Because I am Here

This article originally appeared on the Security Catalyst Blog.

Colleges and universities store employment data, financial records, transcripts, credit histories, medical histories, contact information, social security numbers and other types of personal information. Although higher-education institutions should be forums where information and knowledge are easily exchanged, “sometimes the free flow of information is unintentional.” Here are eight policies and behaviors that put personal information at risk:

1. Administrative Decentralization
2. Naive Office Culture
3. Unprotected “Old” Data
4. Shadow Systems
5. Unregulated Servers
6. Unsophisticated Privacy Policies
7. Improper Use of the SSN
8. Unsanitized Hard Drives

Administrative Decentralization

In a university setting each college, each department, and often each professor operates nearly autonomously. In an environment where knowledge must flow freely, decentralization is a must. However, it means that new centralized policies to address information security are difficult to implement.

Naive Office Culture

A closely related risk factor is office culture. Staff turnover makes training an ongoing struggle, despite strict policies governing information control. Accidental information leaks can occur, even in the most secure IT environment. In addition, all office cultures resist changing any process, no matter how inefficient. In one example, I called my law school to discuss financial aid. After identifying myself by only my last name, the staff member automatically read my social security number over the phone.

Unprotected “Old” Data

Colleges do a pretty good job of guarding current personal information, but fail to protect older information, which is especially risky if the old data includes social security numbers.

Almost every week a faculty member backs up an old hard drive to his personal web space, unaware that the hard drive contained legacy student grades and social security numbers. Occasionally the professor is aware of the information but mistakenly believes that his university-provided Web space is not available to the public. Often the data sit on the institutional server for up to five years undetected and forgotten—until the information turns up on Google.

Shadow Systems

“Shadow Systems” are copies of personal information from the core system which professors, colleges, departments, and even student organizations maintain independently. Shadow systems can be sophisticated databases under high security or simple Excel spreadsheets on personal laptops. They multiply at an alarming rate because faculty members with administrative access can create their own databases at any time.

Thus, even though a small army of information-technology professionals may guard a college’s core systems, the security perimeter extends much further. And despite strict policies governing information control, employee turnover makes training about privacy and security issues a continual struggle.

Unregulated Servers

Often faculty members and third-party vendors also set up their own unregulated servers outside university firewalls, often for legitimate academic use. Those servers are particularly vulnerable to hackers and accidental online exposure. In one security audit, a private university uncovered 250 unauthorized servers connected to its public internet network, each containing sensitive student information.

Unsophisticated Privacy Policies

Colleges’ privacy policies often demonstrate a basic lack of understanding of the law and, more importantly, how the institution carries out the law through internal processes. Many policies basically say nothing more than “We follow the law,” without explaining what the law is or how they follow it. Even worse, some simply say, in essence, “Trust us, we’ll be good.”

Many institutions’ privacy policies also erroneously mimic commercial policies, which are narrowly tailored to cover only information collected online. Those policies are deficient in a college setting because just a small fraction of personal information that colleges maintain is collected online.

Further, a single institution may have dozens or hundreds of separate privacy policies, each dealing with a different, and incomplete, set of issues. For example, at some highly decentralized institutions, each college, department, and even some facilities like student unions have their own privacy policies. While privacy policies should reflect the practices of each group, inconsistent policies can create confusion among staff members who must explain or carry them out.

Improper Use of the SSN

Even though many colleges don’t now use social security numbers to identify students, they once did. Those old records sit like land mines on old servers. In addition, some universities print them on academic transcripts and official documents. Even though the American Association of Collegiate Registrars and Admissions Officers recommends printing the social security number on transcripts, my January 2007 study indicates that fortunately, most don’t.

Unsanitized Hard Drives

Deleted files remain almost unchanged on the hard drive until it is overwritten or physically destroyed. Once unsanitized hard drives are re-sold, sensitive personal and corporate information can be easily retrieved. Though most universities have a sanitization protocol when retiring old hard drives, enforcing the policy can be challenging.

Solutions

College administrators should consider the following:

• Regularly scan institutional networks for sensitive information, such as social security numbers, grades, and financial information. Use a combination of public search engines, and internal text- and file-scanning software.
• Automatically retire “old” data on institutional servers but allow faculty members to un-retire old data they still use. Forgotten information is dangerous information.
• Establish a “radioactive date,” which is when your institution last used social security numbers as an identifier. Files last modified before this date should be presumed dangerous.
• Create permissions-based access to core systems. Sensitive personal information should be available to faculty members and departments only on a need-to-know basis.
• Establish a data-retention-and-access policy by balancing threat, benefits and risks of maintaining the data.
• Coordinate interdepartmental privacy and security practices with a special committee of information security professionals.
• Update your privacy policy to reflect all privacy issues arising in a university setting. Explain privacy rights and practices that protect offline employment information and sensitive student records. Also explain work-flow protections (for example, “only director-level employees have access to social security numbers”) and technical practices (for example, “employee data is stored on encrypted hard drives”). Privacy policies should deal with more than just cookies and Web forms.
• Eliminate social security numbers from official records where possible, or establish a policy whereby students can opt to omit their numbers from transcripts or other records.
• Physically destroy all old hard drives.

Institutions of higher education must promote the free exchange of ideas while protecting sensitive personal information. Although the academic environment can seem at odds with information security, appropriate practices and procedures can balance information freedom and personal privacy.

Aaron Titus is the Privacy Director for the Liberty Coalition, and runs National ID Watch. A version of this article originally appeared in the October 24, 2008 edition of the Chronicle of Higher Education, and is republished here by arrangement.