mailing list archives
Re: PII SSN question
From: levinson_k () securityadmin info
Date: 15 Aug 2007 22:00:57 -0000
Requirements for whom? I assume you're talking federal government. If you're anyone else, I'm not sure there are any
requirements at all, because who would levy the requirements? OMB sent out a memo about PII protection but I believe
that applies primarily to federal government uses only.
RE: federal government handling of PII, the only thing I know of is here:
I don't believe there are any government-wide requirements yet for storage of PII. PII protection is a fairly new
topic for OMB / Congress / NIST, and requirements have yet to be drafted, vetted and published. The only requirements
I've seen are requirements for PII that is transported externally or accessed remotely, e.g. via web site, VPN, RAS,
etc. For PII that is entirely housed on one agency's internal network, policies do not exist as far as I know.
Other than that, all you have are the regular NIST / FISMA requirements for storage of all sensitive but unclassified
federal government systems.
Yes, you are permitted to store PII. You wouldn't be able to do your job without PII. What you are not allowed to do
is intentionally or negligently allow improper disclosure of PII. Since there are no requirements beyond the normal
requirements already levied for all of your data, I would recommend following normal best practices, e.g. securely
encrypting your data at rest and in transmission, physical security, authentication, patch management, etc. etc. and
you should be OK.
Penalties and governance for storage of privacy information is codified in the USC Privacy Act, but I seriously doubt
that gives you any specifics. In the US, I think you're generally safe from legal action and penalties from that or
any other infosec-related criminal or civil prosecution, as long as you are able to show that you exercised "due
diligence" / "due care," e.g. that your security posture was not seriously negligent/culpable and was generally
comparable to what other similar organizations to yours normally perform.
Karl Levinson, CISSP