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Home Regulatory Compliance
Regulatory Compliance

Data Security Standards: FFIEC Compliance

"FFIEC (Federal Financial Institutions Examination Council)compliance is conformance to a set of standards for online banking issued in October 2005 by the Federal Financial Institutions Examination Council (FFIEC). The standards require multifactor authentication (MFA) because single-factor authentication (SFA) has proven inadequate against the tactics of increasingly sophisticated hackers, particularly on the Internet. In MFA, more than one form of authentication is implemented to verify the legitimacy of a transaction. In contrast, SFA involves only a user ID and password."

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Data Security Standards: PCI Compliance

Payment Card Industry (PCI) Compliance

The Payment Card Industry Data Security Standard (PCI DSS) is a set of requirements designed to ensure that ALL companies that process, store or transmit credit card information maintain a secure environment.

Is PCI a law? No. It is a worldwide information security standard assembled by the Payment Card Industry Security Standards Council (PCI SSC). Enforcement of compliance is done by  organizations processing transactions (i.e. Visa, Mastercard,   American Express etc.).

PCI DSS Requirements (Wikipedia)

  1. Install and maintain a firewall configuration to protect cardholder data
  2. Do not use vendor-supplied defaults for system passwords and other security parameters
  3. Protect stored cardholder data
  4. Encrypt transmission of cardholder data across open, public networks
  5. Use and regularly update anti-virus software on all systems commonly affected by malware
  6. Develop and maintain secure systems and applications
  7. Restrict access to cardholder data by business need-to-know
  8. Assign a unique ID to each person with computer access
  9. Restrict physical access to cardholder data
  10. Track and monitor all access to network resources and cardholder data
  11. Regularly test security systems and processes
  12. Maintain a policy that addresses information security

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FTC Delays Red Flags Rule Until August 1, 2009

The Federal Trade Commission has again delayed the enforcement of the "Red Flags" Rule to give business more time to prepare programs to comply with the law. The FTC is making available new materials to help business better understand the rule's requirements, and templates designed to assist in creating identity theft prevention programs that are appropriate to the size of a particular business.

What are the "Red Flag" Rules?

The rules implement sections 114 and 315 of the Fair and Accurate Credit Transactions Act of 2003.

They require "each financial institution and creditor that holds any consumer account, or other account for which there is a reasonably foreseeable risk of identity theft, to develop and implement an Identity Theft Prevention Program (Program) for combating identity theft in connection with new and existing accounts. The Program must include reasonable policies and procedures for detecting, preventing, and mitigating identity theft."

What are basic elements of an Identity Theft Prevention Program?

According to the FTC's Red Flags Rule How To Guide for Business, there are four basic elements of and Identity Theft Prevention Program?

First, your Program must include reasonable policies and procedures to identify the "red flags" of identity theft you may run across in the day-to-day operation of your business. Red flags are suspicious patterns or practices, or specific activities, that indicate the possibility of identity theft. For example, if a customer has to provide some form of identification to open an account with your company, an ID that looks like it might be fake would be a "red flag" for your business.

Second, your Program must be designed to detect the red flags you've identified. For example, if you've identified fake IDs as a red flag, you must have procedures in place to detect possible fake, forged, or altered identification.

Third, your Program must spell out appropriate actions you'll take when you detect red flags.

Fourth, because identity theft is an ever-changing threat, you must address how you will re-evaluate your Program periodically to reflect new risks from this crime.


 

HIPPA Compliance: Behavioral Characteristics Provide Identity Assurance and Access Management

Relentless technology advancement, the push for Electronic Medical Records (EMR) and integrating diagnostic device data, treatments, and patient history and response are priorities for healthcare facilities today. The challenge is not limited to systems and technologies within a facility, but across facilities because physicians and specialists often practice or share patients across facilities depending on the treatment course. With medical transcription increasingly getting outsourced, much information is managed and compiled externally but access is required when the patient visits.

While the intent of this advancement in technology is to provide ready access to information at the time of service delivery, healthcare practitioners (physicians, nurses, dieticians, specialists) must access multiple systems to get the information they need. Doctors find their productivity reduced by the time it takes them to log in and out. HIPAA compliance mandates patient information be available on a "need" basis to protect the privacy of the patients. Yet, it is not uncommon to find user IDs and passwords posted on or near the computer.  With patient care -- not data security -- the primary objective, it is not uncommon for practitioners to stay logged on to a system for extended periods, even when they step away and give others access. The challenge, therefore, is to leverage technology to increase the quality of healthcare while improving the productivity of the practitioners, without compromising the privacy of the patient.

Remembering more passwords or using single-sign-on (SSO) technology may not be the answer for healthcare. Second factor authentication increases security without impacting productivity.  Second factor authentication using external devices such as tokens, or proximity cards requires significant upfront investment for acquisition, integration, and training. Moreover, external devices tend to get lost or "borrowed", compromising the security of systems and the patient.

Consider, instead, using the behavioral characteristics of practitioners as a second factor. Individuals are products of many variables in unique combination that define specific cognitive capabilities.  Given how a person responds to the environment - from typing on a keyboard, to thinking, and behavior given certain external stimuli, it is possible to capture behavioral characteristics, match them with environmental and system variables to assemble a unique digital imprint of a user.

This goes beyond identifying an individual based on what a person knows (User ID and Password) and what a person has (cell phone, token ID). Systems can identify an individual based on "who they are" and "what they do".

Albert Einstein said, "The significant problems that we face cannot be solved at the same level of thinking we were at when we created them". Leveraging the capabilities available requires a paradigm shift in thinking.  Security does not have to be physically bolted on to an individual. It can be the individual, using keystroke dynamics, reflective thinking, environmental, and system variables. The system must provide identity verification for the user in real time. The solution must monitor multiple factors and assess risk based on business policies and guidelines to provide a true multi-factor risk-based authentication solution that protects the system from fraudulent attack and increases the user productivity.

Delfigo Security offers a zero footprint security solution platform that helps companies provide strong authentication to protect against identity and data theft.

Bharat Nair is Vice President of Business Development at Delfigo Security, http://www.delfigosecurity.com/, Boston, MA. He can be reached at This e-mail address is being protected from spambots. You need JavaScript enabled to view it or by phone at 1.617.248.6501


 


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