Data%20Privacy%20and%20Security:%20Sort%20of%20Urgency

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Data Privacy and Security Sort of Urgency

• Praveen Panchal, CIO

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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
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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
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Implications

• Furious Constituents
• Negative Publicity
• Tarnished Reputation
• Public Embarrassment
• Investigations
• Lawsuits, Fines and Penalties
• Financial Losses
• Waste of Valuable Resources

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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.
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Technological Solutions

• Perimeter and Interior Firewalls
• Virtual Private Network
• Intrusion Detection and Prevention System
• Enterprise Directory
• Filtering Technology
• Network Behavior Analysis

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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.

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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

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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

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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

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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)

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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)

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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

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Questions?
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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.