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DEFENSE PRIVACY & CIVIL LIBERTIES OFFICE
Safeguarding Personally Identifiable Information (PII)
Samuel P. JenkinsDirector for Privacy
Defense Privacy and Civil Liberties Office
Identity Protection and Management Expo
Orlando, Florida
April 2011
DEFENSE PRIVACY & CIVIL LIBERTIES OFFICE
Purpose
The purpose of this presentation is to provide a summary of the administrative, physical, and technical safeguards that are applicable to systems that collect, use, maintain, or disseminate personally identifiable information (PII).
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DEFENSE PRIVACY & CIVIL LIBERTIES OFFICE
Objectives
Upon completion of this presentation, you should be able to:Understand the role of safeguards that
should be applied to systems of records (SORs).
Explore the physical, technical, and administrative safeguards for protecting PII.
Define the role of Privacy Impact Assessments and SORNs in safeguarding PII.
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DEFENSE PRIVACY & CIVIL LIBERTIES OFFICE
The Privacy Act of 1974 requires agencies to:
Establish Rules of Conduct.Establish Safeguards.Maintain accurate, relevant, timely,
and complete information.
Privacy Act and Safeguards
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DEFENSE PRIVACY & CIVIL LIBERTIES OFFICE
Privacy Act and Safeguards
Safeguards are used to protect agencies from “reasonably anticipated threats.”Threats may cause harm, embarrassment,
inconvenience, or unfairness.
Threats to personal information include:Unauthorized access.Unauthorized alteration.Unauthorized disclosure.
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DEFENSE PRIVACY & CIVIL LIBERTIES OFFICE
Privacy Act and Safeguards
Safeguards should be tailored to the:Size and sensitivity of each system.System-specific vulnerabilities.
Types of Safeguards:Administrative.Physical.Technical.
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DEFENSE PRIVACY & CIVIL LIBERTIES OFFICE
Physical Safeguards
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DEFENSE PRIVACY & CIVIL LIBERTIES OFFICE
Physical Safeguards
Paper records should be stored in locked cabinets.
Records being faxed or mailed should have a coversheet.
Facilities handling PII should be access controlled and hardware should be locked up.
Never leave files, storage media, or computers unattended or in vehicles.
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DEFENSE PRIVACY & CIVIL LIBERTIES OFFICE
Physical Safeguards
Records Disposal – Retirement or deletion of a record does not obviate need for safeguards.Must render discarded info
unrecognizable and beyond reconstruction.
Destruction should be tailored to the time of media involved.○ Paper – burn, shred.○ Electronic – overwrite, degauss incinerate.
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DEFENSE PRIVACY & CIVIL LIBERTIES OFFICE
Technical Safeguards
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DEFENSE PRIVACY & CIVIL LIBERTIES OFFICE
Security Requirements include:
Encryption.Control Remote Access.Time-Out Function.Log and Verify.Ensure Understanding of
Responsibilities.
Technical Safeguards
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DEFENSE PRIVACY & CIVIL LIBERTIES OFFICE
Technical Safeguards
Ensure all emails with PII are encrypted and that all recipients have a ‘need to know.’
Ensure records are access controlled.PII on shared drives should only be
accessible to people with a ‘need to know’ Ensure Social Security numbers
(including the last 4) are not posted on public facing websites.
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DEFENSE PRIVACY & CIVIL LIBERTIES OFFICE
Administrative Safeguards
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DEFENSE PRIVACY & CIVIL LIBERTIES OFFICE
Admin Safeguards - Policies
Agencies must have policies in place for PII handling, specifically defining:Affected Individuals.Affected Actions.Consequences.
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DEFENSE PRIVACY & CIVIL LIBERTIES OFFICE
Agencies are responsible to ensure staff handling PII are adequately trained:Training must be commensurate with
an individual’s responsibilities.Training will be a prerequisite before
permitted access to DoD systems.Such training is mandatory for
affected DoD personnel and contractors.
Admin Safeguards - Training
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DEFENSE PRIVACY & CIVIL LIBERTIES OFFICE
Admin Safeguards - Training
Components shall ensure receipt of Privacy Act training, such as:
Orientation Training. Specialized Training. Management Training. Privacy Act Systems of Records
Training.
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DEFENSE PRIVACY & CIVIL LIBERTIES OFFICE
Admin Safeguards - Training
Annual Refresher Training.Provided to ensure continued
understand of their responsibilities.All personnel with authorized access
to PII shall annually acknowledging their understanding.
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DEFENSE PRIVACY & CIVIL LIBERTIES OFFICE
DoD Components shall expand their training materials and program to include specific privacy and security awareness segments to their training program(s).
Admin Safeguards - Training
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DEFENSE PRIVACY & CIVIL LIBERTIES OFFICE
Admin Safeguards – Breach Handling
Existing Requirements:FISMA Requirements.Incident Handling and Response Mechanism.
OMB M-07-16 modified breach reporting rules.
Modified Agency Reporting Requirements:US-CERT Modification.Develop and Publish a Routine Use.○ Effective Response.○ Disclosure of Information.
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DEFENSE PRIVACY & CIVIL LIBERTIES OFFICE
Admin Safeguards – Breach Handling
Breach Notification: Criteria to Consider:
Whether Breach Notification is Required.
Timeliness of the Notification.Source of the Notification.Contents of the Notification.Means of Providing Notification.Who Receives Notification: Public
Outreach in Response to a Breach.
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DEFENSE PRIVACY & CIVIL LIBERTIES OFFICE
Admin Safeguards – Review & Report
Under the Federal Information Security Management Act (FISMA) agencies must:Review PII holdings & report to
Congress Annually.Review and reduce the volume of PII.Specifically, Agencies Must Reduce the
Use of Social Security Numbers.○ Eliminate Unnecessary Use.○ Explore Alternatives.
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DEFENSE PRIVACY & CIVIL LIBERTIES OFFICE
As part of FISMA privacy reporting, DoD Components are required to:Confirm that they have established, or are
in the process of establishing, PII review plans; or
Provide a schedule for periodically updating their review of their holdings.
It is DoD policy that:All automated systems containing PII are
registered in the Defense Information Technology Portfolio Repository (DITPR).
Admin Safeguards – Review & Report
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DEFENSE PRIVACY & CIVIL LIBERTIES OFFICE
It is DoD policy that (continued): Updates to OMB be designed so that:
○ IT systems with PII reviewed on same cycle as Defense Information Assurance Certification and Accreditation Process (DIACAP).
○ PIA/SORNs reviewed at least once every two years.
Components shall report results to DPCLO on FISMA schedule.
Admin Safeguard – Review & Report
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DEFENSE PRIVACY & CIVIL LIBERTIES OFFICE
Privacy Impact Assessments (PIA) & System of Records
Notices (SORN)
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DEFENSE PRIVACY & CIVIL LIBERTIES OFFICE
A Privacy Impact Assessment (PIA) is an analysis of how information is handled to: Ensure handling conforms to applicable
legal, regulatory, and policy requirements.Determine the risks and effects of
collecting, using, maintaining, and disseminating PII in an electronic information system, and
Mitigate potential privacy risks.
OMB 03-22 (9/26/2003), EGOV 208(b)
Admin Safeguards – PIAs & SORNs
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DEFENSE PRIVACY & CIVIL LIBERTIES OFFICE
When is a PIA Required when PII is collected from:Existing information systems and
electronic collections where a PIA has not previously been completed and that collects PII about Federal personnel and contractors.
New information systems or electronic collections:○ Prior to developing or purchasing; and ○ When converting paper records to
electronic systems.
Admin Safeguards – PIAs & SORNs
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DEFENSE PRIVACY & CIVIL LIBERTIES OFFICE
A PIA is not required when the information system or electronic collection:Does not collect, maintain or
disseminate personal identifying information.
Is a National Security System (including systems that process classified information).
Admin Safeguard – PIAs & SORNs
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DEFENSE PRIVACY & CIVIL LIBERTIES OFFICE
Admin Safeguards – PIAs & SORNs
What is a SORN?A SORN is a public notice of an agency’s
intent to collect & retrieve PII in a SOR.SORNs include:
○ The safeguards that will be applied to the system.
○ The who, what, why, and where of the system.○ Processes for access and correction of records.
A SORN must be published in the Federal Register before a system can begin to collect PII.
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DEFENSE PRIVACY & CIVIL LIBERTIES OFFICE
PIA/SORN Essential Elements
Crosswalk
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DEFENSE PRIVACY & CIVIL LIBERTIES OFFICE
PIA/SORN Crosswalk
Privacy Impact Assessment (PIA)/System of Record Notice (SORN) Essential Elements Crosswalk
PIA SORN
What privacy information is collected Categories of Records in the System
Why the information is collected Authority/Purpose(s)
What the intended uses are for the information
Purposes(s)
With whom the information is shared Routine Uses
What opportunities individuals have to decline to provide PII
Privacy Act Statement/Notification procedure
How information is secured Safeguards
What privacy risks need to be addressed Narrative Statement/Probable or potential effects on the privacy of individuals.
Whether a System of Records Notice (SORN) exists
(Not applicable)
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DEFENSE PRIVACY & CIVIL LIBERTIES OFFICE
PRIVACY IMPACT ASSESSMENT (PIA)
DoD Information System/Electronic Collection Name:
DoD Component Name:
SECTION 4: REVIEW AND APPROVAL SIGNATURESPrior to the submission of the PIA for review and approval, the PIA must be coordinated by the Program Manager or designee through the Information Assurance Manager and Privacy Representative at the local level.Program Manager or Other Official Signature(to be used at Component discretion)Component Senior Information Assurance Officer Signatureor DesigneeComponent Privacy Officer SignatureComponent CIO Signature(Reviewing Official)
Source: DD Form 2930
PIA/SORN Crosswalk
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DEFENSE PRIVACY & CIVIL LIBERTIES OFFICE
Focused on meeting the information requirements of the Agency while ensuring the protection of the rights of the individual in the collection, use and dissemination of PII.
Focused on protecting the information and information systems supporting the operations and assets of an organization.
Privacy’s success is
dependent on establishment of
basic foundation for
information security.
PRIVACY SECURITY
NIST Draft Guide to Protecting the Confidentiality of (PII) (1/09)
Critical Privacy – Security Interface
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PIA/SORN Crosswalk
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DEFENSE PRIVACY & CIVIL LIBERTIES OFFICE
Summary
You should now be able to:Understand the role of safeguards that
should be applied to systems of records (SORs).
Explore the physical, technical, and administrative safeguards for protecting PII.
Define the role of Privacy Impact Assessments and SORNs in safeguarding PII.
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DEFENSE PRIVACY & CIVIL LIBERTIES OFFICE
Resources
DoD 5400.11-R, Department of Defense Privacy Program, May 14, 2007.
OMB M-07-16, Safeguarding Against and Responding to the Breach of Personally Identifiable Information, May 22, 2007.
DoD Implementation: Safeguarding Against and Responding to the Breach of Personally Identifiable Information (PII), June 5, 2009.
DD Form 2930, “Privacy Impact Assessment (PIA),” 2008.
OSD Memorandum 13798-10, “Social Security Numbers Exposed on Public Facing & Open Government Websites.”