Information & Communication Technologies 08 2014 NMSU All About Discovery! Risk-Based Information Security Program at NMSU presented by Norma Grijalva

Information & Communication Technologies 08 2014 NMSU All About Discovery!

Data Privacy Laws/Regulations

• FERPA – Family Educational Rights and Privacy Act• HIPAA – Health Insurance Portability and Accountability

Act• GLBA – Gramm-Leach-Bliley Act• RFR – Red Flags Rule of the Federal Trade Commission• FISMA – Federal Information Security Management Act • PCI DSS – Payment Card Industry Data Security

Standards• Others exist, but the above are primary

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General Institutional Requirements

• FERPA, HIPAA, GLBA, RFR, FISMA, and PCI-DSS require the following:– Designated information security responsibility– Risk-based information security program– Data security policies and procedures– Monitoring and incident handling/compliance– Data security training and awareness

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Consequences of Noncompliance

• FERPA – Loss of federal funding to institution

• HIPAA – Monetary penalties of up to $6M / year

• GLBA – Fines and imprisonment

• RFR – Federal fines

• FISMA – Loss of research and contract funding

• PCI DSS – Fines– Removal of institution’s ability to take credit card payments

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Recent Higher Ed Data Breaches• Butler University, June 2014

– 163,000 records taken

• Iowa State University (NMSU peer), April 2014


• North Dakota University, March 2014


• Indiana University, February 2014


• University of Maryland, February 2014


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Hard Costs Related to Breaches• Maricopa Community College District for last

year's data breach costs are approaching $20 million

• University of Maryland to pay $2.6M just for credit monitoring of data breach victims. Other costs TBD

• Target estimates data breach costs at nearly $150 million and shares are down

• These are just a few examples…

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NMSU’s Risk

If hackers compromised Banner, how many unique social security numbers would they have access to?

A. 10,000

B. 25,000

C. 50,000

D. I already have enough trouble sleeping at night

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~ 500,000(including the SSNs of the people sitting to your right and left)

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NMSU’s Risk (continued)

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• In addition to social security numbers and other Personally Identifiable Information (PII), NMSU’s systems contain other regulated data

• Not all regulated data resides centrally --- desktop/shadow systems and departmental servers may also contain regulated data

• We still get reports of PII data being transmitted “in the clear” despite NMSU data security policy


Estimated Cost of a Data Breach

• Based on 2013 Study by Ponemon Institute & Symantec – $111 per record at US universities and colleges – $136 per record across industry

• Estimated cost of a breach at NMSU– $55,500,000 based on loss of 500,000 records at

$111 per record• Includes costs associated with loss of public confidence,

reputation, etc.

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Breaches Bring Greater Focus

• Higher education institutions are reacting to data breaches by committing to improved data security– University of Maryland created a President's

Task Force on Cybersecurity, adding more staff and purchasing expensive security tools

– Iowa State University is creating policies and deploying security tools, etc.

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NMSU is being proactive

• Enhancing security practices within the technology – network, servers, software

• Implementing new security tools• Beefing up training & awareness, compliance

across the institution• Working to establish a risk-based information

security program• Doing what we can with available resources, but

more is needed

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Changing IT Landscape

• Factors that are now shaping IT– Greater and very real threats to institutional data

– Integration of information technology into all areas of NMSU’s business, requiring a strategic versus strictly operational perspective of IT

– Competition for IT resources is growing, requiring better planning, resource allocation, and sharing

• A move to IT Governance is key!

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Information Technology Governance

• Just what is IT Governance?– The processes that ensure the effective and efficient

use of IT in enabling an organization to achieve its goals. (Gartner)

• What does IT Governance do for NMSU?– Ensures the effective evaluation, selection,

prioritization, and funding of competing IT investments– Optimizes resources– Lowers risk– Enhances measurement of institutional IT performance

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IT Governance, Then Data Governance

• Data governance is born of IT governance– Once IT governance is established, data governance

follows

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Governance Leads to Security

• IT and Data Governance are the foundation of data security, culminating in protection that is based on identified risk– Awareness is the first step

– Information security is everyone’s responsibility

• Appropriate governance ensures that the university is in compliance with data security laws and NMSU policies

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Information & Communication Technologies 08 2014 NMSU All About Discovery!17

To successfully protect our data, we need your support!


What Can You Do?

• Participate in IT and data governance taskforces

• See IT as a strategic asset

• Endorse a risk-based information security program

• You and your staff should participate in online or in person data security training

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Risk-Based Information Security Program at NMSU

Questions?Thanks

Norma Grijalva

John Roberts

Carlos S. Lobato

Documents

Information & Communication Technologies 08 2014 NMSU All About Discovery! Risk-Based Information Security Program at NMSU presented by Norma Grijalva