
– Prior to audit--Planned to encrypt files and not store on computers
– Audit found information on desktops, laptops, zip drives, USB drives.
– Audit found process of removing personal information from computers didn’t always work as planned. Over 300 files, each with a person’s name, address, and SS#.
Why…
• Arizona #1 in Identity Theft• Newspaper publishes “public”
information• Audit responsibilities require sensitive
data• Agency requests for agreements
– Encroachment on statutory authority
• Public relations nightmare
Why…
• Portable Media– Auditor was in car accident and lost their
thumbdrive
• Nashville Davidson County Election Commission Office– The office was broken into
Why…
• Nashville Davidson County Election Office• Office was broken into on
December 24, 2007• Break-in was not noticed until
December 27, 2007• Two Laptops were some of the
items that were missing
Why…
• It was standard practice for the office to tape to the machine user name and passwords.
• The laptops were using an access database that contained all register voters personal information including their SSN.
Why…
• The office was preparing for the primary election and was in the process of removing the SSN’s from the Access database.
• The street value of the stolen laptops was probably $600 total, but the incident is costing the city millions in Identity Theft Protection.
TRUECRYPT VS ENTRUST
• TRUECRYPT– Partial disk
encryption– Passwords do not
sync– No vendor support– USB encryption– Encryption time 30-
40 minutes– Cost FREE
• ENTRUST– Full disk encryption– Passwords sync
with operating system
– Vendor Support – 1-800 number
– Removable media encryption
– Encryption time 4-8 hours
– Cost $130 per licence
Truecrypt Concerns
• File Restoration
• Key Management
• Administrative Support
• Removable Media Support
• Partial Disk Encryption
Why Did We Choose Truecrypt
• Strategic Plan– Our purpose is to serve the people of
Tennessee by Enhancing effective public policy decisions at all levels of government
• 47-18-2107 TCA Release of personal consumer information– …Unauthorized acquisition of
unencrypted computerized data…
Statutes
• Provide broad access to information– Authorized to review confidential records
without limitation– Agencies required to provide records
• Working papers and audit files are not public information
• Audit exclusions for other Acts, such as HIPPA, FERPA
DCPP
• Whole disk encryption (partition based)
• Boot protection• Pre-Boot authentication• Sector level protection• Administrator / user specific rights• Transparent to users• Minimal administration and user
training
Ironkey
• Always-on military grade data encryption
• No software or drivers to install
• Easy to deploy and use
• Ability to create and manage enforceable policies
• Unique serial numbers
What Technology We Use
• Truecrypt• EFS (windows built in encryption)• Lexar USB drives with encryption
software• Whole disk encryption on Dell laptops
using Wave Embassy Security Center software and hard drive-based encryption
EFS
Advantages:– Free– Easy to implement– 256-bit AES– Easy to backup to network drive (registry
tweak needed to decrypt data as it is copied to network drive)
– Set and forget...sort of
EFS
Disadvantages:– No additional password– Folder based. Auditors can save in
unencrypted folders– 256-bit AES not used in Pre-XP SP1– Certificate expired and some auditors
could not get access to data for a day
Lexar Secure II
Advantages:• Free• Known encryption (AES 256)
Disadvantages:• Not easy for auditors to remember
setup• Uses Vaults—auditors use
unencrypted area
Wave Embassy
• Whole Disk Encryption (hardware based on Dell Latitude, HP, Lenovo)
• Wave Embassy suite is the software front end to where the real work is done—hardware-based encryption
• Used in conjunction with TPM chip
Wave Embassy
Advantages:• 128-bit AES (not as strong as 256-bit
key, but still strong)• Multiple passwords (pre-boot
authentication)• Works with biometrics
Wave Embassy
Disadvantages• Complex to set up (including BIOS
settings)• Multiple passwords• Need to have a Seagate Momentus
FDE.2 HDD which runs at 5400 rpm
Statutes and Policies• Statutes
– NRS 218.870 (“All working papers from an audit are confidential…”)
• Policies– Reinforce and support statutes– Detailed
• Extreme care to ensure confidentialy of information “gained” during audits (more than what is in workpapers)
• Careful with discussions
How…Guidance to Staff
Training• One on one with each person
– Lexar– Wave Embassy
• Periodic staff training– Reinforce statutes– What is confidential, what is not– Examples shown
• Management meetings allow supervisors to reinforce policies and importance
How…Our Policies
• Backup Volume Header– Allows users to restore encryption to
original installation.
• Create an Admin Password– This is to be used in the event someone
forgets their password.
How…Our Policies (Cont.)
• Created standard passwords for users– This is used to ensure password
complexity
• Created standard login procedures– This is used to help the auditors to be
consistent when they login
How…Our Policies (Cont.)
• Removable Media– This policy is to make it clear that
personal thumbdrives are not be used to store confidential data
• Storage of Files– This policy is to make it clear where you
needed to store confidential data
How…Our Policies (Cont.)
• Enforcement– Once a year have security awareness
training– Periodic emails to staff reminding them of
the encryption policies– Unannounced Random Sample
How…Problems
• Auditors were confused about which password to use to log-on to their workstation
• Thumbdrives
• Auditors do not like using passwords for thumbdrives
How…
• Policy• Communicate to auditee/entity
common information• Statutory authority• Security of confidential records• Auditor General policies
– Internet Use and Email acceptable use agreements
– IT policy with address data security– Acknowledgement of state policy
How…
• Determine whether information is confidential or public (may be more restrictive than public records law)
• Confidential– Personal information
• Info which can identify a person
– Sensitive information• Info which may be harmful to the state and its
citizens
• Public information
How…
• Then, ensure that appropriate security measures are applied based on classification of data
• Confidential– Encryption and/or restrictive physical
and/or logical access rights• Store on Office network or encrypted flash
drives• Return original data or store securely
– Never copy confidential data to home computer
How…
– If remote, use VPN and use remote sessions
– Limit access rights on network drives– Use restricted views and coding
techniques for data stored in databases– Determine whether or how much
confidential information must be included in audit documentation
How…
• Use encryption when storing on external storage media (HDs, CDs)– Use secure passwords/phrases
» Minimum of 8 characters» Upper/lower case» Special characters
• Store passwords/phrases securely
• Public Information• No special security precautions• Adhere to professional standards and Office
policy• Can be stored in shared directories
How?
• Document classification assessment and subsequent actions taken
• Archiving and Disposition– Keep only as long as necessary or
required– Ensure confidential data is protected
when archived– Let others involved know about the
confidential nature of the data stored
Questions
Nathan Abbott; [email protected]
Joe Moore; [email protected]
Doug Peterson; [email protected]