Data Privacy and Security: Sort of Urgency Praveen Panchal, CIO
Why?...Because • Within little over one year there were 237 reported security breaches… • Compromising more than 97 million records containing personal information • 83 or 35% incidents involved High Ed institutions Source – Privacy Rights Clearinghouse
Changing Nature of Threats • Early threats were targeted on servers and computers connected to network to destroy them or use them to launch subsequent attacks • Now threats are no longer operating systems, networks, or control of machines but rather… • Personal data about the users on these machines for profit “Attackers are increasingly seeking financial gain rather than mere notoriety. During the past year we have seen a significant decrease in the number of large scale global virus outbreaks and, instead, are observing that attackers are moving towards smaller, more focused attacks” Vincent Weafer – Senior Director at Symantec Corporation
Implications • Furious Constituents • Negative Publicity • Tarnished Reputation • Public Embarrassment • Investigations • Lawsuits, Fines and Penalties • Financial Losses • Waste of Valuable Resources
What we can do? • Implement Technological Solutions • Adopt “Soft” IT Security Approaches • Change the Campus Culture • Combination of all the above Note: All the points addressed here have been adopted as an activity in the CUNY Security Plan.
Technological Solutions • Perimeter and Interior Firewalls • Virtual Private Network • Intrusion Detection and Prevention System • Enterprise Directory • Filtering Technology • Network Behavior Analysis
“Soft” IT Security Approach • Planning Develop well-thought-out comprehensive IT security plan, risk assessment and IT security implementation strategy which is standards-based, flexible, mission-driven, adaptable, simple and measurable • Implementation Implement IT security plan and make it intrinsic part of day-to-day operations of the campus • Auditing Periodically examine, assess and analyze security of central and local applications, networks, and data • Policies and Procedures Develop policies and procedures for data backup, authentication and authorization, physical security, employee responsibilities, disaster recovery, formal incident-response procedures, etc.
Change the Campus Culture • Invigorate Senior Management Interest and Support in IT Security (“Buck Stops Here!”) Garner “political” support which is critical to provide credibility to IT security program implementation • Define IT Security Functions (“Who Does What?”) Implement governance structure to institute CUNY mandated policies and procedures and empower Internet Security Officer (ISO) to implement these policies and procedures • Training and Awareness (“Think IT Security First!”) Provide training on current techniques, security awareness programs, change in institutional culture to respect for private information of our constituents and restrict the distribution of sensitive data • Maintain Assets Inventory (“What We Got?”) Identify and classify assets that require protection through classifications such as regulatory compliance, confidential, internal and public
CUNY Security Initiatives • Security Communication and Training Seminars and Workshops - Wireless Technology, Intrusion Management, Vulnerability Management and Microsoft Security • Security Policy, Advisement and Procedures Security alerts and advisories - Phishing, Email/Passwords, Private Information and Spam Email Security procedure authored and adopted for Breach Reporting Security policies (18) authored and adopted - Access to Sensitive or Non-Public University Data/Systems, Authentication, User IDs, Severance of Computer Accounts, Review of Computer Access, Student/Part-time Employees/Contractor User IDs, Passwords, Privileged Access, Mobile Devices, Incident Response and Reporting, Change of Data in Permanent Records, Centralized Data Management, Grade Changes, Changes in Information Systems, Vulnerability Assessments, Web Accessible Data, Management Responsibility, Information Security Policy Governance
CUNY Security Initiatives • Security Incident Response Reporting and notification protocols and consistent follow through their execution • Information Security Strategy University Security Plan oriented towards providing security services and increased capabilities to benefit the Colleges and the University while maintaining the collaborative approach with CUNY constituents • E-Signature Initiative Initiative to gather input from University and College constituents to assess and recommend e-Signature opportunities for consideration during ERP implementation
CUNY Security Initiatives • Data Warehouse Formal review and approval process for vetting all requests to access the data warehouse (forms are published at security.cuny.edu) • Security Technology Selection Intrusion Management Program - Network behavior analysis appliances from Mazu Networks and signature-based intrusion detection appliances from Symantec • Assessments CIS Portal Vulnerability Assessment, University Web Services Assessment and external vendor (Liveperson.com) • Security Integration – CIS Projects EDS Credit Card Processing/PCI Compliance, Enterprise Directory, Crystal Developer/Enterprise, CO LAN, Portal Authentication/Identity conflicts, Wireless Network Architecture, email Architecture, and VPN/firewall port requests (approver)
Information Security Laws and Regulations • Family Educational Rights and Privacy Act (FERPA) • Gramm-Leach-Bliley Act (GLBA) • Health Insurance Portability and Accountability Act (HIPAA) • Communications Assistance for Law Enforcement Act (CALEA) • Payment Card Industry Data Security Standard (PCIDSS) • Federal Information Security Management Act (FISMA)
Conclusion • Senior-Level Support and Involvement • Enterprise view of Information Security rather than just specific department • Alignment of Technologies, Processes and Campus Culture with Information Security • Flexible Information Security efforts to more easily adapt to new threats as they emerge
Thank You! Acknowledgement: This presentation was made possible with the help of Mr. Carl Cammarata, CUNY Chief Information Security Officer and selected articles from Educause Review, September/October 2006.