Federal Student Aid Conference

Orlando, FL

Session 59

Cyber Security

Karen Sefton

Brian Fuller

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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

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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.

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What Data is At Risk?

Sensitive Data?

Personally Identifiable Information?

Data in the Public Domain?

Privacy Act Data?

SSN?

Account Number?

Address?

Name?

Date of Birth?

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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.

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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)

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Drivers For Protecting PII

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Drivers For Protecting PII

• Responsible Stewardship

• Laws and regulations

governing treatment of PII

– FISMA

• NIST

– OMB

– GLB

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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.

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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

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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

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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 schools are included in the financial institutions definition of GLB

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How Federal Student Aid Protects Sensitive Data - Current State

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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”

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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

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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

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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

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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

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How Federal Student Aid Protects Sensitive Data - On the Horizon

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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

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Developing an Enterprise Security Program at your Institution

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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.”

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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

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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

Drivers of Change

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Drivers of Change

Changing Nature of Threats

External Pressure

Identity TheftInformation is the target

FERPAFISMASarbanes-OxleyData Loss Notification LawsPCI data security standardCustomer Expectations

Defining an Enterprise Security Program

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Defining an ESP

• Governance

• Operations

• Training

• Assessment

• Monitoring & Remediation

It is critical to build a security program, containing repeatable processes, that is integrated into the day-to-day business processes of the organization.

Implementing an Enterprise Security Program in Higher

ED

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Implementing an ESP in Higher ED

• Standards-Based

• Flexible

• User-Driven

• Adaptable

• Simple

• Measurable

Steps to Implementing an Enterprise Security Program

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Steps to Implementing an ESP

1. Secure Senior Management Support

2. Implement Governance Structure

3. Establish Communication Program

4. Develop Inventory

5. Perform Risk Assessments

6. Implement Controls

7. Monitor & Refine

8. Train the Community

Obtaining Support from an Existing Knowledge Base

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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

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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

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National Institute of Standards and Technology (NIST)

• 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

NIST 800-100 – Quick guide to all relevant areas

Establish a common baseline of understanding Read NIST 800-100!

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Key Takeaways

• Build a security program aligned

with business objectives

• Leverage existing security

knowledgebase

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Questions?

We appreciate your feedback and comments Karen Sefton

Phone: 202-377-3111

Email: karen.sefton@ed.gov

6339 S Fiddlers Green Circle Greenwood Village, CO 80126www.bearingpoint.com/securityingovernment

Brian FullerSenior Manager

Tel: +1.720.493.7146E-mail: brian.fuller@bearingpoint.com