Federal Student Aid Conference

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Federal Student Aid Conference

• Orlando, FL

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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 Companys 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?
Name?
Data in the Public Domain?
Account Number?
Privacy Act Data?
Sensitive Data?
Date of Birth?
Personally Identifiable Information?
Address?
SSN?
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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

• Were an academic institution dependent upon the
  open and free exchange of ideas. Security
  requirements will stifle our creativity!
• We just dont 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 cant 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

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Drivers of Change
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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
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Defining an Enterprise Security Program
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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

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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

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Steps to Implementing an Enterprise Security
Program
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Steps to Implementing an ESP

• Secure Senior Management Support
• Implement Governance Structure
• Establish Communication Program
• Develop Inventory
• Perform Risk Assessments
• Implement Controls
• Monitor Refine
• Train the Community

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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)
NIST 800-100 Quick guide to all relevant areas

• 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

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 [phone]
• Email
  karen.sefton_at_ed.gov