Schizophrenia on Capitol Hill

As you may be aware, Congress is considering a bill that would require internet service providers to retain data on their customer’s assigned IP addresses  (as well as name, address, credit card number and a host of other data) for up to 12 months.  Though the bill ostentatiously targets child pornographers, the legislation goes so far beyond that one legislator proposed an amendment to rename the bill Keep Every American’s Digital Data for Submission to the Federal Government Without a Warrant Act.

While this bill is horribly privacy invasive, for the obvious reasons, Congress has chosen to accept the familiar bugaboo of child protection as justification enough to impose this burden.  It’s so especially odd given the number of privacy protective laws also being proposed in this Congress. However, such schizophrenic action by Congress or business is by no mean uncommon.  In fact, I would have to say it’s par for the course. Not only is it par for the course for Congress, but most businesses use this approach as well.  Collect more data and then ratchet up security in an attempt protect that data.  

Of course, there is another approach.  The one I’ve been advocating and that was recently picked up recently by none other than Forbes’ Kashmir Hill, is, of course, Privacy By Design.   

What do you want to be when you grow up?

Most people’s eyes gloss over when I say I’m a “privacy professional.”  They don’t have the foggiest idea of what I mean.  This is a problem both outside and within the corporate world.  Some jobs are easily identifiable with a single word.  If I say I’m a fireman, for the most part, people can understand what I do for a living.  There may be some aberration, such as if work mostly handling forest fires versus structure fires but in general, the public understand what I do on a daily basis.

When you start talking information technology professional, the confusion begins.  Even simplifying that term into computer professional, people will tend to put you into two camps: someone who programs computers or fixes them.  If they associate you with the latter, you’re now their new best friend to come get rid of that nasty virus.  However, the range of information technology professionals is much broader. You have programmers for sure but also database developers, web developers, driver developers, component programmers, designers (who know graphical interfaces).  You have a host of administrators: network admins, sys admins, database admins, etc.  Then you have the engineers and architects who design the system.  Then the support personell.  Then you start moving into layers of abstraction and there are IT governance folks who develop data policies, auditors who enforce the policy.  The IT world is rich with nuanced professionals, none of whom would consider their job the same as others, yet from the outside they are easily lumped together, “oh you’re a computer guy.”

Apparently the same is true of lawyers.  Some lawyers have a very public persona.  The criminal defense lawyers on TV, the personal injury attorneys on every billboard, this is what the public sees.  They also know you need to go to lawyers for things like divorces and real estate but still tend to lump everybody into either civil law or criminal law.  The truth is lawyers are much more diverse once they develop a specialty really have limited ability to advise on other issue.  More importantly, some laws are so intricate that many corporate lawyers specialize in very narrow niches: Foreign Corrupt Practices, mergers and acquisitions, etc. 

Returning to my issue at hand. I get the question all the time, of people asking me what I do or what I want to do.  My response “I’m in privacy” is clearly unintellible to people outside the field.  Even people who you think might have an inkling of an idea, still seem perplexed that someone could claim such as their professional vocation.  My point of this blog post is really to help myself come up with a simple easly explanation….. an elevator pitch that I can give when confronted with the question.

My girlfriend had a good suggestion.  I actually asked her last night what she thought I did.  She had a better notion than most but still incomplete.  She says she often struggles explaining it to her friends. She suggested a three prong approach: first say what it is, second explain what it does and third give an example.

1. What is the title? “Privacy Architect”

Now I would say even most seasoned privacy professionals would have a hard time understanding what this means.  The vast majority of privacy pros come from a regulatory compliance background, they either don’t have the IT knowledge or just don’t think in terms of building in privacy up front. 

2.  What does a privacy architect do?  “I help companies design their computer systems and business practices with their customers privacy in mind.” 

While this is a really incomplete picture, I think it’s simple enough to convey mostly what I do.  My work may not be limited to computer systems and business practices.  I think about privacy of other stakeholders than customers. This doesn’t really encompass the legal issues at hand, nor the brand building that having a good privacy reputation can bring.

3.  Give an example of what you do. “Say a company wants to start an online bookstore. What books one purchases can reveal very personal interests: medical issues, political positions or financial status. Customers may want to keep such information private. What I do is help design the online store to empower their customers to preserve their privacy while still allowing the business to serve those customers.”

I’d really appreciate anyone’s feedback on this.  Does it capture what I do?  Is it simple and understandable. 

Helping your customers help themselves

Watch this video….

Now consider, how can a company help a customer protect themselves against this kind of attack?  Even given the inherent weaknesses of credit cards, consider this option:

The video says that hackers monetize compromised computers by installing key loggers. The hackers then search through the keyed data looking for credit card numbers. “But we can’t do anything if the customer’s computer is compromised!”  B.S.

What’s the solution?  Don’t have your customer enter all the digits of the credit card via their keyboard.  Display an onscreen keypad for entry of the last four digits.  This thwarts the CC thieves and demonstrates to your customers that you are attempting to protect them even on potentially compromised systems.  Simple, easy, effective.


The KnowledgeNet speech in Boca Raton went really well. I got some great positive feedback.  In fact it was suggested that I propose to give the speech (or a similar one) at one of the IAPP’s national conferences. In addition, my preparation for the speech spurred my interested in several areas which I hope to explore, both within this blog and outside of it. 

The first, in trying to develop a simple PbD (Privacy by Design) example, I ran into the issue of protecting emails while still supplying the system with contact information.  Some people use one time email services (like Mailinator).  However, these have several potential downfalls, primary of which the email service can read your email and secondly, for some, you can only get email once.  I’m going to return to this subject when I have some time to do some more investigation.  I know there are other services out there that might fit the bill, I just need to find an innovative solution to this problem. 

Another issue that I found is that privacy professionals really need to be versed in cryptography.  They don’t need to actually know how the cryptography works, they just need to know about the capablities so they can demand those of their product development teams.  Things like zero knowledege proofs, homomorphic encryption, hasing.  I’m going to try and write an e-book about this but I think first I write each chapter (on a different technology as a blog post).

Still another issue that raised its head is the concept of provable audit-ability.  Most auditor just have to take the IT professional’s word that certain information/systems are secure.  Take for example, a developer who makes a backup of production data on an orphan server.  Nobody knows about it except the developer.  Nobody audits the access controls on that box because they don’t even know about it.  How is an audit supposed to find it?  The concept of provable audit-ability goes to proving with mathematical certainty that nobody tampered with or has access without authorization.  It’s doable, if organizations are willing to consider privacy by design rather than privacy by accident.  Currently auditors say “we think we’re secure” but they really don’t know and they can’t know until a breach occurs and it’s too late.

Giving this speech has put a lot on my mind and there are many more blog posts to make in the coming weeks.  Let’s hope I can find time to put the pen to paper, so to speak.

Social Security Number redux

This article describes the continuing problem of banks using social security numbers as identifiers and partial passwords.  It seems the FTC has previously identified the problem of SSNs being utilized as authentication tokens and has even gone so far as to propose legislation to reduce the over-reliance on them in industry.  I would like to point out my simple solution doesn’t require any legislation, simply publish SSNs on the internet as a ubiquitous identifier, thereby reducing their value to identity thieves and as authentication tokens.