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*ANOTHER* E&Y Laptop Reported as Stolen...in Late February...Containing Data on 243,000 Individuals

Oh, come on now!  I couldn't believe I was reading yet ANOTHER report of ANOTHER E&Y laptop that has been stolen recently!  ANOTHER stolen from a car...ANOTHER with an unbelievably huge amount of personally identifiable information (PII)...ANOTHER that did not have the data encrypted!  C'mon folks!  If you are information security or privacy professionals, or business leaders of any kind, you really need to step up your efforts to educate your personnel about the risks involved with using laptops, implement encryption on all mobile computing devices, and not allow such inordinately large databases of personal information to be on mobile computing devices.

It is amazing also that the laptop theft occurred in February, but the E&Y client whose PII was on the laptop, Hotels.com, was not notified until May 3. 

The data included names, addresses and credit card information.

"Ernst & Young invites those affected by the incident to enroll in a free credit monitoring service arranged by the auditor."

Why don't they just go ahead and enroll all those individuals into the credit monitoring service?  Why make the victims have to tell them to do it...it's likely many of the individuals will not be aware any potential breach has even occurred until they start having problems with their credit reports.  Yeah, sure, letters were mailed to them...but how many will be read?

"The letter from Hotels.com said "Ernst & Young was taking additional steps to protect the confidentiality of its data, including encrypting the sensitive information we provide to them as part of the audit process.""

If you entrust sensitive data, such as PII, to another company, for any reason, you should make it one of your contractual requirements for them to keep the data encrypted.  Their sloppy security is probably going to impact you more than them when they have an incident involving it.

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So if the data was encrypted via 256 bit AES, would this be (or any other mobile data theft) be as big of a deal? At what point do you say, "Whew, the data was encrypted, the probability of exploit (i.e. Risk) is minimal"?

Strongly encrypted data is generally useless in the hands of a data thief that does not have the decryption key. Yes, thefts of such encrypted data is basically then a non-incident...not only because the the thief cannot do anything with it, but also, just as importantly to businesses, you've given the individuals about whom the data applies the reassurance that the liklihood of compromise is minimal. State breach notification laws, such as California's SB 1386 (the first that went into effect) recognizes the importance of encryption by not requiring notices if the data is encrypted (however, it's worth noting this law does not indicate the strength of encryption required). Many of the other state breach notice laws, however, do not take this into consideration.

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Rebecca Herold's Bio:

Rebecca Herold,CISSP, CIPP, CISM, CISA, FLMI, has been providing information security, privacy and regulatory assistance and services to organizations from a wide range of industries for over 18 years. Rebecca was instrumental in building the information security and privacy program while at Principal Financial Group, which was awarded the CSI Information Security Program of the Year Award in 1998. IT Security ranked Rebecca as one of the top 59 IT security influencers, and Computerworld put Rebecca their list of the 25 top privacy experts and on their list of the 9 best privacy consulting firms. Rebecca has been CPO for two consulting organizations, and has had her own information privacy, security and compliance business since 2004. Rebecca has written chapters for several books, dozens of articles, and has been writing a monthly privacy column for the CSI Alert newsletter since the beginning of 2001, and is working on her 11th book. Some of her other books include The Privacy Papers, Managing an Information Security and Privacy Awareness and Training Program, The Definitive Guide to Security Inside the Perimeter (Realtime Publishers), The Shortcut Guide to Improving IT Service Support through ITIL (Realtime Publishers), and The Practical Guide to HIPAA Privacy and Security Compliance. In addition, Rebecca is the leader of The Realtime IT Compliance Community where she posts to her IT Compliance weblog. You can contact Rebecca at: rebecca_herold@realtimepublishers.net.