The purpose of this document is to outline ITS's general approach to dealing with security incidents relating to, or affecting, Carleton's network and computing environment. It is not intended as a comprehensive framework along the lines of ISO/IEC 27035, but rather as 1) a framework for helping clients understand what is happening, and 2) a template we can look to internally for guidance, in the heat of the moment, in case of a security incident.
This document also outlines our specific response steps where personally identifiable or otherwise very sensitive information has been disclosed.
Maintaining Carleton's network and overall computing environment has become, increasingly, a cybersecurity challenge. 2017, in particular, was a bad year for for cybersecurity. 2017 saw a number of highly publicized breaches, like the Equifax hack, as well as new vulnerabilities on computer processors (Spectre and Meltdown), and the rise of ransomware. In response to these security challenges, ITS has taken steps to improve our ability to monitor our network, detect anomalies, and mitigate vulnerabilities (or outright compromises) when discovered.
This document is concerned, in particular, with mitigation, that is, with ITS's response when a vulnerability or compromise has been discovered. There is also a detailed section outlining what actions we will take if we determine that personally identifiable or otherwise very sensitive information has been disclosed.
By "vulnerability" we mean an operating state that could allow malicious parties to perform unauthorized actions, for example, an unpatched/un-updated Windows desktop that could be subverted and used as platform for bitcoin mining, spamming, or monitoring of other network traffic to facilitate additional unauthorized actions. By "compromise" we mean an actual breach, that is, a circumvention of our normal operations by a malicious party that presents an immediate reputational and/or financial risk to the college.
A breach could be something as minor as, for example, the theft of user credentials, allowing unauthorized parties to assume the identity of a Carleton user. A breach could also be something as significant as exfiltration of a large amount of sensitive data, or outright theft/ransom of an entire administrative database.
Detection of anomalous or unauthorized activity in Carleton's computing environment that presents either a reputational or financial risk to the college may come to ITS through a variety of channels, including
Once a problem has been identified, we assess. In complex cases, we may engage third parties, for example, cybersecurity firms with expertise in the area where we've experienced a compromise.
Investigation and assessment can be difficult and it is sometimes intrusive. It may require careful examination of things like activity logs and email. In general, ITS takes the privacy of the Carleton community very seriously and will only examine and analyze what is strictly needed in order to assess the full extent of a threat that's been identified. Furthermore, the smallest possible group of people will conduct such investigations. And they will not communicate any findings relating to individual user actions other than those strictly relevant to the investigation they are performing. Our goal is to to limit risk and damage, and to protect the campus from the normal threats that all networked computing environments are subject to.
Ultimately, in any given case, we want to reach a point where we understand our risk.
Once affected people and systems have been assessed, ITS will assign appropriate resources, which may include
Action we may take to mitigate vulnerabilities and breaches may take a variety of forms, such as
When sensitive PII is involved, Carleton's response, once we have discovered a breach, is necessarily more formal. ITS will:
With respect to notification, a number of laws will guide our response.
At the Minnesota state level, Minnesota Statute 325E.61 requires entities that conduct business in Minnesota, and that own or license personal information, to notify residents of Minnesota without unreasonable delay of any data breach that results or could result in the unauthorized acquisition of their unencrypted personal information. Substitute notice is permitted in specific circumstances and notification may be delayed for law enforcement purposes. If more than 500 individuals have to be notified of a breach, we must also notify all consumer reporting agencies that compile and maintain files on consumers on a nationwide basis, as defined in 15 USC Section 1681a(p), within 48 hours.
At the US federal level, insofar as we maintain health data subject to HIPAA, we must notify affected parties of breaches. Federal laws are evolving in this area and changing.
At the international level, the GDPR article 33 mandates that, “in the case of a personal data breach, data controllers shall without undue delay” notify the appropriate regulator of the breach. Article 33 goes on to state that, where feasible, this notification should take place no later than 72 hours after the breached party has become aware of the incident.
Persuant to these and other emerging regulations, Carleton will, in the event of a PII breach,