Data Security


Many people today that consider themselves to be internet savvy might believe that they are too clever to fall for an online scam.  They know that they should not respond to pleas for help from Nigerian princes that need to move furniture for their long-deceased, well-meaning philanthropist great uncle.  They know that any job posting that requires respondents to send their bank routing information is likely not legitimate.  They know that a bank will never send an email asking their account holders to “verify their passwords” by clicking on a link.  But do they know that they shouldn’t click on that link that promises a sneak peak of the iPhone 5?

According to a recent survey by the Ponemon Institute (in collaboration with PC Tools), the answer is “no.”  The temptation is just too much, even for seemingly savvy internet users.  “Almost half (47%) of US respondents identified an online survey with a prize as either a scam or an attempt to get you to buy something later. However, when presented with the test scenarios, more than half (55%) of US respondents indicated they would be likely to provide their personal information to redeem a prize after completing an online survey,” said Richard Clooke, Online Security Expert, PC Tools.

A recent article on CNet emphasizes point made by the survey. Last spring, a number of Facebook users were scammed by a link that offered a look at the new iPhone 5.   According to Elinor Mills, the author of the article, “People who normally ignore all the other scams involving purported free software or naked celebrity photos clicked that fake news link and even completed a captcha on a second site, which reposted the scam to their own Facebook stream. That probably says more about how fanatical people are about Apple products than anything else. But it did raise the question–what does it take to lure someone to click on something that seems fishy?” It would certainly appear that the old cliche “everyone has their price” is analogous to this situation. If scammers can target the right prey with the right bait, people seem to disregard their concerns about fraud.  Target techies and Jobs-o-philes with a promised look at a future Apple product and they’ll likely click away.

The moral of the story – “think before you click.”  Many people associate internet scams with malware and Trojans, but sometimes scammers are looking for more specific information about users so that they can launch more targeted and sophisticated attacks later on.   For example, in the scam listed above,  scammers could perhaps garner email addresses.  Those addresses could then be used in phishing attacks later on to get more sensitive data from individuals.  It’s important to remember not to let your guard down when it comes to cyberscams.

Dr. Heather Mark, Ph.D.

SVP of Market Strategy

We often think that our personal computers or laptops are not targets of hackers.  “There is little data of value to a thief,” we might rationalize.  “They are going to be better served going after a big target – like a bank or other financial institution.”  This assumes that the only reason a computer would be hacked is for the value contained on that computer.  On the contrary, sometimes hackers or data thieves seek out computers that they can use as a launching pad for other attacks.  Of course, as long as the criminal has accessed your computer, they are likely to make use of whatever personal data may reside there, as well.  That means that creating a complex password for all of your computers – not just those that are used for business – is important.

SplashData, a company that provides mobile productivity applications, recently released a study of some of the worst passwords to use.   These passwords are the ones that are most frequently cracked.  Not surprisingly, the most frequently compromised password, is “password.”    The top 5 on the list from SplashData  is:

1. password

2. 123456

3. 12345678

4. qwerty

5. abc123

The complete list can be found here.

On this blog, we frequently discuss the importance of complex passwords – including alphanumeric characters, upper case and lower case, punctuation, and other symbols.   We also suggest that the password be changed at least every 90 days.  This will help to prevent hackers from making an easy target of your computer.

Dr. Heather Mark, PhD; SVP Market Strategy

Another year has flown by and the busy season at ProPay is about to begin. We want our merchants to have a successful and stress free holiday season. This is the perfect time to make sure our merchants are up to date on the latest fraud schemes. A fraudulent buyer, chargeback or theft of data can put a damper on your end of year sales.  Here are just a few of the most prevalent fraud trends today.

Spam— Unsolicited email, possibly fraudulent from a company that you didn’t authorize to send you messages.

Phishing/Spoofing— Phishers will impersonate a legitimate company by sending fake emails or creating fake Web sites in order to acquire your personal information—like PINs, credit card or bank account numbers.

Spyware— Software that records your personal information without you realizing it. Several anti-spyware software programs are available to combat spyware.

E Commerce Fraud- Before you buy anything online, ask yourself if the site is legitimate. Look seal from trusted companies that have certified the site as safe and secure. If the deal sounds too good to be true, it probably is.

Get-out-of-debt fraud— Many online debt elimination resources are fraudulent. Be wary. Investigate them thoroughly. If they aren’t a legitimate 501(c)(3) nonprofit organization, then it’s likely that they’re trying to take advantage of your debt-related vulnerability.

International schemes— Don’t respond to emails that suggest you have won or inherited money from someone in a foreign country—Nigeria and Eastern European countries are where many of these emails originate. And any scheme that asks you to give advance money for a larger sum in return is too good to be true, and will always be fraudulent.

Evil twin— A fake Wi-Fi network set up near to and often using a similar name as a real public Wi-Fi network, like those in libraries, parks, and coffee shops. If you unknowingly join the evil twin network, the criminal behind it will have access to all of the information on your computer.

Take a few moments to review this list and to research other fraud trends that could impact you and your business. The small investment of time will be worth it in the long run. Here’s to a successful holiday season and a strong push to the finish line in 2011.

Last week, I attended the PCI SSC Community Meeting in Scottsdale, AZ.   The meeting is held every year so that stake holders in the payments industry can get together and discuss the PCI DSS and its impacts.  Each year brings with it new guidance documents, and sometimes new standards.  This year was no exception and the standard mix of new standards and new guidance was supplemented by discussion of new technologies (perhaps new is a bit of a stretch, as one of the “new” technologies under discussion was EMV – a technology that has been around for decades).  Mobile payments and Near Field Communications (NFC) were also hot topics of discussion and reminded of one my favorite topics – weighing the adoption of technology and its attendant convenience with the protection of payment data.

I am an advocate of a careful risk analysis – there are occasions in which a new technology does introduce risk, but that risk is outweighed by the potential benefit to customers and to the business overall.  In those instances, the organization may determine that the risk is acceptable and the technology is adopted.  In other instances, an organization may determine that the benefits are far outweighed by the risks and the technology is not implemented.  The point is that careful deliberation is sought.  Unfortunately, the current state of the market (economically difficult coupled with rapid technological change) may lead some companies to adopt a new technology as a “me too” strategy.  The appearance may be that by adopting new technologies companies are showing progress and leadership, which will lead to a competitive advantage.  Many times, though, the rapid adoption of new technology without proper vetting can introduce the “unknown unknown” into the environment.

The idea of the “unknown unknown” can be nicely summed up by saying that “you don’t know what you don’t know.”  In other words, one doesn’t have enough experience or knowledge about a particular subject to speak definitively about what its potential risks might be.  The concept was famously speared after Rumsfeld made his famous “unknown unknown” speech.  While pundits and comedians alike had a good time poking fun at Rumsfeld for his use of the terms “known unknowns” and “unknown unknowns,”  he is referencing something that risk analysts and philosophers alike have discussed for years. The premise of Nassim Taleb’s  The Black Swan is largely concerned with operating in a world in which we don’t know what we don’t know.  You can mitigate the number of unknown unknowns through analysis, evaluation, and research.

One of the ways that companies can mitigate the “unknown unknown” in terms of payment security is to evaluate new technologies against the standards established by the industry.  The standards are established to counter the known risks in the payment environment.  Any time a new technology is considered, a good practice is to consider how that technology would be integrated into the existing infrastructure and evaluate that result against the standards and against data security best practices )which sometimes evolve at a faster rate than the standards do.  Certainly this will not bring to light all possible permutations of risk that might arise from the adoption of a new technology, but it will help address an organization’s compliance status and may help mitigate the risk associated with adopting a new technology.

Dr. Heather Mark, PhD; SVP Market Strategy

Those that are familiar with this blog may have heard it said more than once that the United States lags far behind Europe with respect to the protection of consumer information.  The European Union, in fact, has been operating under the penumbra of the European Directive on Data Protection for 15 years.  The EU actually recognizes the protection of personal data as a fundamental human right.   That is a far cry from the legislative activities surrounding data privacy in the United States.  The US has traditionally take piecemeal approach to data protection, often leaving the regulation of data privacy and security to the states, and in some cases to individual industries.  Given the political culture of the United States, such an approach is not terribly surprising.  However, the rapid advancement of technologies has perhaps been enough to spur the federal legislature into evaluating the lessons of the EU directive to see if, or how, similar regulation might work in the US.

On Friday, Sept 16th, the House Energy & Commerce Committee’s Commerce Subcommittee will be holding hearings on the issue of privacy, and specifically the impact of the EU regulations.  In Rep. Bono-Mack’s published opening comments, she states “The purpose of the Directive is to harmonize differing national legislation on data privacy  protections within the European Union, while preventing the flow of personal information to  countries that – in the opinion of EU regulators – lack sufficient privacy protections.”  She goes on to discuss the large number of unintended consequences of the regulatory regime.  To be fair, unintended consequences are almost always found the in wake of new legislation, particularly such sweeping legislation as the EU Directive on Data Protection.  It should be noted, though, that with 15 years of implementation history and lessons, the US should be able to draw sufficient parallels without also reaping the same number of “unintended consequences.”

In looking at the purpose of the directive one can immediately see the attraction of such a regime in the US.  As stated by Rep. Bono-Mack, the purpose is to “harmonize differing … legislation on data privacy…”  In looking at the domestic regulatory landscape surrounding data privacy and protection, it is difficult to conclude that some “harmonizing” would not benefit both businesses and consumers.  As of this writing, more than 45 states have data breach notification laws.  While there are some major commonalitites to these laws, there are also significant variations.  There are differing definitions of “personally identifiable information,” “breach,”  “trigger,” and other critical terms.  Some states include data security protections in those laws, while others have separate laws for data security, and still others have no laws regarding data protection and security.  The situation becomes even more confusing when one considers the federal legislation impacting privacy and security (FERPA, HIPAA/HITEC, GLBA, SOX, etc) and industry self-regulating programs.

While there are some concerns that tomorrow’s hearing is too slanted towards industry, ignoring or downplaying the concerns of consumers, I believe that it is a positive step. Bill McGevern, professor of law at University of Minnesota does bring up an interesting point, though.  That is the different conceptions of data privacy between the US and Europe.  According to McGevern, Europeans think of privacy as a fundamental human right, while Americans (and particularly American businesses) conceive of privacy as a market force with which they have to deal.  That being said,  this author does believe that it is possible to create a European-style privacy directive that accounts for American sensibilities.

Dr. Heather Mark, PhD; SVP of Market Strategy

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