Protecting Sensitive Data in Federal Student Aid Programs

1. Session 59 Cyber Security Karen Sefton Brian Fuller

2. Cyber Security at Federal Student Aid • How Federal Student Aid Protects Sensitive Data – Current State • How Federal Student Aid Protects Sensitive Data – On the Horizon • Developing an Enterprise Security Program at your Institution

3. Recent Press Shows Consequences of Security Breaches ChoicePoint Settles Data Security Breach Charges; to Pay $10 Million in Civil Penalties, $5 Million for Consumer Redress At Least 800 Cases of Identity Theft Arose From Company’s Data Breach MasterCard International Identifies Security Breach at CardSystems Solutions, A Third Party Processor of Payment Card Data Purchase, NY, June 17, 2005 - MasterCard International reported today that it is notifying its member financial institutions of a breach of payment card data, which potentially exposed more than 40 million cards of all brands to fraud, of which approximately 13.9 million are MasterCard-branded cards. Federal student aid site exposes borrowers’ data. The U.S. Department of Education has disabled the online payment feature for its Federal Student Aid site, following a security breach that could affect up to 21,000 borrowers.

4. What Data is At Risk? Name? Data in the Public Domain? Account Number? Privacy Act Data? Sensitive Data? Date of Birth? Personally Identifiable Information? Address? SSN?

5. Data Security Focus is PII • Personally Identifiable Information or Personally Identifying Information (PII) • PII definitions vary • Common definition: PII is any piece of information which can potentially be used to uniquely identify, contact, or locate a single person. PII can be used to expose individuals to identity theft, robbery, murder, or other crimes.

6. Federal Student Aid Systems Containing PII • Common Origination and Disbursement (COD) • Central Processing System (CPS) • Free Application for Federal Student Aid (FAFSA) • Direct Loan Servicing System (DLSS) • National Student Loan Data System (NSLDS) • Conditional Disability Tracking System (CDDTS) • Debt Management Collection System (DMCS) • Direct Loan Consolidation System (DLCS) • Ombudsman Case Tracking System (OCTS)

7. Drivers For Protecting PII

8. Drivers For Protecting PII • Responsible Stewardship • Laws and regulations governing treatment of PII • FISMA • NIST • OMB • GLB

9. Responsible Stewardship • Government has a responsibility to protect the privacy of the very personal data it collects from its citizens • Contractors and Trading Partners share the responsibility to protect citizen data.

10. Laws and Regulations Federal Information Security Management Act of 2002- FISMA • Bolsters computer and network security within the Federal Government and affiliated parties, such as government contractors, by mandating yearly audits. • Directs compliance with NIST standards • Requires all federal agencies to report security incidents to the federal incident response center (US Cert) at the Department of Homeland Security

11. Laws and Regulations OMB Circulars and Memoranda New directives resulting from Veterans Affairs laptop breach. All government agencies required to: • conduct assessments of their mobile data and network remote-access provisions to ensure full compliance with NIST regulations • report all suspected or confirmed security incidents to US Cert within one hour of discovering the incident • establish core management group to respond to loss of PII to mitigate the risk of identity theft

12. Laws and Regulations Gramm-Leach Bliley Act • Includes provisions to protect consumers’ personal financial information held by financial institutions • Defines financial institutions as “companies providing many types of financial products and services to consumers including lending, brokering or servicing any type of consumer loan, transferring or safeguarding money, preparing individual tax returns, providing financial advice or credit counseling, providing residential real estate settlement services, collecting consumer debts and an array of other activities • Post-secondary institutions are financial institutions under GLB

13. How Federal Student Aid Protects Sensitive Data - Current State

14. Current State – Enterprise Controls • Contractual requirements for internal controls, incident reporting, corrective action • Security Operations Centers within data centers provides intrusion detection, reporting, and vulnerability assessments • Self-assessments and government audits • Policies and procedures for Federal Student Aid employees and partners accessing application systems • Strong controls around application user access and “need to know”

15. Current State – Data at Rest • Laptops and other portable devices • All PII data must be stored on encrypted thumb drives, password protected files on CD ROM/DVD when employees must access PII to accomplish their work • Laptops must accompany the employee on travel in carry-on baggage • Hardcopy documents and reports • Ready access to shredders and secure disposal containers in the workplace • Policies require safeguarding reports transported off-site; i.e. no PII in checked baggage

16. Current State – Data in Motion Email Policies discourage emailing PII. If necessary to conduct business, emailed text and attachments must be password protected or encrypted

17. Current State – Data in Motion • Data exchanges with schools, lenders, Guaranty Agencies: • encrypted tapes • electronic transmissions over dedicated or secure lines • Tapes must be double-packaged for transit and degaussed after use

18. Current State – Data in Motion • Tapes will not be an option after mid-2007 • NSLDS data submissions via SAIG • GA Default assignments via SAIG beginning December 2006 • Credit Bureau updates via VPN beginning fall 2006 • Private Collection Agency (PCA) updates via VPN

19. How Federal Student Aid Protects Sensitive Data - On the Horizon

20. On the Horizon • Eliminating SSN in borrower-facing products • Billing invoices, disclosures, and other correspondence • Web screens • Assessing more frequently the universe of internal and external users of systems containing PII • Tightening access for the “student to administrator” relationship in NSLDS, CPS, COD • Increased rigor in activating/deactivating users to ensure only system and data access required by job duties • More communication with exchange partners and contacts, including DPAs, on their challenges and ideas for improvement

21. Security in Higher Education: The Excuses “We’re an academic institution dependent upon the open and free exchange of ideas. Security requirements will stifle our creativity!” “We just don’t have the money to protect our IT Investments.”

22. No Choice but to Pay Attention • These were the same arguments made by the Department of Energy, as their nuclear secrets were walking out of our national labs. • Given the vast amount of Personally Identifiable Information (PII) maintained by the higher Education community, this industry can’t afford to ignore information security. • Recent exposures underscore the fact that the higher Education community is not immune: • Theft of laptops from countless universities • PII exposures throughout the industry and government • Exposure of data at Federal Student Aid website

23. Agenda • Drivers of Change • Defining an Enterprise Security Program (ESP) • Implementing an Enterprise Security Program • Steps to Implementing an Enterprise Security Program • Obtaining Support from Existing Industry Knowledge Base

24. Drivers of Change

25. Drivers of Change Identity Theft Information is the target Changing Nature of Threats FERPA FISMA Sarbanes-Oxley Data Loss Notification Laws PCI data security standard Customer Expectations External Pressure

26. Defining an Enterprise Security Program

27. Defining an ESP It is critical to build a security program, containing repeatable processes, that is integrated into the day-to-day business processes of the organization. • Governance • Operations • Training • Assessment • Monitoring & Remediation

28. Implementing an Enterprise Security Program in Higher ED

29. Implementing an ESP in Higher ED • Standards-Based • Flexible • User-Driven • Adaptable • Simple • Measurable

30. Steps to Implementing an Enterprise Security Program

31. Steps to Implementing an ESP • Secure Senior Management Support • Implement Governance Structure • Establish Communication Program • Develop Inventory • Perform Risk Assessments • Implement Controls • Monitor & Refine

32. Obtaining Support from an Existing Knowledge Base

33. Obtaining Support from Existing Knowledge Base • EDUCAUSE/ECAR • DISA (Configuration Standards) • FISMA • NIST Documentation • Publications/Associations • Government Computer News • Federal Computer Week • INFOWEEK • SecurityFocus.com • SANS.ORG

34. National Institute of Standards and Technology (NIST) • Mandated by Congress to provide guidance in protecting government IT assets and data • Provides security standards and guidelines that support an enterprise-wide risk management process • Plays an integrated part of agencies’ overall security

35. Info Security Governance System Development Lifestyle Awareness and Training Capital Planning Interconnecting Systems Performance Measures Security Planning Contingency Planning Risk Management Certification and Accreditation Security Services & Acquisition Incident Response Configuration Management National Institute of Standards and Technology (NIST) NIST 800-100 – Quick guide to all relevant areas Establish a common baseline of understanding Read NIST 800-100!

36. Key Takeaways • Build a security program aligned with business objectives • Leverage existing security knowledgebase

37. Questions? We appreciate your feedback and comments Name: Karen Sefton Phone: 202-377-3111 Email: karen.sefton@ed.gov Name: Brian Fuller Phone: 720-493-7146 Email: brian.fuller@bearingpoint.com