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Security, Privacy, and Innovative Law Enforcement Information Sharing: Covering the bases

So it’s no great revelation that public safety has benefited greatly from public private partnerships, and I’m cool with that, especially when we are dealing with technology that saves lives. However, a press release hit my email inbox today that made me think of the risks to security and privacy when we implement innovative technologies.

Before I get into the story it, let me be v-e-r-y clear…I am NOT here to debate the effectiveness or morality of red-light/speed enforcement systems, nor am I here to cast dispersions on any of the organizations involved in the press release…this blog posting is strictly about using the Gatso press release to emphasize a point about security and privacy - when we engage in innovative law enforcement technology solutions, we need to take extra care to adequately address the security and privacy of personally identifiable information.

Here’s the press release from Gatso-USA:

GATSO USA Forms Unique, Strategic Partnership with Nlets

Earlier this month, GATSO USA was approved as a strategic partner by the Board of Directors of the National Law Enforcement Telecommunications System (Nlets). Nlets is….general narrative about NLETS was deleted. The approval of GATSO is an exciting first for the photo-enforcement industry.

Nlets will be hosting GATSO’s back office and server operations within the Nlets infrastructure. GATSO will have access to registered owner information for all 50 states plus additional provinces in Canada. The strategic relationship has been described as a “win-win” for both organizations.

From Nlets’ perspective, there are key benefits to providing GATSO with hosted service. Most importantly, it virtually guarantees personal data security. Due to this extra step of storing personal data behind the DMV walls of Nlets, the public can be assured that security breaches — such as the recent incident with PlayStation users — are avoided.

From GATSO’s perspective, hosting the system with Nlets will provide a ruggedized, robust connection to comprehensive registered owner information — without the security issues faced by other vendors in this industry. Nlets was created over 40 years ago…more stuff about NLETS was deleted).

The main points I took away from this press release were:

1. Nlets is going to host the back-end server technology that GATSO needs to look up vehicle registration information of red-light runners;
2. Gatso is going to have access to vehicle registration information for all vehicles/owners in ALL 50 states in the U.S. and (some) provinces in Canada; and
3. And, because it’s behind Nlets firewalls, security is not an issue.

Again, please don’t call me a party-pooper as I am a huge advocate for finding innovative ways to use technology to make law enforcement’s job easier. However, I am also painfully aware (as many of you are) of the many security and privacy related missteps that have happened over the last few years with technology efforts that meant well, but didn’t do enough to make sure that they covered the bases for security and privacy matters. These efforts either had accidental leakage of personal information, left holes in their security posture that enables direct attacks, or created opportunities for nefarious evil-doers with legitimate access to use that access to sensitive information for other than honorable purposes.

After I read the press release, I thought that it would be a good case-study for the topic of this blog - it involved innovative use of technolgy for law enforcement, a psuedo-government agency (Nlets), two foreign-owned private companies, and LOTS of PII sharing - some might even say it had all the makings of a Will Smith movie.

To help set the stage, here are a few facts I found online:

• Gatso-USA is a foreign company, registered in New York State, operating out of Delaware; its parent company is a Dutch company, GATSOmeter BVGatso.
• Gatso does not appear to vet all of the red-light/speed violations itself; it uses another company – Redflex Traffic Systems to help with that (Redflex is not mentioned in the press release).
• Redflex seems to be a U.S. company, but it has a (foreign) parent company based in South Melbourne, Australia.
• Finally, there are no-sworn officers involved in violation processing. Red-light/speed enforcement cameras are not operated by law enforcement agencies; they outsource that to Gatso, who installs and operates the systems for local jurisdictions (with Redflex) for free, (Gatso/Redflex is given a piece of the fine for each violation).

There are no real surprises here either; there are many foreign companies that provide good law enforcement technologies to jurisdications across the U.S., and outsourcing traffic violations is not new…BUT what is new here is that a sort-of-government agency (Nlets), has now provided two civilian companies (with foreign connections) access to Personally Identifiable Information (PII) (vehicle registrations) for the entire U.S. and parts of Canada…should we be worried?

Maybe; maybe not. Here are nine questions I would ask:

1. Personnel Security: Will Nlets have a documented process to vet the U.S. and overseas Gatso and Redflex staff who will have access to this information through direct or VPN access to Nlets systems?
2. Data Security: Will Gatso or Redflex maintain working/test copies of any of the registration information outside of the Nlets firewall? If so, are there documented ways to make sure this information is protected outside the firewall?
3. Data Access: Will Gatso/Redflex have access to the entire registration record? or, will access be limited to certain fields?
4. Code Security: Will any of the code development or code maintenance be done overseas in the Netherlands or Australia? If so, will all developers be vetted?
5. Network Security: Will overseas developers/site suport staff have access to the data behind Nlets firewalls? What extra precautions will be taken to protect Nltes systems/networks from abuse/attack?
6. Code Security: Will Nlets conduct any security testing on code loaded on the servers behind their firewalls?
7. Stakeholder Support: Have all 50 U.S. states, and provinces in Canada, been made aware of this new information sharing relationship? Do they understand all of the nuances of the relationship? And, are they satisfied that their constituents personal information will be protected?
8. Audit/Logging: Will all queries to vehicle registration information logged? Is someone checking the logs? How will Nlets know if abuses of authorized access are taking place?
9. Public Acceptance: How do states inform their constituents that their personal vehicle registration information is being made available to foreign owned company? Will they care?

How these questions are answered will determine whether or not we should worry…

Did I miss any other important questions?

Beyond this particular press release and blog posting, I suggest that you consider asking these kinds of questions whenever your agency is considering opening/connecting its data systems to outside organizations or private companies—it may just prevent your agency from becoming a headline on tonights news, like St. Louis –> St. Louis Police Department computer hacked in cyber-attack .

The bottom-line is that whenever you take advantage of opportunities to apply innovative technologies to public safety, make sure that you cover ALL the bases to protect your sensitve data and PII from leakage, direct attacks, or misuse and abuse.

As always, your thoughts and comments are welcome.

r/Chuck

Information Sharing: The main thing is to keep the main thing the main thing

Almost two years ago, i responded to a blog posting by Jeff Jonas entitled “Nation At Risk: Policy Makers Need Better Information to Protect the Country.” After a recent discussion about law enforcement  information sharing with a colleague, i thought it might be worthy to re-run my response here…read the posting below and let me know what you think…r/Chuck

March 17, 2009

Hi Jeff,

With sincere apologies to Sean Connery, I am dismayed that people are still bringing a knife to an information sharing gun fight—the importance of information sharing, data discoverability, security protections, metrics and incentives, and empowerment have been documented many times over since I became involved in information sharing in 1999 and have proved to be of little value to making information sharing happen.

I believe a significant reason for this is that information sharing has been seen as the “main thing.” Information sharing should NEVER be seen as the main thing; it is simply a means to an end. I have never forgotten what Scott McNealy of Sun Microsystems said—“The main thing is to keep the main thing the main thing.” And, the main thing for government is safe streets, clean air and water, a strong economy, etc…NOT information sharing.

The “guns” that we need to bring to the information sharing table are simply engaged executive leadership and accountability for mission results.

Of the many significant information sharing projects around the country that I have been a part of, I can tell you that the most important ingredient for successful information sharing is: “An agency executive who actively communicates an operational imperative for mission success and then holds their managers accountable for using information sharing as a critical enabler for achieving desired mission results.” [I have a few blog posts on the subject at http://www/nowheretohide.org/wordpress]

While I agree that good security, good technology, good project management, good metrics and the like are necessary, none of this will matter if the need for information sharing is relegated two or three levels down the organization chart or is just seen as an edict from above—federal, state, and municipal agencies are already choking on multiple (and often conflicting and unfunded) mandates.

With my apologies to our President, the PM-ISE, and the Markle Foundation there is nothing more they can print on a sheet of paper to make information sharing happen—hundreds of executive orders, national strategies, task force reports, and security policies have been published—what more could they possibly say?

I believe it now comes down to the individual will of executive leadership in those federal, state and municipal agencies who hold the information that should be made shareable and their capacity to make it happen within their respective agencies. And that Jeff is the one area where I do believe that President Obama and our Congress can help—by simply ensuring that the people they choose to lead those agencies a) truly embody the will, character, and leadership qualities to achieve the mission and b) understand the value that information sharing brings to help make that happen.

r/Chuck Georgo
chuck@nowheretohide.org

Having trouble convincing the boss to spend on Security and Privacy protection? Read on…

The Poneman Institute, considered the pre-eminent research center dedicated to privacy, data protection and information security policy, released its 2009 Ponemon Institute “Cost of a Data Breach” Study on January 29, 2010.

In the report, they published the results of their fifth annual study on the costs of data breaches for U.S.-based companies. They surveyed 45 companies represnting 15 various industry sectors–significant contributors were financial, retail, services and healthcare companies.

Numbers-wise, the companies they interviewed lost between 5,000 and 101,000 records, at a cost range between $750,000 and $31 million.

What was really interesting was that the average per-record cost of the loss was determined to be $204.00–and how many records does your law enforcement/public safety agency hold?

Some factors they considered in computing the cost of the breach included:

• Direct costs - communications costs, investigations and forensics costs and legal costs
• Indirect costs - lost business, public relations, and new customer acquisition costs

The report also lists a number of causes for the data breaches, such as:

• 82% of all breaches involved organizations that had experienced more than one data breach
• 42% of all breaches studied involved errors made by a third party
• 36% of all breaches studied involved lost, misplaced or stolen laptops or other mobile computing devices
• 24% of all breaches studied involved some sort of criminal or other malicious attack or act (as opposed to mere negligence).

You can download the full report here: http://www.encryptionreports.com/download/Ponemon_COB_2009_US.pdf

Thoughts and comments welcomed…r/Chuck

Portal-mania: They’re reproducing like bunnies, but they ain’t as cute

I had a conversation with a fusion center director yesterday about portals that really drove home a feeling I had about the recent plethora (read: boatload) of portals that the average analyst person supporting public safety and homeland security has to login to in order to do their jobs. 

I’m paraphrasing a bit, but he basically indicated that the state, local, and private sector organizations in his state told him that they “DO NOT want to have to log into multiple portals” to stay informed about criminal and terrorism threats to their state’s  infrastructure.” 

When you take a closer look at the “Portal-mania” that exists, it seems that every agency and multiple programs within a single agency has to have their own portal for accessing the information and analytic tools that agency or program provides; here’s a quick list of ones I am familar with, (feel free to email me the names of others you know about):

1. DHS HSIN State and Local Community of Interest (SLIC)
2. DHS Lessons Learned Information Sharing (LLIS)
3. DHS Automated Critical Asset Management System (ACAMS)
4. DOJ Regional Data Exchange (R-DEx)
5. DOJ National Data Exchange (N-DEx)
6. DOJ eGuardian
7. DOJ Law Enforcement Online (LEO)
8. DOJ InfraGard
9. DOJ National Sex Offender Public Website (NSOPW)
10. DOJ National Criminal Intelligence Resource Center (NCIRC)
11. DOJ Regional information Sharing System (RISS)
12. Private Sector CyberCop
13. [State] Criminal Justice Information System (CJIS)
14. …add to this Department of the Treasury, Department of Transportation, and other federal agency portals
15. …and about three-dozen other databases and private sector websites

This is nutz! Dedicated portals are so 1990′s…we should be able to use the same technology I used to create this website and blog (WordPress and four different plug-in widgets) to make information and advanced analytic capabilities available to Fusion Centers and other public safety users.  I would like to challenge the agencies and programs listed above to make the information and capabilities they offer available  through widgets, web-parts, and gadgets that Fusion Centers and other intelligence/information sharing users can integrate into THEIR portal of choice. 

Whether it’s SharePoint, Oracle, or IBM Websphere, state, local, or private sector organizations should be able to pick and integrate into THEIR selected portal environment from the portal list above the information and capabilities that they need to do their job–they should not have to access the multiple, stovepiped portals as they do today.

I’d like to know what you think about this…Thanks..r/Chuck Georgo

Microsoft Fusion Core Solution: For pain relief, take two webparts and call me in the morning

I don’t usually plug any specific software, but I felt compelled to tell you about something I have been working with Microsoft on for about  the last eight months–it’s called the Fusion Core Solution (FCS). What’s different about this project is that FCS isn’t just another application, it is an effort by Microsoft to help fusion centers do more with the many applications they currently own or have plans to invest in. First a bit of background.

Whether you like the idea of a fusion center or not, they are here to stay. At last count, there were about 70 of them, and DHS recently spoke of helping to get even more going.  At their core, I believe a fusion center is responsible for doing three basic things: 

1. Accepting and vetting reports of unusual behavior (criminal or terrorism related);
2. Providing intelligence support to major case and tactical law enforcement operations; and
3. Proactively supporting federal, state, and local homeland security and community safety objectives. 

To do this well, the majority of fusion centers in operation today are required to rely on an assortment of manual processes, a patchwork of incompatible software applications, and dozens of disparate information sources. Walk into the typical fusion center today and you’ll probably find that an analyst answering the phone has to enter the request for their services into one application for management purposes, enter the same information into a second application for sharing purposes, then has to manually bring up and login to anywhere from 5-15 different data sources to search for information related to the service request, then has to open up at least one or more applications to write up  and package up the requested response, and then, more than likely, has to either manually fax it to whomever asked for the information or call them back on the telephone to give them the answer–a pretty painful and tedious way to work.

Today though, Microsoft announced release of a project that I have been helping them to develop for quite some time–the Fusion Core Solution.  Microsoft hopes, through use of Office, SharePoint and ESRI’s ArcGIS to help ease the pain described above.  The FCS uses SharePoint as a horizontal integration and workflow management platform to help an analyst go from taking in a fusion center service request, to searching for information, to analyzing that information, to producing the intelligence product without having to leave the SharePoint environment at all.

At a non-technical level, the FCS will enable fusion centers to do a couple of pretty cool things:

1. Provides a common look and feel across multiple analytic tools and business processes.
2. Greatly reduces the number of user names and passwords analyst must remember.
3. Organizes requests for fusion center services, and tracks progress of fusion center work.
4. Helps to better document and comply with 28 CFR Part 23, CUI and PCII requirements.
5. Provides multiple analyst-to-analyst and fusion center-to-fusion center collaboration tools
6. Helps to keep track of fusion center and extended staff capabilities and availability.

From a technical perspective, FCS fully supports NIEM conformant information exchanges and establishes a framework for supporting the service-oriented principles of the Justice Reference Architecture (JRA) as it applies to information and data sharing.

In a nutshell, “Fusion Core Solution is for a Fusion Center what Microsoft Windows is to a personal computer“–you can think of FCS as the “operating system” for a Fusion Center.

For more info, check out the Fusion Core Solution website, or email me.

r/Chuck

Added 8/4/2009: Click HERE to see Joe Rozek, Microsoft’s Executive Director of Homeland Security, and Former Senior Director for Domestic Counterterrorism at The White House Office of Homeland Security talk about Fusion Core Solution

NIEM and JIEM: Two Great Tastes In Justice Information Sharing

Remember the old Reese’s Peanut Butter Cups commercial? “You got chocolate on my peanut butter “…”No, you got peanut butter on my chocolate “…?  Well, this is one of these stories…

It’s no secret, the National Information Exchange Model (NIEM) is a huge success.  Not only has it been embraced horizontally and vertically for law enforcement information sharing at all levels of government, but it is now spreading internationally.  A check of the it.ojp.gov website lists more than 150 justice-related Information Exchange Package Documentation (IEPD) based on NIEM–it’s been adopted by N-DEX, ISE-SAR, NCIC, IJIS PMIX, NCSC, OLLEISN, and many other CAD and RMS projects. 

For at least the last four years, Search.org has been maintaining the Justice Information Exchange Model (JIEM) developed by Search.org.  JIEM documents more than 15,000 justice information exchanges across  9 justice processes, 75 justice events, that affect 27 different justice agencies. 

So if JIEM establishes the required information exchanges required in the conduct of justice system business activities, and NIEM defines the syntactic and semantic model for the data elements within those justice information exchanges…then…

Wouldn’t it make sense for JIEM exchanges to call-out specific NIEM IEPDs?

And vice-versa, wouldn’t it make sense for NIEM IEPDs to identify the specific JIEM exchanges they correspond to?

Here’s a diagram that illustrates this…

Let me know what you think..

r/Chuck

chuck@nowheretohide.org - www.nowheretohide.org

Health Info Sharing Beating LE to the Punch

If you haven’t heard about the Department of Health and Human Services Federal Health Architecure and CONNECT project, I suggest you pop over to this website where documentation for version 2.0 of the software resides:

http://www.connectopensource.org/display/NHINR2/Release+2.0+Home

CONNECT is an open source software gateway that connects public and private health orgaizations to the National Health Information Network.  Think of it like a giant peer-to-peer N-DEx, but with an open source “front-porch” that drops into each agency and extracts the data from back-end systems.

I’ll be doing more investigation into the CONNECT project to see if we can adapt it for law enforcement information sharing use–the closest thing to this on the LEIS side is the FINDER project in orlando, FL.

as always, comments and thoughts welcomed.

r/Chuck

chuck@nowheretohide.org - www.nowheretohide.org

Information Sharing: When they say it's about the money, it's NOT about the money…

Some who read this may take it as a rant against agencies/providers who say we need more money for implementing law enforcement information sharing (LEIS), but in-fact, this post is really about understanding the landscape and influencing the choices and priorities of state and county policymakers and the affected law enforcement executives.

Let me first layout the agency landscape :

• There are about 14,000 state and local law enforcement agencies;
• In roughly 3,000 counties;
• That make up the 50 states of our great nation.

Now let’s layout the funding landscape:

• For 2008 the Department of Homeland Security (DHS) allocated $3,200,000,000 (billion) for state and local assistance grants;
• In that same year, the Department of Justice (DOJ) made another $2,000,000,000 available;
• For 2008 that’s a total of $4,200,000,000;
• For 2007 that number was $4,500,000,000;
• For 2009, we are hoping that number stays about the same or goes even higher.
• To all these numbers you must add funding from the Department of Defense, Department of Transportation, Department of Health and Human Services, or State funding sources for LEIS.

Finally, let me lay out the cost landscape for LEIS:

• In my eight or so years of experience of building and deploying LEIS, I’ve seen the costs associated with hooking up an agency to vary between $5,000 and $80,000 per record system connection;
• On average though, I feel the safer number is between about $20,000 and $40,000;
• For arguments sake, let’s use the high number of $40,000.

Now comes the fun part…let’s do some math…

• To be realistic, let’s say that 25% of the 14,000 agencies are already sharing information;
• That leaves about 10,000 agencies left to connect;
• At $40,000 an agency, we would need a total of $560,000,000 (Million);
• Divide that by the 3,000 counties, and we will need about $190,000 per county;
• If we do this over three years, that’s only $63,000 per county, per year for three years!

With (on average) every county getting about $1,400,000 every year for law enforcement and public safety (out of the $4.2 Billion allocated annualy), I would like to think that we (collectively) can see the benefits of LEIS enough to spare $63,000  a year for three years to get it done.

Here’s where the issue of choices and priorities comes in.  If we can agree that the money IS there, what we really need to work on are ways to convince the policymakers and law enforcement exectutives in those counties that investing a little in LEIS is a better investment than whatever it is their currently spending their part of the $4,200,000,000 on.  Do you agree?

I’d also like to know what role youthink the IACP, MCC and NSA would play here?

Thoughts and comments invited…and yes, I used a calculator…;-)

r/Chuck Georgo

IJIS Institute Committee Leader Appointed: Chuck Georgo Takes Reins of Security and Privacy Committee

The IJIS Institute announces the appointment of Chuck Georgo, founder of NOWHERETOHIDE.ORG, as the Chairperson of the IJIS Institute’s Security and Privacy Advisory Committee. 

The purpose of the IJIS Institute’s Security and Privacy Advisory Committee is to provide advice and counsel to the Department of Justice’s Office of Justice Programs (OJP), as well as other national organizations, on issues of information system security and privacy as applied to integrated justice and public safety information systems, and to develop materials and seminars to educate industry and government staffs on security and privacy measures, designs, and related issues. 

The Security and Privacy Advisory Committee strives to be vendor agnostic in all activities and work products and to be the authoritative source for establishing effective privacy and security measures throughout the justice, public safety, and homeland security information sharing community. Additionally, the committee’s goals include increasing government and industry awareness and understanding of technical and non-technical privacy and security requirements and improving the privacy and security posture for federal, state, local, and tribal justice information sharing efforts. In order to achieve these goals, the committee performs research, issues white papers, develops and conducts training, participates in advisory working groups, and supports technical assistance projects.

Chuck Georgo, regarding his appointment, noted that, “Successful information sharing requires trust. I believe that to get trust you need two things—honorable motive and reliability. Organizations must know that your motives benefit the social good and that your means to protect shared information from compromise is achievable and durable. While honorable motive is in the hands of law enforcement and justice agency executives, I believe that the IJIS Institute, through the Security and Privacy Advisory Committee, can help government and industry to employ effective ways for achieving the reliable means to protect that information. I look forward to working with my fellow committee members to further advance the cause of information sharing through robust security and privacy principles and practices.” 

Chuck Georgo has nearly 28 years of experience in intelligence, national security, defense, and law enforcement arenas. He has served as a strategic planner, business analyst, and technologist supporting the National Security Agency, Federal Bureau of Investigation, Department of Homeland Security, Naval Criminal Investigative Service, Naval Security Group, and many other public and private sector organizations. 

# # #

About the IJIS Institute — The IJIS Institute serves as the voice of industry by uniting the private and public sectors to improve mission critical information sharing for those who protect and serve our communities. The IJIS Institute provides training, technical assistance, national scope issue management and program management services to help government fully realize the power of information sharing. Founded in 2001 as a 501(c)(3) non-profit corporation with national headquarters on the George Washington University Virginia Campus in Ashburn, Virginia, the IJIS Institute has grown to more than 240 member and affiliate companies across the United States. For more information visit www.IJIS.org.

About NOWHERETOHIDE.ORG – NOWHERETOHIDE.ORG, LLC, was established to help federal, state, and local law enforcement, justice, and homeland security agencies to better achieve their public safety and national security objectives. As our name implies, we want to help these agencies become so effective that criminal elements have nowhere-to-hide from justice. We offer planning, assessment, and technology consulting services to help law enforcement, justice, and national security agencies identify and resolve the issues that currently stand in the way of achieving high performance standards. For more information visit www.nowheretohide.org.

What Gets Measured Gets Done…Using Evaluation to Drive Law Enforcmement Information Sharing

Tom Peters liked to say “what gets measured gets done.”  The Office of Management and Budget (OMB) took this advice to heart when they started the federal Performance Assessment Rating Tool (PART) (http://www.whitehouse.gov/omb/part/) to assess and improve federal program performance so that the Federal government can achieve better results. PART includes a set of criteria in the form of questions that helps an evaluator to identify a program’s strengths and weaknesses to inform funding and management decisions aimed at making the program more effective.

I think we can take a lesson from Tom and the OMB and begin using a formal framework for evaluating the level of implementation and real-world results of the many Law Enforcement Information Sharing projects around the nation.  Not for any punitive purposes, but as a proactive way to ensure that the energy, resources, and political will continues long enough to see these projects achieve what their architects originally envisioned. 

I would like to propose that the evaluation framework be based on six “Standards for Law Enforcement Information Sharing” that every LEIS project should strive to comply with; they include:

1. Active Executive Engagement in LEIS Governance and Decision-Making;

2. Robust Privacy and Security Policy and Active Compliance Oversight;

3. Public Safety Priorities Drive Utilization Through Full Integration into Daily Operations;

4. Access and Fusion of the Full Breadth and Depth of Regional Data (law enforcement related);

5. Wide Range of Technical Capabilities to Support Public Safety Business Processes; and

6. Stable Base of Sustainment Funding for Operational and Technical Infrastructure Support.

My next step is to develop scoring criteria for each of these standards; three to five per standard, something simple and easy for project managers and stakeholders to use as a tool to help get LEIS “done.”

I would like to what you think of these standards and if you would like to help me develop the evaluation tool itself…r/Chuck

Chuck Georgo
chuck@nowheretohide.org
www.nowheretohide.org