It happens in your office every day:  someone on your team hits a roadblock when they realize that email just won’t handle the huge file they need to send – immediately. Or another coworker starts to send an account number or password via email and realizes that perhaps, email isn’t all that secure.

That’s when the tech savvy gal in the corner suggests the obvious solution: just send that file or sensitive personal information via FTP!  She lists a variety of “free” tools that can be downloaded easily, as well as a couple cloud solutions, and in desperation (and often ignorance), your coworker takes her advice and a new FTPer is born.

FTP, or “file transfer protocol,” is a solution that’s been available for more than 30 years.  Within the last decade, so many free or inexpensive FTP tools have become available that many of us assume that FTP must be a reliable solution, or why would so many people be using it?

As we know with many of society’s ills, just because something is easy to find and popular to use doesn’t mean it’s a smart or effective idea.

The downside of FTP

While FTP may be able to send large files, standard FTP – like email — is not secure, and is therefore vulnerable to hackers.

Rogue FTP tools, like those free tools sprinkled on employees’ PCs, start to become a liability to the company, both financially and to its reputation and credibility.

To begin with, multiple employees with multiple FTP tools mean that no one has a master view of the flow of data in and out of your company. It’s impossible to know who is sending what to whom, and who is receiving files from where.

State and Federal laws require that data which contains personally identifiable information must be encrypted and secured. This also applies to most of the financial data that we collect and create. How can you keep tabs on all of this with a lot of FTP processes running on various PCs throughout the office?

Second, because FTP is not secure, the company increases its risk for a data breach.  Costs to notify those affected when a data breach occurs, combined with the fines that can be assessed, can be in the millions of dollars, not to mention the damage to the company’s brand.

If not FTP, then what?

One approach to control FTP traffic is to set up restrictions on the corporate firewall, essentially prohibiting access for all but specifically authorized personnel to the ports required for FTP processes to work.

Chances are, though, that the same tech savvy employee who suggested FTP in the first place also knows how to bypass this restriction by finding different ports or switching to online FTP services. For determined FTPers, even our cell phones are equipped to send and receive files.

So, if it’s hard to stop it, the next best option is to educate your employees, and to develop and promote clear expectations and consequences regarding sending files and sensitive data from work. Many employees want to do the right thing, but don’t understand the implications of sending sensitive data through the easiest – though not necessarily the safest – means.

Another option that is rapidly growing in popularity is the implementation of a managed FTP solution that can be configured to allow users to send and receive large files  and sensitive information within their daily workflow, but with the addition of administrative control and much greater security.

A managed file transfer solution such as Linoma Software’s GoAnywhere Suite, in combination with setting up appropriate firewall rules and educating all employees of corporate policy and procedures,  will keep your employees – tech savvy or not – productive and happy, and give your IT department peace of mind knowing that the company data is secure.

Daniel Cheney

Daniel has been the IT Director at a healthcare company for the last 12 years and a longtime beneficiary of GoAnywhere Director and the IBM i platform. He is also a technical analyst and writer for various technical and social media projects with Humanized Communications.

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Many Americans have spent the last few days frantically searching for receipts and other documentation to finish their taxes before Tuesday, April 17.  No doubt some of those people thought they knew exactly where to find what they needed, and were dismayed to discover that their confidence — as well as their data — had been misplaced.

How about your confidence regarding your organization’s sensitive data? As managers, are you aware of all of the transactions going in and out of the company network? Who is sending and pulling files, and why? What’s the best way to manage all of these data exchanges? Isn’t there a more user-friendly solution than prohibiting all FTP communications except from specified computers or user profiles?

Efficient workflow requires efficient data flow

No doubt data security is critical.  So is the ability to exchange information to accomplish daily business goals.  Almost every department needs to exchange files with trading partners, customers, vendors, remote employees, and more.

Here are just a few examples of data your company may be exchanging every day:

Finance/Accounting/HR

• Tax documents
• Annual, quarterly monthly reports to shareholders, investors, banks, financial partners
• Personnel reporting

Marketing/Sales

• Art files to/from artists, printers, marketing partners
• Video and other content for web, publishers, printers
• PDF brochures, proposals, whitepapers to prospects, partners, customers

Information Technologies

• Data files to/from system integration partners
• Database exchanges with business networks
• System updates
• EDI file transaction exchanges
• Update to HA and offsite systems

Customer Service

• Customer update documents
• Client reporting documents
• Receipt of supporting documents

Production/Warehousing

• Supplier data exchange
• Customer data exchange
• Inventory reporting

Research & Development

• Product specifications to/from manufacturing partners
• Large CAD/engineering data to/from development partners

How do you control the data flow?

Educate your employees

Each organization has developed rules and codes of conduct to maintain productivity, positive morale, and customer confidence.  Ideally, these policies are documented and part of employee training. It’s imperative that the rules governing data management are also included in the documented policies, and all employees regardless of their roles need to demonstrate their understanding of the data management policies. Clear directives regarding management’s expectations is the first line of defense against data breach.

Implement the appropriate technology solution

The right technology tools can also be a valuable part of the data control approach.  Most data exchanges can be performed through secure email, FTP and network communications. A combined implementation of firewall and managed FTP solutions will help secure and distribute the resource requirements as appropriate for every department’s needs.

Firewalls not only protect the company network from outside intruders, but can also help manage internal traffic.  A managed file transfer (MFT) system allows specific types of transfers based on users’ permissions or specified events so the inbound/outbound flow of data can be better managed and monitored. With an MFT system, audit logs are automatically kept of each data exchange, and files and emails can be encrypted and secured to ease worries that they might be sent to the wrong people.

The bottom line

Given the multitude of data files that need to be moved in and out of your organization, and the need to create efficient workflows that allow employees to do their jobs while maintaining strict vigilance about data security, few facets of your business are more important than controlling your data flow.  Getting information in the right hands and keeping sensitive data shielded from non-authorized access is an ongoing challenge, but education and the right tools are the keys to success.

Daniel Cheney

Daniel has been the IT Director at a healthcare company for the last 12 years and a longtime beneficiary of GoAnywhere Director and the IBM i platform. He is also a technical analyst and writer for various technical and social media projects with Humanized Communications.

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During the past few years, the media has highlighted a variety of examples of the loss of private information by large companies either by theft or misuse.

One of the reasons for the increased media attention is the renewed focus on establishing and enforcing data breach notification laws which apply to companies that own, lease or store private, personally identifiable information. If that data is exposed to unauthorized use either by accident, cyber attack, employee misconduct, or other causes, most states require companies responsible for protecting that data to announce the data breach and individually notify everyone affected. Some states require that credit agencies are also notified.

For clarification, private data means any information that can be used to identify an individual, including sensitive information such as a credit card number, social security number, or health related data.

There are a few exceptions to having to report the data breach. If the compromised files were encrypted while in transit across the Internet or stored on stolen backup tapes, for example, it is unlikely that the files could be unencrypted, so the individuals’ privacy isn’t as likely to be compromised.

A company that finds itself dealing with a data breach learns quickly that the process is not just embarrassing and costly (sending notifications, providing free credit reports, etc.), it can also damage the company’s hard-earned reputation resulting in the loss of customers. The point is that companies are responsible – and legally liable — for the information that is in their hands.

Securing File Transfers

Most companies use FTP (file transfer protocol) to send data files back and forth to their trading partners, vendors, remote employees, etc. Most often, FTP is used to send files that are too large to email.

However, file transfers like these are captured and compromised by data thieves on the Internet every day — unless security procedures have been put into place to safeguard the files’ data.

Companies need to implement procedures that secure both an in-motion process (files in transit over the Internet) and an at-rest process (files stored on servers or backup tapes). SFTP and FTPS protocols both secure the file while in motion by encrypting the communication link between two systems during the file transfer. PGP encrypts the file itself, protecting it while at rest on the server or backup tapes.

When addressing the challenge of sending ad-hoc files that are too big to email, finding a managed file transfer solution that includes a secure mail feature can mean the difference between an accidental data breach and a successfully delivered file.

Implementing these security procedures is a significant step organizations can take to greatly reduce their risk of data breach, and therefore their exposure to the financial liability and the loss of confidence of their customers and trading partners.

Daniel Cheney

Daniel has been the IT Director at a healthcare company for the last 12 years and a longtime beneficiary of GoAnywhere Director and the IBM i platform. He is also a technical analyst and writer for various technical and social media projects with Humanized Communications.

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The data breach at Citigroup in May – a breach which reportedly exposed an estimated 200,000 customer accounts – has motivated members of the U.S. Congress to re-introduce legislation to penalize the very organizations that have been victimized by hackers.  What are the next steps your company should take?

New bills to protect consumers’ personal data

Two bills are proposed by both House and Senate legislators.

First, Sen. Patrick Leahy (D-Vt.) has introduced the Personal Data Privacy and Security Act of 2011.  The new bill provides:

• Tough criminal penalties for individuals who intentionally or willfully conceal a security breach involving personal data;
• A requirement that companies that maintain personal data establish and implement internal policies to protect data privacy and security; and
• A requirement that the government ensure sensitive data is protected when the government hires  third-party contractors.

This act would also require, under threat of fine or imprisonment, that businesses and agencies notify affected individuals of a security breach by mail, telephone or email  “without unreasonable delay.” Media notices would be required for breaches involving 5,000 or more people.  The FBI and the Secret Service would need to be notified if the breach affects 10,000 or more people, compromises databases containing the information of one million or more people, or impacts federal databases or law enforcement.

But that’s not the only security bill that has businesses concerned.

In the House, Rep. Mary Bono Mack (R-Ca) is holding hearings in preparation of a bill she’s named The SAFE (Secure and Fortify) Data Act that would also require “reasonable security policies and procedures” to protect consumers and enable disclosures to victims and the Federal Trade Commission within 48 hours of a data breach.

Companies no longer viewed as the victims

All this sounds good from the consumer’s point of view. But what about the expense – and potential penalties – suffered by the “owners” of the data: the businesses themselves?

While these bills may address the public’s interest for notification — and indeed they would bring some semblance of a national standard – they also represent an interesting shift in the liabilities that companies will face.  How is that?

Though we currently have no federal data breach notification law, federal policies now view the companies that experience a data breach as the victims of crime. However, under the proposed legislative bills, companies that do not act quickly to appropriately secure the personal data of customers – or fail to report a data breach in a reasonable amount of time – would not only suffer the theft of data, but also be held liable for its loss.

This is a significant shift. Companies are now being viewed not as the owners of consumer data, but merely guardians and trustees whose job it is to protect that data or face criminal penalties. And the message is clear: if companies won’t take adequate precautions to secure the sensitive data of our customers, they’ll pay a hefty price.

Where does your company stand?

In a world in which diligent hackers have the power break into seemingly secure networks and systems, what can your company do?

The challenge is first to determine exactly what qualifies as adequate precautions.

A review of the HIPAA HITECH security provisions that took effect last year provides some insight about what the government considers adequate protection.

HITECH strongly recommends the use of encryption technology. Encryption is a good place for your company to start, especially when dealing with the data your company stores on its servers.  If sensitive data itself is kept securely encrypted, a data breach doesn’t expose the content of the information itself.

Secure managed file transfer protocols – which send data using encryption – is the second place to focus attention.

If data is encrypted when it is being securely transmitted between business partners, the value of that data should it be breached – through hacking, theft, or other malicious actions – is worthless.  Encryption and secure managed file transfers can dramatically minimize the holes of technical breaches, significantly reducing an organization’s liability.

Preventing exposure

The Citigroup data breach has rekindled the momentum for a nationwide, cross-industry data breach reporting standard. This standard will not to eliminate the physical breaches themselves. What’s needed is legislation to encourage companies secure the underlying data that is the target of the hackers.

Isn’t it time for your company to take a serious look at its liabilities and to investigate how encryption and managed file transfers can close these important security holes?

Thomas Stockwell

Thomas M. Stockwell is one of Linoma Software's subject matter experts and a top blogger in the industry. He is Principle Analyst at IT Incendiary, with more than 20 years of experience in IT as a Systems Analyst, Engineer, and IS Director.

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Most data breaches are caused by simple acts of carelessness.

Last March the Ponemon Institute released its findings for the 2010 Annual Study: U.S. Cost of a Data Breach. The study — based on the actual data breach experiences of 51 U.S. companies from 15 different industry sectors — revealed that data breaches grew more costly for the fifth year in a row. They jumped from $204 per compromised record in 2009 to $214 in 2010.

The increase in cost, however, pales in comparison to the reputational cost of companies that have been victimized, particularly in the healthcare sector.

HITECH builds Wall of Shame

Consider that the U.S. Department of Health and Human Services has begun posting the data breaches affecting 500 or more individuals as required by section 13402(e)(4) of the HITECH Act.  The New York Times has labeled this site “The Wall of Shame”.  Why? Because if patients have no faith in electronic record-keeping, the future of healthcare record automation will be jeopardized: Law suits and government regulation will bury any cost-savings.

The Back Stories of Healthcare Data Breaches

What are the stories behind the most severe healthcare sector data breaches reported in 2010?  Here are the ten most expensive stories, in ascending order of cost, documented in the Privacy Rights Clearing House database. While they’re sober reminders of the problem of keeping data secure, they’re also instructive: none of these breaches were malicious hacks, but were instead the results of theft, poor record-keeping policies, and simple human error.

(Note that the estimate of liability uses the $214/ record cost identified by the Ponemon Institute in its annual report. We have purposely not published the names of the reporting institutions.)

10^th Most Expensive: Physician Computer Theft Exposes 25,000

On June 29^th of 2010 a thief stole four computers from a physician specialist’s office in Fort Worth, Texas.  This theft resulted in an estimated 25,000 patient records being exposed.  The patient records contained addresses, Social Security numbers and dates of birth. Estimated liability: $5,350,000.

9^th: Medical Center Theft Exposes 39,000

On the weekend of May 22^nd, 2010 two computers were stolen from a medical center in the Bronx. Names, medical record numbers, Social Security numbers, dates of birth, insurers, and hospital admission dates of patients were known to be on the computers.  Total records compromised: 39,000. Estimated liability: $8,346,000.

8^th: Optometrist’s Computer Theft Exposes 40,000

A computer stolen from an Optometry office in Santa Clara, California on Friday April 2nd, 2010 contained patient names, addresses, phone numbers, email addresses, birth dates, family member names, medical insurance information, medical records, and in some cases, Social Security numbers. Though the files were password protected, they were not encrypted.  A total of 40,000 records were lost, with an estimated liability of $8,560,000.

7^th: Medical Records Found at Dump Expose 44,600

Medical records were found at a public dump in Georgetown, Massachusetts on August 13^th, 2010. The records contained names, addresses, diagnosis, Social Security numbers, and insurance information. A medical billing company that had worked for multiple hospitals was responsible for depositing the records at the dump. The exposure required the hospitals to notify patients – an effort that continues to this date.  The total number of records known to have been exposed is 44,600, but the search continues.  Estimated liability: $9,544,400.

6^th: Consultant Laptop Stolen Exposing 76,000

On March 20^th, 2010, in Chicago, Illinois, a contractor working for a large dental chain found his laptop stolen.  The computer held a database containing the personal information of approximately 76,000 clients, including first names, last names and Social Security numbers. Estimated liability: $16,264,000.

5^th: Lost CDs Expose 130,495

On June 30^th, 2010 a medical center in the Bronx reported that it had failed to receive multiple CDs containing patient personal information that was sent to it by its billing associate.  These CDs were lost in transit. Information of 130,495 patients included the dates of birth, driver’s license numbers, descriptions of medical procedures, addresses, and Social Security numbers.  Estimated liability of $27,925,930.

4^th: Portable Hard Drive Theft Exposes 180,111

In Westmont, Illinois, a medical management resources company reported on May 10, 2010 that a portable hard drive had been stolen after a break-in.  The company believes the hard drive contained personally identifiable information about patients including name, address, phone, date of birth, and Social Security number. The company acknowledged that this hard drive had no encryption.  As a result, 180,111 records were exposed, creating an estimated liability of $38,543,754.

3^rd: Leased Digital Copier Leaks 409,262

On April 10^th, 2010 a New York managed care service in the Bronx reported that it was notifying 409,262 current and former customers, employees, providers, applicants for jobs, plan members, and applicants for coverage that their personal data might have been accidentally leaked through a leased digital copier. The exposure resulted because the hard drive of the leased digital copier had not been erased when returned to the warehouse. Estimated liability: $87,582,068.

2^nd: Training Center Hard Drive Theft Center Exposes 1,023,209

The theft of 57 hard drives from a medical insurance company’s Tennessee training facility in October of 2010 put at risk the private information of an estimated 1,023,209. customers in at least 32 states. The hard drives contained audio files and video files as well as data containing customers’ personal data and diagnostic information, date of birth, and Social Security numbers, names and insurance ID numbers. That data was encoded but not encrypted. Estimated liability to date: $218,966,726.

Most Expensive of 2010: Two Laptops Stolen Exposes 860,000

A Gainsville, Florida health insurance company reported in November of 2010 that two stolen laptops contained the protected information of 1.2 million people.  This is an on-going story, as new estimates are calculated.  To date, the estimated liability is $256,800,000.

Preventing Exposure: Data Encryption

These cases document that the majority of the data breaches which occurred in 2010 were not the result of hacking activities, or even unauthorized access by personnel. The greatest data losses were simply the result of computer theft of portable devices and misplaced media.  Had the contents of the files been encrypted, this could have significantly reduced the risks and liabilities of these data losses.

Time and time again, industry experts point to data encryption as the key method by which organizations can prevent inadvertent exposure of sensitive data.

Of course, no healthcare organization wants to be listed on the US Department of Health and Humans Services’ Wall of Shame.  And the costs – in dollars and in reputation – can be extraordinary.

Isn’t it about time your management got serious about data encryption?

Thomas Stockwell

Thomas M. Stockwell is one of Linoma Software's subject matter experts and a top blogger in the industry. He is Principle Analyst at IT Incendiary, with more than 20 years of experience in IT as a Systems Analyst, Engineer, and IS Director.

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