www.evalid8.com identity theft… …or a lack of management a 50,000 foot technology view of this...
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www.evalid8.com
Identity Theft…
…or a Lack of ManagementA 50,000 Foot Technology View of this Business Tsunami
Maryland Chamber of Commerce Conference 2007Cambridge, MD
Presented by:
Brian Dilley - President / Founder eValid8 CorporationCISA / CGEIT / MBA Accredited Auditor
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Agenda
Introduction Legal Precedent Snap Shot Technology Solutions Independent Validation Logical Solutions Physical Solutions What it is going to Cost YOU! Frontline Report Open Mic
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Introduction
Mr. Brian Dilley - Your Speaker President
Certified Information Systems Auditor Accredited Mortgage Bankers PKI Auditor Member – Information Systems Audit and Control Association
(ISACA) Member – ISACA Maryland Chapter Board Member – Howard County Chamber of Commerce
24 years of Experience Cryptographer, IT Security Specialist, PKI Expert Active PKI Internal / External auditing activities FISMA SP 800-53 Assessor Identity Management – Global / Federal / State / Commercial IRS Privacy SME
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Legal Precedent
Revised TJX Settlement To Offer Customers Vouchers Or ChecksAfter a federal judge raised concerns about a proposed TJX settlement stemming from an intrusion into its systems that compromised 45.7 million credit and debit card numbers, the deal has been revised to offer customers a choice of a $30 store voucher or a $15 check, according to this Boston Globe article. The company has estimated that it expects breach-related costs of about $256 million. The story indicates that the litigation outcome could set a precedent ($5.00 per record) for other similar breach-related cases.
LATEST NEWS IS THAT THE BREACH COULD EXCEED 94 million CREDIT CARDS – FINES WILL INCREASE
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Snap Shot
Maryland Personal Information Protection Act 8 Sections
14-3501 - Definitions 14-3502 - Customer Obligations 14-3503 - Protections 14-3504 - Breach 14-3505 - Provision 14-3506 - Notice 14-3507 - Business Affiliate 14-3508 - Violation
Good News (yada yada yada …If you comply with GLBA, Federal Fair & Accurate Transaction Act,
Federal Interagency Guidelines Establishing Information Security Standards, Federal Interagency Guidance on Response Programs for Unauthorized Access to Customer Information and Customer Notice you meet the intent of SB 194 and are covered…what analysis have you conducted ?????
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Technology Solutions
Encryption In transit (electronic or physical) In storage (long or short term) eMail, Documents, Tokens, Biometrics, RealID, HSPD12, PKI, Strong
Authentication – all based on cryptography and/or digital certificates
Authorized Access Permissions and Rights Vetting Permissions / Issuing IDs
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More Technology
VPNs Dedicated Lines Encryption Session Termination SSH / Credential logons
Algorithms AES, SHA-1 or greater – RC4 can be beaten SSL / TLS HTTPS
Firewalls Ports & Protocols Only open what is needed
Logs Audit, Review, Report, Investigate
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Technology Statements
Logon Warning Banners Allows prosecution, Due notice has been given
Privacy Statement Website – Do you have one?
Retention Policy – See Vangel Paper http://www.vangelpaper.com/laws/records.php Period required by contracts or law Access / Authorization / Documentation Destruction SHRED! SHRED! SHRED! Removal, minimize what is to be stored & retained
IT Security and Privacy Protection touches every business sector today
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Organization IT Plans
IT Documents & Plans Privacy Statement System Security Plan Business Continuity Plans Backup / Archive Plans Retention Policies Destruction / Disposal Policy Transmission / Transportation Policy User Policy / Authentications Independent Audits / Assessments Plan of Action & Milestones
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Controls
Technical, Logical, Physical All families of protection come into play Comprehensive Plan Implementation of Plan 3rd Party Validation of Plan - eValidated™
Physical Controls Gates, Guns, Guards, Doors, & Locks,
If you have those then the hard work begins Log Books
Documentation of all events, prompt reporting Training Awareness
Dust the cobwebs off All professionals go to training to keep their skills up
Accountability Personnel / Management
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Independent Validation
HAVING NO PLANS IS NOT BETTER Due diligence prevents lawsuits based upon
negligence LAWYERS HAVE IDENTIFIED THIS AS ANOTHER
ABESTOS HEYDAY FOR THEIR INDUSTRYThis time all businesses are in play – IT crosses all
industries
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Certified IT Auditors
Right Profession for the Right Engagement ISACA – ANSI Accredited
CISA CISM
Trained Professionals Security and Privacy separation of duties provides
management with a check and balance
Global Recognized Professionals Continuing Education Units
http://www.isaca.org
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What it is Going to Cost You!
Penalties Applicable Laws – Varies, but are accumulative
Credit Monitoring Cost $100 * 100K User Database = $10,000,000
Notification Cost $0.41 * 100K User Database = $41,000
Required improvements $5,000 - $100,000,000
Legal Defenses, Seniors IT Professionals
This is for one minor database being lost!
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More $$$$$$$$$$$$$$$$$$
Lawsuits Not only from individuals, but companies that have
entrusted their information to you The sky is the limit – Tort Law prevails
Trained Professionals Over $100K per year, per professional – local business level U.S. Government pays over $250K per year, per
professional Conservative Estimate, lets assume 400,000 specialists
$100,000,000,000 per year Based on 3,000,000 Federal (Non-DoD) employees by the
Census Bureau (2005) i.e. DHS employs over 800K employees as of 2006
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More $$$$$$$$$$$$$$$$$$
Business against Business VISA, MasterCard, American Express Healthcare Privacy Information retained
Consumers against Business Clients
Lawyer growth industry This will be an emerging trend for litigation and
restitutions
Privacy tied to security solutions Legal Ramifications on Two Fronts
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Frontline Report
Old practices are what makes it work Watching, all the time Awareness improves behavior, improves response
times Accountability and Responsibility Independent Assessments – Regular basis
Technology Part of the solution Scales Provides Strong protections / authentication / logging Electronic Non-Repudiation
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More News…
People Biggest Exposure and Solution Component
Physical & Cyber Security Have got to work together Old perceptions and paradigms must be broken Jobs will not be replaced by technology
Security enables Privacy --> Privacy enables Trust --> Trust enables Business!
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Open Mic
Contact Information (If you want a copy)
eValid8 CorporationPhone: 866.465.6005Fax: 410.465.9315
eMail: brian.dilley@evalid8.com
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Where are those files?
Business Landscape
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References
GAO Report – Identity Awareness http://www.gao.gov/new.items/d02766.pdf
President’s Strategic Plan http://www.ftc.gov/opa/2007/04/idtheft.shtm
U.S. Government Identity Theft Website http://www.idtheft.gov/
NIST IT Security Publications http://www.nist.gov/public_affairs/pubs.htm
Maryland Law http://mlis.state.md.us/2007RS/bills/sb/sb0194e.pdf
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