Friday, August 25, 2006

Personal information - don't just protect it in the database

Kim Cameron's Identity Blog highlighted the case of more than 100 Australian government employees being forced out of a single agency for snooping on client information. According to the Sydney Morning Herald article, hundreds more were demoted or faced salary deductions as punishment.

Interestingly I have a little insight into some of the Centrelink agency's online applications. Despite this, the rest of the specifics to Centrelink in this post are wild speculation, so take them with a pinch of salt.

The agency provides a range of online services to Australians, especially around benefits and financial support, and enables users to perform many interactions and transactions with the agency online. This leads to approximately 80 million online transactions per week. As I understand it, before going online the agency had struggled with how to counter individual users claiming that information they had (or had not) provided online was incorrectly recorded, leading to incorrect payment of benefits and other issues. This would mean that cases that led to litigation would be hard to defend. The requirement for non-repudiation rested with the agency and this proved difficult for them to address.

Here is where the wild speculation starts. Centrelink is considered a gold-standard in the Australian government for an online service that is secure and trusted. It employs a website monitoring application called WebCapture that for online transactions records both the information presented to a user, the forms they see and the documents requested, alongside any information that users enter into forms, the options they select, links they follow and buttons they click. This information is recorded on the web-server, stored to a repository and may be played back by authorized users as a virtual video recording of the entire transaction. As I understand it, the captured, replayable transaction has been tested in court as having appropriate legal weight to provide non-repudiation: the logged in user did perform the transaction, and this is exactly the information they were presented and they responded with.

I am guessing if some of the employees in question used this monitoring capability to snoop on customer information that they couldn't access in other systems. WebCapture information is held in an extremely secure repository, with metadata passed to a standard database. The question is whether the agency effectively designed and enforced their security policies with respect to accessing this data. A system's security is only a strong as the security policies you define for it. In this case, it may be that the WebCapture repository or associated database was the subject of poor IT security policy enforcement or poor governance around the maintenance of those policies or the users that could access it.

If this scenario is actually true, it highlights an issue that should be obvious, but may have been missed in this case. As we add additional layers of software into our infrastructure, if they are not subject to good IT governance and management processes they may be fraudulently used to access personal data and transactions, or lead to other security issues. Every new layer of infrastructure needs to be managed - personal data does not just reside in the database anymore.

With good governance and management of the systems and security policies using best practices like ITIL, a system like WebCapture can provide undeniable proof of transactions performed by clients, protecting the organization from false claims and litigation. This is a huge benefit to an organization like Centrelink. There is no substitute for good management of data in all IT systems, not just the database.

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