Utmost attention will be paid to secure personal privacy

Densely typed in, nearly 2,000 words over four pages, the policy statement of The University of Washington’s Electronic Information Privacy Policy on Personally Identifiable Information lays out in clear terms what PII is at the University and who can provide exceptions to the rules. The document requires familiarity with technical information and communication systems and at least some knowledge of the University -- how it is structured and administered.

The document regulates the ideas behind the University’s goals in relationship to Personally Identifiable Information (PII), to be “in full compliance with all related federal and state statutes and regulations, and demonstrate a rigorous commitment to core values of maximizing trust, integrity, and respect for privacy.” It is a statement of clear commitment which using the methods outlined in this case study can be accomplished through a collaborative, enterprise wide community commitment to the ideal, so that the insurance costs do not escalate beyond the UW’s ability to pay, and to maintain a sense of respect, responsibility, and dedication to humanity.

There can be no doubt that the tone of this document is intended to protect people, enumerating who “they” are in some detail. The document outlines the exceptions for control of information, by detailing which executives may take responsibility for PII.

In contrast to the stated commitment and ideal, the reality is more difficult to practice because “60% to 80% of consumers' PCs are infected with spyware”, as Kirk Bailey, UW’s Chief Information Security Officer told MSIM2008 interviewers, “But much, if not all of any individual’s Personally Identifiable Information (PII) is already available through other online sources. In fact if an organization looses control of someone’s PII, it would be very difficult to prove who the source really was.”

The truth is most if not all PII is already publicly available. This was demonstrated by Kirk Bailey’s study reported in the New York Times and Seattle Post Intelligencer, in which his valid birth certificate was obtained with little difficulty, and leveraged to gain control of bank accounts. By cross referencing a number of sources, such as databases, and search behaviors other information may be inferred.

There are several motivating factors underlying the reasons to protect Personally Identifiable Information, but the primaries are reputation and risk management. Reputation and cost are inextricably linked, because it is the law to remediate each case as applied to individual people.

Organizations and individuals have been successfully sued for millions of dollars in privacy claims. Common practice is to settle out of court in class action and group lawsuits, to avoid further degradation to the organization, reputation, tarnishing of their brand, and disturbing influences on the business in terms of compliance and audits. The expense really never ends; the costs are ongoing in the form of insurance.

The definition and legal application of privacy standards such as HIPAA are being tested in practice, due to recent enactment. Company executives have lost their jobs and organizations their reputations because they could not show they complied with best practices in relationship to securing PII data on systems, or worse yet, intentionally misused their customers PII by selling it to a third party without permission.

Loosing control of PII is expensive to remediate. By statute in Washington State, when a persons PII has been compromised they must be informed. At the University of Washington it is estimated last year it cost $187.00 per personal contact. The University’s reputation, as well as its brand is at stake, due to the lost of PII. And it is no fun for the people who have to make those calls. In order to assume responsibility and restore some faith that the organization’s intentions are good the senior staff speak with truly irate individuals.

At the current time security breaches and PII loss appears inevitable; as the University’s CISO Kirk Bailey takes a four fold method to reduce risk, and obtains insurance against such losses. Enterprise-wide, voluntary, even eager, compliance with regulations and statues is a best practice in terms of lost prevention. This is a major factor in the methods he applies.

Regarding how companies abuse privacy Kirk Bailey detailed in his Hackers PBS interview, he said unscrupulous companies do this with “The placement of "cookies" or the requesting of information when you log onto the site. Forms that are filled out and then that information is rolled up into databases, or tracking your activities on their Web sites to create a profile of what your interests might be, then using those conjectures and that real data and wrapping it within a profile and selling it that information. We know those things take place. I resent those kinds of things. I find that unacceptable. It's not necessary. . . .”

-Kirk Bailey, PBS interview, 2001 http://www.pbs.org/wgbh/pages/frontline/shows/hackers/interviews/bailey.html


Shukovsky, P. “’Good Guys’ show just how easy it is to steal ID” Seattle Post Intelligencer. March 5, 2005 (retrieved from the web March 19, 2005). http://seattlepi.nwsource.com/local/214663_googlehack05.html

Collaborative, Enterprise Wide, Information Security C-Level Management

“…distributed leadership requires shared values and a sense of community.”
- UW Provost Phyllis Wise

Executive Summary
The state supported University of Washington (UW) is faced with a Herculean set of information age problems to ensure its reputation, which may be viewed as risk management issues, framed within its own mission of providing educational excellence for the state, the region, and the nation. As limited economic resources are used to protect and manage information, paying for information management and security reduces the amount of funds remaining to serve the University’s primary mission, ”the preservation, advancement, and dissemination of knowledge.” (Board of Regents, 1998)

The University’s senior management strategy is that a collaborative, institution-wide model (Strategic Risk Initiative Review Committee, 2006) built on best practices will work best within their framework while reducing costs. Using this method will protect its decentralized, collaborative and entrepreneurial culture, and its information technology, including Personally Identifiable Information, and education information assets, while conforming to state and federal regulations.

Upon the request of UW President Mark Emmert a study was conducted, and, after an in-depth analysis and public comment period (Strategic Risk Initiative Review Committee, 2006), they chose to hire one executive as a C-Level manager, their Chief of Information Security, Kirk Bailey. Although he has no staff, he has the ability to summarily shut down any system. His objective is to advise and inform the three campus and sixteen colleges, and their information manage teams to secure sensitive and other information, and provide a clear direction for information risk management based on his expert knowledge domain, including dynamic social networking (Interview with Kirk Bailey, 2007).

Background
Founded on November 4, 1861, the University of Washington is comprised of three campuses: Seattle, with sixteen schools and colleges ranging from first-year undergraduates through doctoral-level candidates; and the Bothell, and Tacoma campuses, with upper-division undergraduates and graduate students.

As a core value to serve its purpose “the University is committed to maintaining an environment for objectivity and imaginative inquiry and for the original scholarship and research that ensure the production of new knowledge in the free exchange of diverse facts, theories, and ideas.“ (Board of Regents, 1998) In effect this means allowing colleges and schools a great deal of self-governance within the University, because those organizations are the best at understanding what they do.

As a large educational, research, and medical facility the UW acquires, stores, disseminates, and uses vast amounts of data, through its libraries and collections, courses, faculty scholarship, and publications. It advances new knowledge through research, inquiry, and discussion; and disseminates it through classrooms, laboratory, scholarly exchanges, creative practice, international education, and public service. As such the University itself can be considered both a consumer of vast amounts of data, and a source of information.

Some of this information is directly related to individuals – this essentially private data is termed “Personally Identifiable” and has broad implications in its use in credit, grades, tracking and membership, medical, and as related to other types of sensitive research, such as intelligence. Personally Identifiable Information (Executive Officers of the University of Washington, 2001) is regulated by state and federal laws, such as the Health Insurance Portability and Accountability Act (HIPAA) catching up to the ramifications of easily collectable, storable, and frequently transferable information (PII). As a best practice there is also a wealth of compliance issues related to private data housed within a public institution. (Strategic Risk Initiative Review Committee, 2006)

References:
Title: UW Role and Mission Statement
Author: Board of Regents
Publication: http://www.washington.edu/home/mission.html
Date: February 1981; revised February 1998, modified: November 5, 1998

Title: Collaborative Enterprise Risk Management
Author: Strategic Risk Initiative Review Committee, V’Ella Warren, Vice President, Financial Management, David Hodge, Dean, College of Arts and Sciences, co-chairs
Publication: www.washington.edu/admin/finmgmt/erm/ermsummary021306b.pdf
Date: February 13, 2006

Title: Enterprise Risk Management, University of Washington
Author: Strategic Risk Initiative Review Committee, V’Ella Warren, Vice President, Financial Management, David Hodge, Dean, College of Arts and Sciences, co-chairs
Publication: http://www.washington.edu/faculty/facsen/sec_minutes/05-06/sec_021306.pdf.
Date: January 9, 2006

Title: Privacy Policy, University of Washington
Author: Executive Officers of the University of Washington; the President, the Executive Vice President, the Provost, and the University's Privacy Officer, Vice President for Computing and Communications
Publication: http://www.washington.edu/computing/rules/privacypolicy.html
Date: October 6, 2001

Title: Interview with Kirk Bailey
Location: University of Washington, Seattle
Date: February 22, 2007