wildercb/PrivacyTextBooks1.2 · Datasets at Hugging Face

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would argue that using SSNs to authenticate identity is a reasonable
security practice, given the more effective and less dangerous alternatives
for authenticating identity. The SSN should never be used as a password to
authenticate identity.
Through a few enforcement actions, the FTC could fault companies that
use SSNs as passwords. Other companies would then quickly take note and
change their practices to avoid getting in trouble. If the FTC were to take
this step, one of the best tools for identity thieves would be neutralized.
Without this easy tool, many of the less sophisticated thieves would be out
of luck. Of course, the more sophisticated thieves would undoubtedly try
something else. But most identity thieves aren’t very sophisticated; they do
the crime because it is so easy.
The result, we predict, would be a significant reduction in identity theft.
Countless people wouldn’t be victimized and put through a harrowing,
time-consuming, and costly ordeal. Data breaches would be less costly to
organizations because compromised SSNs wouldn’t be able to cause so
much harm.
Unfortunately, we still await a federal law or FTC enforcement or rule to
neutralize SSNs. The government has assigned to all of us the worst
password ever created, and we can’t change it. Nearly a century after the
creation of the SSN, the government still won’t protect us by limiting its
use.
The law should also hold responsible the actors that make data breaches
so harmful. Too many companies are loose about granting credit or have
poor ways of authenticating identity. The law fails to force them to fully
internalize the cost of their practices to individuals. As a result, fraudsters
continue to take advantage of the system. The loss is borne by the
individuals and the companies having the breach.
7
Unifying Privacy and Data Security
In April 2015, representatives from CyTech Services, a small forensics
analysis company, met with officials at the U.S. Office of Personnel
Management (OPM). The CyTech employees were at OPM to demonstrate
their new tool, which would perform a diagnostic scan on OPM’s servers.
OPM maintains personnel records of millions of federal employees and
applicants to federal jobs. Because these jobs include sensitive positions,
including FBI officers and others, applicants must undergo background
checks. These background checks can be very intrusive, involving questions
about financial troubles, drug and alcohol use, any criminal wrongdoing,
psychological information, and much more. OPM maintained records of
these background checks—nearly 21.5 million records involving current
federal employees and retirees. CyTech Services initiated the diagnostic
scan. Everyone expected the scan to be clean.1 Nobody was prepared for
what happened next.
The scan identified odd unknown processes occurring on the server.2
Everyone in the room was stunned. Their jaws dropped. Something was
very wrong.
The House Oversight and Government Reform Committee began a
massive investigation, resulting in thousands of pages of documents and
transcribed interviews. After nearly a year, the Committee’s investigation
revealed that CyTech’s demonstration wasn’t the first time that OPM had
learned about the intrusion.3 In fact, OPM had discovered a breach in
March 2014, more than a year earlier. Later in 2014, two breaches occurred
at KeyPoint Government Solutions, a company that provided services to
OPM and that had access to OPM’s data. OPM failed to terminate
KeyPoint’s access, even though KeyPoint’s credentials were used to access
OPM’s network.
One of the hacked OPM databases, the Central Personnel Data File,
contained personnel records of current and former federal employees. The
database included their Social Security Numbers, job positions, and
performance evaluations.
Another hacked OPM database, the Electronic Questionnaires for
Investigations Processing (e-QIP) system, contained security clearance and
background check information. This data included information on 1.8
million spouses, children, and family members of security clearance
applicants.4
OPM also maintained fingerprint data, which dated back to 2000.
Initially, OPM reported that only 1.1 million fingerprint records were
compromised, but it later updated the figure to 5.6 million. OPM stated that
“Federal experts believe that, as of now, the ability to misuse fingerprint
data is limited.”5 This statement, however, strains credulity. Many experts
criticized OPM for downplaying concerns about the compromised
fingerprints. One expert declared that undercover agents could be
“completely compromised,” noting that “a secret agent’s name might be
different. But they’ll know who you are because your fingerprint is there.
You’ll be outed immediately.”6
As far back as 2007, OPM’s Inspector General Office (OIG) was
delivering semi-regular audit reports to Congress criticizing OPM’s security
practices as a “material weakness”—the lowest possible assessment on its
scale.7 Later reports noted that “[t]he continuing weakness in OPM
information security program results directly from inadequate governance.
Most if not all of the [information security] exceptions we noted this year
result from a lack of leadership, policy, and guidance.” A 2014 information
security audit also noted OPM’s poor security, faulting OPM for failing to
implement multi-factor authentication, which had been recommended much
earlier and would have likely prevented the breach.8 Time and again, the
warnings had been made that OPM’s security was poor, but nobody did
anything about it.9
The OPM breach was not only the product of bad security practices but
also of poor privacy practices. Nuala O’Connor, former head of the U.S.
Department of Homeland Security’s privacy office, noted that “OPM didn’t
have the most basic data map or a simple inventory list of its servers and
databases, nor did it have an accounting of all the systems connecting to its
network.”10 This is a data privacy flaw. A key dimension of protecting data
is maintaining a data inventory to keep track of the data being stored and
who is responsible for it.
Moreover, OPM was storing all this data in a centralized location,
making it easy for the hackers to obtain a lot of data.11 Keeping massive
stores of personal information is also a privacy no-no. Even worse, OPM
retained the data seemingly forever; it had data going back decades,

would argue that using SSNs to authenticate identity is a reasonable

security practice, given the more effective and less dangerous alternatives

for authenticating identity. The SSN should never be used as a password to

authenticate identity.

Through a few enforcement actions, the FTC could fault companies that

use SSNs as passwords. Other companies would then quickly take note and

change their practices to avoid getting in trouble. If the FTC were to take

this step, one of the best tools for identity thieves would be neutralized.

Without this easy tool, many of the less sophisticated thieves would be out

of luck. Of course, the more sophisticated thieves would undoubtedly try

something else. But most identity thieves aren’t very sophisticated; they do

the crime because it is so easy.

The result, we predict, would be a significant reduction in identity theft.

Countless people wouldn’t be victimized and put through a harrowing,

time-consuming, and costly ordeal. Data breaches would be less costly to

organizations because compromised SSNs wouldn’t be able to cause so

much harm.

Unfortunately, we still await a federal law or FTC enforcement or rule to

neutralize SSNs. The government has assigned to all of us the worst

password ever created, and we can’t change it. Nearly a century after the

creation of the SSN, the government still won’t protect us by limiting its

use.

The law should also hold responsible the actors that make data breaches

so harmful. Too many companies are loose about granting credit or have

poor ways of authenticating identity. The law fails to force them to fully

internalize the cost of their practices to individuals. As a result, fraudsters

continue to take advantage of the system. The loss is borne by the

individuals and the companies having the breach.

7

Unifying Privacy and Data Security

In April 2015, representatives from CyTech Services, a small forensics

analysis company, met with officials at the U.S. Office of Personnel

Management (OPM). The CyTech employees were at OPM to demonstrate

their new tool, which would perform a diagnostic scan on OPM’s servers.

OPM maintains personnel records of millions of federal employees and

applicants to federal jobs. Because these jobs include sensitive positions,

including FBI officers and others, applicants must undergo background

checks. These background checks can be very intrusive, involving questions

about financial troubles, drug and alcohol use, any criminal wrongdoing,

psychological information, and much more. OPM maintained records of

these background checks—nearly 21.5 million records involving current

federal employees and retirees. CyTech Services initiated the diagnostic

scan. Everyone expected the scan to be clean.1 Nobody was prepared for

what happened next.

The scan identified odd unknown processes occurring on the server.2

Everyone in the room was stunned. Their jaws dropped. Something was

very wrong.

The House Oversight and Government Reform Committee began a

massive investigation, resulting in thousands of pages of documents and

transcribed interviews. After nearly a year, the Committee’s investigation

revealed that CyTech’s demonstration wasn’t the first time that OPM had

learned about the intrusion.3 In fact, OPM had discovered a breach in

March 2014, more than a year earlier. Later in 2014, two breaches occurred

at KeyPoint Government Solutions, a company that provided services to

OPM and that had access to OPM’s data. OPM failed to terminate

KeyPoint’s access, even though KeyPoint’s credentials were used to access

OPM’s network.

One of the hacked OPM databases, the Central Personnel Data File,

contained personnel records of current and former federal employees. The

database included their Social Security Numbers, job positions, and

performance evaluations.

Another hacked OPM database, the Electronic Questionnaires for

Investigations Processing (e-QIP) system, contained security clearance and

background check information. This data included information on 1.8

million spouses, children, and family members of security clearance

applicants.4

OPM also maintained fingerprint data, which dated back to 2000.

Initially, OPM reported that only 1.1 million fingerprint records were

compromised, but it later updated the figure to 5.6 million. OPM stated that

“Federal experts believe that, as of now, the ability to misuse fingerprint

data is limited.”5 This statement, however, strains credulity. Many experts

criticized OPM for downplaying concerns about the compromised

fingerprints. One expert declared that undercover agents could be

“completely compromised,” noting that “a secret agent’s name might be

different. But they’ll know who you are because your fingerprint is there.

You’ll be outed immediately.”6

As far back as 2007, OPM’s Inspector General Office (OIG) was

delivering semi-regular audit reports to Congress criticizing OPM’s security

practices as a “material weakness”—the lowest possible assessment on its

scale.7 Later reports noted that “[t]he continuing weakness in OPM

information security program results directly from inadequate governance.

Most if not all of the [information security] exceptions we noted this year

result from a lack of leadership, policy, and guidance.” A 2014 information

security audit also noted OPM’s poor security, faulting OPM for failing to

implement multi-factor authentication, which had been recommended much

earlier and would have likely prevented the breach.8 Time and again, the

warnings had been made that OPM’s security was poor, but nobody did

anything about it.9

The OPM breach was not only the product of bad security practices but

also of poor privacy practices. Nuala O’Connor, former head of the U.S.

Department of Homeland Security’s privacy office, noted that “OPM didn’t

have the most basic data map or a simple inventory list of its servers and

databases, nor did it have an accounting of all the systems connecting to its

network.”10 This is a data privacy flaw. A key dimension of protecting data

is maintaining a data inventory to keep track of the data being stored and

who is responsible for it.

Moreover, OPM was storing all this data in a centralized location,

making it easy for the hackers to obtain a lot of data.11 Keeping massive

stores of personal information is also a privacy no-no. Even worse, OPM

retained the data seemingly forever; it had data going back decades,