Small Office Security: Does It Really Exist?
There is a notion that small professional offices such as those of lawyers, certified public accountants, advertising agencies, medical doctors and clinics, and so on are too small to be of interest to hackers looking to wreak havoc on the Internet. After all, who would be happy with a small piece of the pie when the large pieces (Fortune 500 companies, government installations, defense networks) are so much more challenging and rewarding to the ego? There may be some truth to this notion. But the spread of broadband and high-speed Internet connections, along with the growing popularity of distributed attacks that use the aggregate processing power of numerous unknowingly compromised computers (zombies) to carry out small portions of an overall attack, make any Internet-connected host a potential target.
There is another, less apparent reason for targeting the small office: the cornucopia of personally identifiable and sensitive information about the clients of those professional offices. Personally identifiable information (PII) is any combination of data that can allow for the specific identification of an individual from a group. For example, a person's name, home address, and telephone number together constitute PII, as it's unlikely that there will be two or more unrelated people with the same name living at the same address and the same telephone number. However, there may be two people with the same name living in different places, or there may be two or more people sharing a telephone line and living together.
The dangers of surrendering personally identifiable information to the general public or to anyone who isn't supposed to have this information can be very great. For example, given the growing level of activism, abortion clinics may be targeted by anti-abortion hacker activists ("hacktivists") looking for information on doctors and patients in order to harass them. Certain medical patients, such as political figures, athletes, CEOs, and celebrities, may themselves be targets of a hacker seeking information to use against them for blackmail or other purposes. For example, a star actor or a rising politician may not want it known that he or she has a sexually transmitted disease.
Another concern is the rise in occurrences of identity theft. This is a nefarious practice in which the assailant uses information about an unsuspecting person to assume his or her identity, in order to purchase big-ticket items (fur coats, TVs, electronics, etc.), gain credit, and transfer or launder money. Not only does this practice lead to potential financial consequences for the victim, but the process of clearing up an individual's credit after a bout with identity theft can take the better part of a presidential term of office.
Gotta Keep It Safe
So there is a need to defend this information, not the least of which is the potential liabilities that even small professional service firms may facefrom government regulators, privacy advocacy groups, and clients whose records have been compromised. These clients may seek damages for failure to perform the necessary due diligence in protecting their sensitive and private information.
There have always been privilege clauses that allowed members of the legal, financial, and medical professions to keep their client's information confidential. However, the ethical standards imposed on members of these professions have now been codified and extended by numerous recent pieces of legislation. These confidentiality standards have been coupled with information security and privacy due diligence standards and included in legislation such as the Gramm-Leach-Bliley Act (GLB Act) and the Health Insurance Portability and Accountability Act (HIPAA).
The GLB Act pertains to those in the financial community and establishes (among other things) security and privacy guidelines for the handling and use of financial information. Similarly, HIPAA establishes security and privacy guidelines through rulings and regulations developed by the Department of Health and Human Services (HSS), for the healthcare community and all organizations that are involved with healthcare in any way, including firms that offer employer-sponsored health coverage.
In addition, numerous state and local regulations have been passed or are pending on the issue of the security and privacy of consumer/customer information.
While the information-security aspects of these laws and regulations don't receive the attention of the privacy aspects, they do exist, and failure to comply may well evoke the regulators' fury. It remains to be seen whether this will take the form of monetary penalties or the equally disturbing headaches and stress caused by an endless stream of official communications sent by regulators seeking to have offenders alter their practices to achieve greater compliance.
But what does compliance really mean when the rules and regulations themselves are vague and are modified over time? For example, under the Bush Administration, HHS has already modified or offered new interpretations of the regulations produced by HHS under the Clinton Administration. Also, certain aspects of the GLB ACT may seem to run counter to provisions of the USA PATRIOT Actspecifically those that call for the financial industry to share client transaction history with the federal government.
So What's a Business Owner To Do?
Without the technical resources of larger organizations, how can small offices defend themselves from the multi-headed monster of shifting government regulations, ever-increasing legal liability, and persistent, malicious hackers?
This is a case where seven giants can be felled with one swing: members of the professional services should be proactive and take at least the basic steps to address security concerns, before laws mandate doing so.