Category: Regulations – GLBA

Why Data Centers Need to Know About GLBA Compliance

May 14, 2019 at 1:10 pm by Heidi White

Data privacy and data protection rules are hot topics, having prompted us to consider exactly how we share, store, and dispose of our personal information from the individual level to the corporate level. Indeed, most (if not all) businesses must now adhere to some sort of data protection and privacy policy as set forth by industry standards. But what happens if your business interacts with other businesses that have their own policies and regulations to follow? Do you have to adopt those rulings for your business in order to continue working together? In most cases, the answer is yes.

Take data centers. If you operate such a business, you likely have stringent rules in place for securing the data you house on behalf of your clients. But, do you also follow the data regulations and privacy policies set forth by your clients? If your answer is no and your clientele is covered under the GLBA, you’ll need to revisit your information security plan immediately to incorporate GLBA compliance.

What is GLBA?

The Gramm-Leach-Bliley Act (GLBA) of 1999 mandates that financial institutions and any other companies that offer financial products to consumers such as loans, financial or investment advice, and insurance must have safeguards to protect their customers’ sensitive data and must also disclose in full their information-sharing practices and data security policies to their customers.

Check-cashing businesses, payday lenders, real estate appraisers, professional tax preparers, courier services, mortgage brokers, and nonbank lenders are examples of businesses that don’t necessarily fall under the “financial institution” category yet are included in the GLBA. The reason is that these organizations are significantly involved in providing financial products and services and therefore have access to personally identifiable information (PII) and sensitive data like social security numbers, phone numbers, addresses, bank and credit card numbers, and income and credit histories.

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GLBA Compliance: Applicable to More than Just GLBA-Covered Businesses

In accordance with GLBA, organizations covered under this Rule must develop a written information security plan that details the policies put in place at the organization to protect customer information. The security measures must be appropriate to the size of the business and the complexity of the data collected. Moreover, each company must designate an employee or a group of personnel to coordinate and enforce its security measures. Lastly, the organization must continually evaluate the effectiveness of its developed security measures, identifying and assessing risks to improve upon the policy and measures taken as needed.

At this point, you may be asking yourself, “How does this affect my business as a data center?”

The data safeguard rules also apply to any third-party affiliates and service providers employed by the companies covered under GLBA. As such, it is the responsibility of the GLBA-covered company to ensure the same steps are taken by the affiliate third-party to protect the data they interact with or store on behalf of the company. This means companies under GLBA are going to select third-party service providers like yours based on those companies that are also set up operationally with the same steps and policies in place to safeguard sensitive data. Furthermore, organizations under GLBA have the authority to manage the way in which their service provider handles their customer information to ensure compliance with GLBA.

Cloud-based data centers therefore must comply with GLBA rules for security policies and enforcement or risk losing business from those organizations and other potential clients that are covered under GLBA. As the data center operator, you could go about this in one of three ways: 1) Create separate GLBA-compliant policies for each client organization based on their needs, 2) Allow each client organization to delineate the GLBA-compliant policies they’d like your business to follow and adopt those accordingly, or 3) Establish one set of GLBA-compliant policies that cover all aspects of data protection and privacy that can work for all client organizations and potential new business.

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An SSD before and after going through a SEM Model 2SSD solid state disintegrator

GLBA and Data Destruction

Just as there are plans and personnel in place to oversee the safeguarding of data while it’s in use, under the GLBA there must be a plan and personnel in place to oversee data destruction when the data has reached its end-of-life. These policies and plans for the proper disposal of secured data should be incorporated into the organization’s information security plan and should be regularly evaluated for risk as well. While this is a straightforward task for the GLBA-covered company, developing and enforcing GLBA-compliant data destruction policies for a third-party affiliate or service provider like a data center is a different story entirely.

Not only do you need to create a set of protocols around data and drive destruction for your data center, you need to be able to prove to your client organization that you can properly dispose of the drives the data is housed on as well as the data itself. This is because both data and drive disposal must be achieved so that neither the data nor the drive can be recovered or otherwise reconstructed after destruction. Since your data center already provides remote access to the information you store, it’s recommended that you purchase and maintain data destruction machinery at your center. This way, you also control where that sensitive information is handled during the data destruction event.

One of the simplest ways to ensure compliance during data destruction events is to work with the GLBA-covered organization to assign certain personnel to that task within your data center. For instance, assigned personnel within your company as well as the client company’s GLBA task force would be required to be on-site during data destruction events. Both parties would be responsible for enforcing data destruction at the data center, including the documentation of every data destruction event, to ensure compliance and alleviate liability in the event of a breach.

Security Engineered Machinery is the global leader in high security information end-of-life solutions including paper and IT shredders, crushers, disintegrators, and degaussers.

The Importance of the NIST 800-88 Standard for Media Sanitization in Secure Data Destruction

November 21, 2018 at 4:00 pm by Heidi White

pii-securityTrends in data storage are changing at an exponential rate. The past few years alone have seen the progression of data storage from large servers with magnetic media to cloud-based infrastructure with increasingly dense solid state media. Along with every technological advancement in data storage has come the inexorable advancement of data theft. As a result, the scope and level of responsibility for protecting sensitive and Personally Identifiable Information (PII) has expanded to include not only the originators of data, but also all of the intermediaries involved in the processing, storage, and disposal of data. To address these critical issues and to protect organizations and citizens of the United States, the Information Technology Laboratory (ITL) at the National Institute of Standards and Technology (NIST) has developed NIST 800-88 “Guidelines for Media Sanitization” to promote information system security for all other applications outside of national security, including industry, government, academia, and healthcare. NIST 800-88 has become the predominant standard for the US Government, being referenced in all federal data privacy laws, and has now been overwhelmingly adopted by the private sector as well.

NIST 800-88 assumes that organizations have already identified the appropriate information categories, confidentiality impact levels, and location of the information at the earliest phase of the system life cycle as per NIST SP 800-64 “Security Considerations in the Systems Development Life Cycle.” Failing to initially identify security considerations as part of the data lifecycle opens up the strong potential that the organization will fail to appropriately maintain control of and protect some media that contains sensitive information.

Confidentiality and Media Types

data-theftConfidentiality is defined by the Title 44 US Code as “preserving authorized restrictions on information access and disclosure, including means for protecting personal privacy and proprietary information.” FIPS 199 — NIST’s Federal Information Processing Standard Publication 199, Standards for Security Categorization of Federal Information and Information Systems — adds that “a loss of confidentiality is the unauthorized disclosure of information.” Bearing these definitions in mind, organizations must establish policies and procedures to safeguard data on used media. Common methodologies of illicit data recovery include basic acquisition of clumsily sanitized media either through third party sale or old-fashioned dumpster diving, or the more sophisticated laboratory reconstruction of inadequately sanitized media.

data-securityCurrently, two types of basic media exist: hard copy and electronic. Commonly associated with paper printouts, hard copy actually encompasses a lot more. In fact, all of the materials used in the printing of all types of media, including printer and fax ribbons for paper and foils and ribbons for credit cards, are considered hard copy. Electronic media consists of any devices containing bits and bytes, including but not limited to rotational and solid state hard drives, RAM, boards, thumb drives, cell phones, tablets, office equipment including printer and fax drives, server devices, flash memory, and disks. It is expected that, considering the rate at which technology is progressing, additional media types will be developed. NIST 800-88 was developed in such a way that sanitization and disposal best practices pertain to the information housed on media rather than the media itself, allowing the guideline to more successfully stay current with future innovations.

Media Sanitization – Methodologies, Responsibilities, and Challenges

Three methodologies of media sanitization are defined by NIST 800-88 as follows:

  • Clear applies logical techniques to sanitize data in all user-addressable storage locations for protection against simple non-invasive data recovery techniques; typically applied through the standard Read and Write commands to the storage device, such as by rewriting with a new value or using a menu option to reset the device to the factory state (where rewriting is not supported).
  • Purge applies physical or logical techniques that render Target Data recovery infeasible using state of the art laboratory
  • Destroy renders Target Data recovery infeasible using state of the art laboratory techniques and results in the subsequent inability to use the media for storage of

Clear

One of the most commonly used clearing methodologies for data sanitization on magnetic media has traditionally been overwriting using dedicated sanitize commands. Note that basic read/write overwriting is never recommended as it does not address all blocks on the media. Drawbacks to overwriting using sanitize commands are two-fold: 1) it is only effective for magnetic media, not solid state or flash, and 2) this methodology is wide open to operator error and theft, as well as undetected failure.

Purge

SEM’s high security degausser can be used to purge data

A common form of purging used for magnetic media sanitization is electromagnetic degaussing, whereby a dedicated degaussing device produces a build-up of electrical energy to create a magnetic field that removes the data from the device when discharged. Degaussing has long been an acceptable form of media sanitization for top secret government information when used in tandem with a hard drive destruction device such as a crusher or shredder. Degaussing alone poses the same concerns as overwriting in that operator error or deceit remains a possibility. In addition, the strength of the degausser is critical when eliminating sensitive information from magnetic media. Typically, degaussers evaluated and listed by the National Security Agency (NSA) are considered the golden standard.

Destroy

While clearing and purging provide adequate media sanitization involving less sensitive data, destroying is the most effective and permanent solution for secure data applications. Organizations should take into account the classification of information and the medium on which it was recorded, as well as the risk to confidentiality. As the internet continues to expand and the switch from physical to digital document-keeping becomes the industry standard, more and more data holds PII information such as financials, health records, and other personal information such as that collected for databases or human resources. As a result, security-focused organizations are becoming more cognizant of the fact that comprehensive data sanitization — including destruction — must become a top priority.

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SEM disintegrators shred particles to a nominal 2mm size

Industry-tested and accepted methodologies of secure data destruction include crushing, shredding, and disintegration, but even these secure end-of-life solutions require thoughtful security considerations. For example, shredding rotational hard drives to a 19mm x random shred size provides exceptional security for sensitive information. However, a 19mm shred size would not even be an option for solid state media, which store vast amounts of data on very small chips. Instead, sensitive solid state media should be shredded to a maximum size of only 9.5mm x random, while best practices for the destruction of highly sensitive or secret information is to disintegrate the media to a nominal shred size of 2mm2. In addition, some destruction devices such as disintegrators are capable of destroying not only electronic media, but also hard copy media such as printer ribbons and employee ID cards, providing a cost-effective sanitization method for all of an organization’s media.

Responsibilities and Verification

IT security officerWhile NIST 800-88 has become the industry standard for secure data sanitization, the guidelines do not provide definitive policies for organizations. Rather, NIST 800-88 leaves the onus of appropriate data sanitization to organizations’ responsible parties including chief information officers, information security officers, system security managers, as well as engineers and system architects who are involved in the acquisition, installation, and disposal of storage media. NIST 800-88 provides a decision flow that asks key stakeholders questions regarding security categorization, media chain of custody including internal and external considerations, and potential for reuse.

Regardless of the sanitization method chosen, verification is considered an essential step in the process of maintaining confidentiality. It should be noted that verification applies not only to equipment and sanitization results, but also to personnel competencies. Sanitization equipment verification includes testing and certification of the equipment, such as NSA evaluation and listing, as well as strict adherence to scheduled maintenance. Organizations should fully train personnel responsible for sanitization processes and continue to train with personnel turnover. Lastly, the sanitization result itself must be verified through third party testing if the media is going to be reused. When media is destroyed, no such verification is necessary, as the pulverized material itself is verification enough. Because third party testing can be impractical, time consuming, and costly, many organizations choose to destroy media to ensure full sanitization of data and in doing so, to greatly mitigate risk.

Conclusion

NIST-800-88NIST 800-88 was developed in an effort to protect the privacy and interests of organizations and individuals in the United States. Adopted by nearly all federal and private organizations, NIST 800-88 provides an outline of appropriate procedures for secure data sanitization that both protects PII and confidential information while reducing organizational liability. Determining proper policies is realized by fully understanding the guidelines, following the sanitization and disposition decision flow, implementing data sanitization best practices, and engaging in ongoing training and scheduled maintenance. Because NIST 800-88 guidelines do not provide a definitive one-size-fits-all solution and are admittedly extensive, working with a knowledgeable data sanitization partner is key to a successful sanitization policy.