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Take On Payments, a blog sponsored by the Retail Payments Risk Forum of the Federal Reserve Bank of Atlanta, is intended to foster dialogue on emerging risks in retail payment systems and enhance collaborative efforts to improve risk detection and mitigation. We encourage your active participation in Take on Payments and look forward to collaborating with you.

Take On Payments

November 5, 2018


Organizational Muscle Memory and the Right of Boom

"Left of boom" is a military term that refers to crisis prevention and training. The idea is that resources are focused on preparing soldiers to prevent an explosion or crisis—the "boom!" The training they undergo in left of boom also helps the soldiers commit their response to a crisis, if it does happen, to muscle memory, so they will act quickly and efficiently in life-threatening situations.

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The concept of the boom timeline has been applied to many other circumstances, as I can personally attest. More years ago than I will admit to, I was a teller and had to participate in quarterly bank-robbery training that focused on each employee's role during and immediately after a robbery. The goal was to help us commit these procedures to muscle memory so that when we were faced with a high-stress situation, our actions would be second nature. My training was tested one day when I came face-to-face with a motorcycle-helmet-wearing bank robber who leaped over the counter into the teller area. Like most bank robbers, he was in and out fast, but thanks to muscle memory, we were springing into action as soon as he was leaping back over the counter and running out of the branch.

This type of muscle memory preparation has also been applied to cybersecurity. Organizations commit significant human and capital resources to the left of boom to help prevent and detect threats to their networks. Unfortunately, cybersecurity experts must get things right 100 percent of the time while bad actors have to be right only once. So how do organizations prepare for the right of boom?

Recently, I had the opportunity to observe a right-of-boom exercise that simulated a systemic cyberbreach of the payments system. This event, billed as the first of its kind, was sponsored by P20 and held in Cambridge, Massachusetts. Cybersecurity leaders from the payments industry convened to engage in a war games exercise that was ripped from the headlines. The scenario: a Thanksgiving Day cyberbreach, the day before the biggest shopping day of the year, of a multinational financial services company that included the theft and online posting of 75 million customer records, along with a ransomware attack that shut down the company's computer systems. The exercise began with a phone call from a reporter asking for the company's response to the posting of customer records online—BOOM! Immediately, the discussion turned to an incident response plan. What actions would be taken first? Who do you call? How do you communicate with employees if your system has been overtaken by a ransomware attack? How do you serve your customers? What point is the "in case of fire break glass" moment, meaning, has your organization defined what constitutes a crisis and agreed on when to initiate the crisis response plan?

An overarching theme was the importance of the "commander's intent," which reflects the priorities of the organization in the event of an incident. It empowers employees to exercise "disciplined initiative" and "accept prudent risk"—both principles associated with the military philosophy of "mission command"—so the company can return to its primary business as quickly as possible. In the context of a cyberbreach that has shut down communication channels within an organization, employees, in the absence of management guidance, can analyze the situation, make decisions, and then take action. The commander's intent forms the basis of an organization's comprehensive incident response plan and helps to create a shared understanding of organizational goals by identifying the key things your organization must execute to maintain operations.

Here is an example of a commander's intent statement:

Process all deposits and electronic transactions to ensure funds availability for all customers within established regulatory timeframes.

Having a plan in place where everyone from the top of the organization down understands their role and then practicing that plan until it becomes rote, much like my bank robbery experience, is critical today.

Photo of Ian Perry-Okara  By Nancy Donahue, project manager in the Retail Payments Risk Forum at the Atlanta Fed

 

November 5, 2018 in consumer protection, cybercrime, cybersecurity | Permalink

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October 22, 2018


Three Views of Noncash Payments Fraud

Despite what we might gather from the headlines, payments fraud is a small fraction of the value of all payments.In 2015, by value, it was only about 1/200 of 1 percent of noncash payment transactions. The pie chart shows what a tiny slice of the pie that payments fraud is.

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This view of the value of payments fraud in 2015 is one of three views that today's post will offer, using data from a recently released payments fraud report.

The report, based on data from the Federal Reserve Payments Study, quantifies noncash payments fraud by value and number in 2012 and 2015 and provides information that can help inform efforts to prevent and detect payments fraud. Data include detail on different payment instruments and transaction types.

Fraud value is defined in the report to be the value of unauthorized third-party payments that were cleared and settled, before any chargebacks, returns, or recoveries. It does not include the costs of any prevention, detection, or remediation methods. The report covers noncash payments used for everyday consumer and business transactions, including automated clearinghouse (ACH), check, and card payments. (Wires are excluded.)

Here's the next view of payments fraud by value: most payments fraud is by card. Slightly more than three-quarters of noncash payments fraud by value are credit card, debit card (prepaid and non-prepaid), and ATM withdrawal fraud; almost half is credit card fraud. The second chart shows that by value, ACH fraud is 14 percent of noncash payments fraud and check fraud is 8.6 percent.

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Finally, fraud rates by value for cards increased from 2012 to 2015 while fraud rates for check payments decreased and fraud rates for ACH stayed flat. That rate increase for cards means that the value of fraudulent card payments grew faster than the dollar-value growth overall, which is concerning. Indeed, card fraud by value grew more than three times faster than the growth in card payments and ATM withdrawals by value—64 percent compared to 21 percent. ACH fraud grew more in line with the growth rate in ACH payments, with fraud by value increasing 11 percent compared to a 13 percent increase in the value of total ACH payments.

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You can find additional data in the report at https://www.federalreserve.gov/paymentsystems/fr-payments-study.htm.

To learn more about the payments fraud report, join our next Talk About Payments webinar on November 1 at 11 a.m. (ET). The webinar is open to the public but you must register in advance to participate. (Registration is free.) Once registered, you will receive a confirmation email with login and call-in information. Also, be sure to check back next Monday for another Take On Payments post about the report.

Photo of Claire Greene By Claire Greene, a payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

 

October 22, 2018 in cards, consumer fraud, cybercrime, cybersecurity, debit cards, payments study | Permalink

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October 1, 2018


Safeguarding Things When They’re All Connected

In a July 6 post, I discussed the explosive growth of internet-of-things (IoT) devices in the consumer market. I expressed my concerns about how poor security practices with those devices could allow criminals to use them as gateways for fraudulent activity. At a recent technology event for Atlanta Fed employees, Ian Perry-Okpara of the Atlanta Fed’s Information Security Department led an information session on better ways to safeguard IoT devices against unauthorized access and usage. Ian and I have collaborated to provide some suggestions for you to secure your IoT device.

Prepurchase

  • Visit the manufacturer's website and get specific product information regarding security and privacy features. Is encryption being used and, if so, what level? What data is being collected, where and how long is it being stored, and is it shared with any other party? Does the product have firmware that you can update? Does it have a changeable password? (You should avoid devices that cannot receive updates or have their passwords changed.) What IoT standards have been adopted?
  • Check with reliable product review sites to see what others have to say about the product’s security features.
  • If your home network router supports a secondary "guest" network, create one for your IoT devices to separate them from your more secure devices such as desktop and laptop computers and printers.

Postpurchase

  • Especially if your device is used or refurbished or was a display model, immediately perform a factory reset if it’s equipped that way in case someone has modified the settings.
  • Download the most recent firmware available for the device. Often, a newer firmware will become available during the period the merchant held the device.
  • Use strong password techniques and change the user ID and password from the factory settings. Use different passwords for each one of your IoT devices.
  • Register your device with the manufacturer to be notified of security updates or recalls.
  • Add the device to your separate network if available.

If you adopt these suggestions, you will have a secure IoT network that will minimize your risk of attack. Criminals will be much less able to take over your IoT devices for bot attacks or for going through them to gain entry into other devices on your home network. You do not want the criminals to get at personal information like your credentials to your financial services applications.

We hope this information will be helpful. If you have other suggestions to better secure your IoT devices, we certainly would like to hear from you.

Photo of Ian Perry-Okara  By Ian Perry-Okpara, an information security architect in the Information Security Department at the Atlanta Fed

 

Photo of David Lott  By David Lott, a payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

 

October 1, 2018 in account takeovers, cybercrime, cybersecurity, data security, identity theft, innovation | Permalink

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September 4, 2018


The First Step in Risk Management

One of the main objectives of information security is having a solid risk management strategy, which involves several areas: policy, compliance, third-party risk management, continuous improvement, and security automation and assessment, to name a few. This diagram illustrates at a high level the full cycle of a risk management strategy: adopting and implementing a framework or standards, which leads to conducting effective risk assessments, which then leads to maintaining continuous improvement.

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One of the main objectives of information security is having a solid risk management strategy, which involves several areas: policy, compliance, third-party risk management, continuous improvement, and security automation and assessment, to name a few. This diagram illustrates at a high level the full cycle of a risk management strategy: adopting and implementing a framework or standards, which leads to conducting effective risk assessments, which then leads to maintaining continuous improvement.

There are more than 250 different security frameworks globally. Examples include the National Institute of Standards and Technology's (NIST) Framework for Improving Critical Infrastructure Cybersecurity, the Capability Maturity Model Integration (CMMI)®, and the Center for Information Security's Critical Security Controls. (In addition, many industries have industry-specific standards and laws, such as health care's HIPAA, created by the Health Insurance Portability and Accountability Act.) Each framework is essentially a set of best practices that enables organizations to improve performance, important capabilities, and critical business processes surrounding information technology security.

But the bad news is that, on average, 4 percent of people in any given phishing campaign open an attachment or click a link—and it takes only one person to put a company or even an industry at risk. Does your overall strategy address that 4 percent and have a plan in place for their clicks? The report also found that the more phishing emails someone has clicked, the more they are likely to click in the future.

So, outside of complying with legal and regulatory requirements, how do you determine which framework or frameworks to adopt?

It depends! A Tenable Network Security report, Trends in Security Framework Adoption, provides insight into commonly adopted frameworks as well as the reasons companies have adopted them and how fully. Typically, organizations first consider security frameworks that have a strong reputation in their industries or for specific activities. They then look at compliance with regulations or mandates made by business relationships.

This chart shows reasons organizations have adopted the popular NIST Cybersecurity Framework.

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The study found that there is no single security framework that the majority of companies use. Only 40 percent of respondents reported using a single security framework; many reported plans to adopt additional frameworks in the short term. Close to half of organizations (44 percent) reported they are using multiple frameworks in their security program; 15 percent of these are using three or more.

This year, the Federal Reserve System's Secure Payments Taskforce released Payment Lifecycles and Security Profiles, an informative resource that provides an overview of payments. Each payment type accompanies a list of applicable legal, regulatory, and industry-specific standards or frameworks. Spoiler alert: the lists are long and complex!

Let me point out a subsection appearing with each payment type that is of particular interest to this blog: "Challenges and Improvement Opportunities." Scroll through these subsections to see specific examples calling for more work on standards or frameworks.

Organizations need choices. But having too many frameworks to choose from, coupled with their constantly changing nature and the fluid payments environment, can complicate the implementation of a risk management strategy. With so many choices and so much in flux, how did you manage with step one of your risk management strategy?

Photo of Jessica Washington By Jessica Washington, AAP, payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

September 4, 2018 in consumer protection, cybercrime, cybersecurity, payments risk, risk management | Permalink

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August 20, 2018


With Social Engineering, It Takes Only One

I recently wrote a post about the time I spent job shadowing in my employer's Information Security Department (ISD). One of the main objectives of the job shadow program is to allow ISD to introduce their communication, education, and outreach efforts to employees. This department works constantly to make employees aware of trending security threats, especially social engineering, and they have to do it in a way that gets the employees' attention. Creating a security-aware culture is critical because it takes just one employee, just one time, to cause a significant risk event. ISD has found that if they deliver messages in a fun way—such as an annual chili cook-off—more ears are open to hear them.

The Retail Payments Risk Forum follows social engineering trends closely since social engineering presents a major security risk and it directly affects payments. These attacks can easily open a gateway for criminals to access payment systems or any protected information system. Here's a quick review of social engineering: it relies on manipulating human behaviors through direct or indirect communication, and it does not necessarily involve technology. As computer security grows increasingly sophisticated, some criminals have found it can be easier to manipulate an individual than to game a machine. Some reports say that social engineering schemes have cost U.S. businesses nearly $3 billion since 2013. It's no wonder that social engineering is a growing concern.

A common social engineering attack is phishing, which is when the criminal uses an email that appears to be from a legitimate company to get people to respond with personal information such as account credentials. According to one company's report, phishing and pretexting in 2017 represented 98 percent of social incidents and 93 percent of breaches. (Pretexting often involves a scam whereby one individual lies to get personal information from another individual. A pretexter, for example, might pretend to be conducting a survey.) At 96 percent, email continues to be the most common vector. The good news is that 78 percent of people who were phished last year didn't open a single email, according to the same report.

But the bad news is that, on average, 4 percent of people in any given phishing campaign open an attachment or click a link—and it takes only one person to put a company or even an industry at risk. Does your overall strategy address that 4 percent and have a plan in place for their clicks? The report also found that the more phishing emails someone has clicked, the more they are likely to click in the future.

Psychological manipulation is a powerful tool to try to influence someone to divulge sensitive information. Since social engineer fraudsters need to reel in just one victim, we need to ensure that every single employee hears the message. Promoting security awareness scratches the surface in fighting social engineering, but it needs to be fun and creative constantly.

Look for one more post in this series describing my time in the job shadowing program in my employer's Information Security Department.

Photo of Jessica Washington By Jessica Washington, AAP, payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

August 20, 2018 in cybercrime, cybersecurity | Permalink

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August 6, 2018


The FBI Is on the Case

I recently took advantage of a job shadow program in our Information Security Department (ISD). I joked with our chief information security officer that I was ready to "ride along" with his detectives for our own version of the television drama series Crime Scene Investigations (better known as CSI).

All jokes aside, I enjoyed working with ISD as part of the team rather than as an auditor, a role I have played in the past. We spent a good part of the day walking through layered security programs, vulnerability management, and data loss prevention. Underneath these efforts is an important principle for threat management: you can't defend against what you don't know.

Threat investigations absolutely must uncover, enumerate, and prioritize threats in a timely manner. Digging into each vulnerability hinges on information sharing through adaptable reporting mechanisms that allow ISD to react quickly. ISD also greatly depends on knowledge of high-level threat trends and what could be at stake.

It turns out that many payments professionals and law enforcement agencies also spend a large part of their time investigating threats in the payments system. After my job shadowing, I realized even more how important it is for our payments detectives to have access to efficient, modern information-sharing and threat-reporting tools to understand specific threat trends and loss potential.

One such tool is the Internet Crime Complaint Center (IC3). The FBI, which is the lead federal agency for investigating cyberattacks, established the center in May 2000 to receive complaints of internet crime. The mission of the IC3 is two-fold: to provide the public with a reliable and convenient reporting mechanism that captures suspected internet-facilitated criminal activity and to develop effective alliances with industry partners. The agency analyzes and disseminates the information, which contributes to law enforcement work and helps keep the public informed.

The annual IC3 report aggregates and highlights data provided by the general public. The IC3 staff analyze the data to identify trends in internet-facilitated crimes and what those trends may represent. This past year, the most prevalent crime types reported by victims were:

  • Nonpayment/Nondelivery
  • Personal data breach
  • Phishing

The top three crime types with the highest reported losses were:

  • Business email compromise
  • Confidence/Romance fraud
  • Nonpayment/Nondelivery

The report includes threat definitions, how these threats relate to payments businesses, what states are at the highest risk for breaches, and what dollar amounts correspond to each crime type. This is one tool available to uncover, enumerate, and prioritize threats to the payment ecosystem. Do you have other system layers in place to help you start your investigations? If you don't know, it might be time for you to take a "ride along" with your detectives.

Photo of Jessica Washington By Jessica Washington, AAP, payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

August 6, 2018 in consumer fraud, consumer protection, cybercrime, cybersecurity, data security, fraud, identity theft, risk management | Permalink

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July 23, 2018


Learning about Card-Not-Present Fraud Mitigation

Over the last year, I have had the pleasure of working with Fed colleagues and other payments industry experts on one of the Accredited Standards Committee's X9A Financial Industry Standards workgroups in writing a technical report on U.S. card-not-present (CNP) fraud mitigation. You can download the final report (at no cost) from the ANSI (American National Standards Institute) web store.

As this blog and other industry publications have been forecasting for years, the migration to payment cards containing EMV chips may already be resulting in a reduction of counterfeit card fraud and an increase in CNP fraud and other fraudulent activity. This has been the trend in other countries that have gone through the chip card migration, and there was no reason to believe that it would be any different in the United States. The purpose of the technical report was to identify the major types of CNP fraud and present guidelines for mitigating these fraud attacks to the various payments industry stakeholders.

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Source: Data from Card-Not-Present (CNP) Fraud Mitigation in the United States, the 2018 technical report prepared by the Accredited Standards Committee X9, Incorporated Financial Industry Standards

After an initial section identifying the primary stakeholders that CNP fraud affects, the technical report reviews five major CNP transaction scenarios, complete with transaction flow diagrams. The report continues with a detailed section of terms, definitions, and initialisms and acronyms.

The best defense against CNP fraud from an industry standpoint is the protection of data from being breached in the first place. Section 5 of the report reviews the role that data security takes in CNP fraud mitigation. It contains references to other documents providing detailed data protection recommendations.

Criminals will gather personal and payment data in various attacks against those who don't use strong data protection practices, so the next sections deal with the heart of CNP fraud mitigation.

  • Section 6 identifies the major types of CNP fraud attacks, both attacks that steal data and those that use that data to conduct fraudulent activities.
  • Section 7 reviews mitigation tools and approaches to take against such attacks. The section is subdivided into perspectives of various stakeholders, including merchants, merchant acquirers and gateways, issuers and issuer processors, and, finally, payment card networks.
  • Section 8 discusses how a stakeholder should identify key fraud performance metrics and then analyze, report, and track those metrics. While stakeholders will have different elements of metrics, they must each go to a sufficient level so the results will provide key insights and predictive indicators.

The report concludes with several annex sections (appendices) covering a variety of subjects related to CNP fraud. Suggestions for the improvement or revision of the technical report are welcome. Please send them to the X9 Committee Secretariat, Accredited Standards Committee X9 Inc., Financial Industry Standards, 275 West Street, Suite 107, Annapolis, MD 21401. I hope you will distribute this document among those in your institution involved with CNP fraud prevention, detection, and response to use as an educational or reference document. I think it will be quite useful.

Photo of David Lott By David Lott, a payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

 

July 23, 2018 in card networks, cards, consumer fraud, consumer protection, cybercrime, cybersecurity, debit cards, identity theft | Permalink

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July 6, 2018


Attack of the Smart Refrigerator

We've all heard about refrigerators that automatically order groceries when they sense the current supply is running low or out. These smart refrigerators are what people usually point to when giving an example of an "internet-of-things" (IoT) device. Briefly, an IoT device is a physical device connected to the internet wirelessly that transmits data, sometimes without direct human interaction. I suspect most of you have at least one of these devices already operating in your home or office, whether it's a wireless router, baby monitor, or voice-activated assistant or "smart" lights, thermostats, security systems, or TVs.

Experts are forecasting that IoT device manufacturing will be one of the fastest growing industries over the next decade. Gartner estimates there were more than 8 billion connected IoT devices globally in 2017, with about $2 trillion going toward IoT endpoints and services. In 2020, the number of these devices will increase to more than 20 billion. But what security are manufacturers building into these devices to prevent monitoring or outside manipulation? What prevents someone from hacking into your security system and monitoring the patterns of your house or office or turning on your interior security cameras and invading your privacy? For those devices that can generate financial transactions, what authentication processes will ensure that transactions are legitimate? It's one kind of mistake to order an unneeded gallon of milk, but another one entirely to use that connection to access a home computer to monitor one's online banking transaction activity and capture log-on credentials.

As one would probably suspect, there is no simple or consistent answer to these security questions, but the overall track record of device security has not been a great one. There have been major DDOS attacks against websites using botnets composed of millions of IoT devices. Ransomware attacks have been made against consumers' home security systems and thermostats, forcing consumers to pay the extortionist to get their systems working again.

Some of the high-end devices such as the driverless cars and medical devices have been designed with security controls at the forefront, but most other manufacturers have given little thought to the criminal's ability to use a device to access and control other devices running on the same network. Adding to the problem is that many of these devices do not get software updates, including security patches.

With cybersecurity issues grabbing so many headlines, people are paying more and more attention to the role and impact of IoT devices. The National Institute of Standards and Technology (NIST) has begun efforts to develop security standards for cryptology that can operate within IoT devices. However, NIST estimates it will take two to four years to get the standard out.

In the meantime, the Department of Justice has some recommendations for securing IoT devices, including:

  • Research your device to determine security features. Does it have a changeable password? Does the manufacturer deliver security updates?
  • After you purchase a device and before you install it, download security updates and reset any default passwords.
  • If automatic updates are not provided to registered users, check at least monthly to determine if there are updates and download only from reputable sites.
  • Protect your routers and home Wi-Fi networks with firewalls, strong passwords, and security keys.

I see IoT device security as an issue that will continue to grow in importance. In a future post, I will discuss the privacy issues that IoT devices could create.

Photo of David Lott By David Lott, a payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

July 6, 2018 in consumer fraud, cybercrime, cybersecurity, fraud, identity theft, innovation, online banking fraud, privacy | Permalink

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May 14, 2018


Is My Identity Still Mine?

I'm sure you've seen the famous cartoon by Peter Steiner published in the New Yorker in 1993. That cartoon alluded to the anonymity of internet users. Twenty-five years later, do you think it's still true? Or is the cartoon by Kaamran Hafeez that appeared in the February 23, 2015, issue of the New Yorker more realistic? Is online anonymity a thing of the past?

Cartoon-image

Having just returned from three days at the Connect: ID conference in Washington, DC, my personal perspective is that numerous key elements of my identity are already shared with thousands of others—businesses, governmental agencies, friends, business colleagues, and, unfortunately, criminals—and the numbers are growing. Some of this information I have voluntarily provided through my posts on various social media sites, but hopefully is available only to "friends." Other bits of my personal life have been captured by various governmental agencies—my property tax and voter registration records, for example. The websites I visit on the internet are tracked by various companies to customize advertisements sent to me. Despite the adamant disavowals of the manufacturers of voice assistant devices, rumors persist that some of the devices used in homes do more than just listen for a mention of their "wake up" name. And, of course, there is the 800-pound gorilla to consider: the numerous data breaches that retailers, financial institutions, health care providers, credit reporting agencies, and governmental agencies have experienced over the last five years.

The conference exhibit hall was filled with almost a hundred vendors who concentrated on this identity security issue. There were hardware manufacturers selling biometric capture devices of fingers, palms, hands, eyes, and faces. Others focused on customer authentication by marrying validation of a government-issued document such as a driver's license to live facial recognition. Remote identification and authentication of end users is becoming more and more common with our virtual storefronts and businesses, but is also becoming more challenging as the fraudsters look for ways to defeat the technology or overall process in some way.

I have yet to have my identity stolen or compromised, but notice I said "yet," and I have probably just jinxed myself. Unfortunately, I believe my identity is no longer just mine and is out there for the taking despite my personal efforts to minimize the availability of personal information. Do you agree?

Photo of David Lott By David Lott, a payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

May 14, 2018 in cybercrime, data security, fraud, identity theft, privacy | Permalink

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February 20, 2018


Best Practices for Data Privacy Policies

In my last couple of posts, I've discussed the issue of ethical policies related to data collection and analysis.  In the first one, I focused on why there is a need for such policies. The second post focused on ethical elements to include in policies directly involving the end user. Whether or not the customer is actively involved in accepting these policies, any company that collects data should have a strong privacy and protection policy. Unfortunately, based on the sheer number and magnitude of data breaches that have occurred, many companies clearly have not sufficiently implemented the protection element—resulting in the theft of personally identifiable information that can jeopardize an individual's financial well-being. In this post, the last of this series, I look at some best practices that appear in many data policies.

The average person cannot fathom the amount, scope, and velocity of personal data being collected. In fact, the power of big data has led to the origination of a new term. "Newborn data" describes new data created from analyses of multiple databases. While such aggregation can be beneficial in a number of cases—including for marketing, medical research, and fraud detection purposes—it has recently come to light that enemy forces could use data collected from wearable fitness devices worn by military personnel to determine the most likely paths and congregation points of military service personnel. As machine learning technology increases, newborn data will become more common, and it will be used in ways that no one considered when the original data was initially collected.

All this data collecting, sharing, and analyzing has resulted in a plethora of position papers on data policies containing all kinds of best practices, but the elements I see in most policies include the following:

  • Data must not be collected in violation of any regulation or statute, or in a deceptive manner.
  • The benefits and harms of data collection must be thoroughly evaluated, then how collected data will be used and by whom must be clearly defined.
  • Consent from the user should be obtained, when the information comes from direct user interaction, and the user should be given a full disclosure.
  • The quality of the data must be constantly and consistently evaluated.
  • A neutral party should periodically conduct a review to ensure adherence to the policy.
  • Protection of the data, especially data that is individualized, is paramount; there should be stringent protection controls in place to guard against both internal and external risks. An action plan should be developed in case there is a breach.
  • The position of data czar—one who has oversight of and accountability for an organization's data collection and usage—should be considered.
  • In the event of a compromise, the data breach action plan must be immediately implemented.

Photo of David Lott By David Lott, a payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

February 20, 2018 in consumer protection, cybercrime, data security, identity theft, privacy | Permalink

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