Freedom to Tinker

In my last post, where I discussed the (likely) theft of my SSN from the State of Ohio, I briefly discussed the possibility of “freezing” my credit report. I’ve done some more investigation on how, exactly, this works.

Details seem to vary from state to state (Consumer’s Union has a nice summary), but you generally can write to each of the three major credit report bureaus, via postal mail, and request that your account be “frozen.” This will not prevent you from getting “pre-approved” credit-card offers. For that, you separately opt-out, although you can at least do it online. Once your request takes effect, most requests to access your credit report will be denied. There are a wide variety of exceptions, mostly related to people who you’re already doing business with, which strikes me as entirely reasonable.

Cost? If you’re the victim of identity fraud (and it’s unclear whether I meet that definition), it’s free. You include a copy of your police report when you’re writing your letters to each of the credit ratings bureaus. If not, the cost is $10 per bureau. Multiply by three, and that’s $30. You’re married and want to do it for your spouse? Add another $30. What if you want to temporarily (or permanently) lift the block? The price varies, but it’s comparable.

Here’s the problem with this system: let’s say you’re doing the sort of things for which people legitimately want to look up your credit report (e.g., borrowing money for a car, opening a new credit card, renting a new apartment, etc.). Particularly if you’re changing jobs, moving to a new area, and so forth, you’ll be doing a lot of this all at once. As a result, precisely when you’re most often giving out your SSN and thus increasing your vulnerability, you also have to disable the block on your account, exposing yourself to the risk of identity theft.

The proper answer, of course, is to arrange for SSNs to have no more value to an identity thief than your name and address. The unanswered question, then, is what exactly can replace it as an authenticator? One possibility, raised in the thread on car dealers who insist on fingerprints, is to require these sorts of transactions be notarized. A notary public‘s main function is to authenticate that a specific person signed a specific document. You already need a notary’s services when you buy or sell a house. Why not require their services for any transaction that involves a personal credit report? The answer, I imagine, is cost, both in time and money. Department stores would be unable to give you “instant credit cards.” Applying to rent an apartment would become more complicated and annoying. There would be more friction, all around, to get credit. However, if identity theft continues to be such a significant problem, maybe it’s a trade-off worth making.

(Aside: how, exactly, do you convince the notary of your identity? The answer varies, but it seems to involve a photo ID, signature, and in some cases a thumbprint. You could certainly imagine cutting the notary out of the process and pushing the same authentication process out to a cash register or wherever else, but this creates a trusted path problem. When a human notary is authenticating a paper document, there’s no question to anybody what, exactly, is being authenticated. If you give your biometric and ID card to a scanner in a store, you have no idea where that data is going and what, ultimately, is being authenticated on your behalf. Astute readers may see a connection between this and the need for election systems to have voter-verifiable paper trails, but that’s a discussion for another day.)

I just received a first-class letter from the State of Ohio, telling me:

The State of Ohio has confirmed that your name and social security number was contained on a computer back-up device that was stolen. It is unlikely that someone can access the data contained in the device without specialized knowledge and equipment. Because we have no information to date that the data has been accessed, everything we are doing, or suggesting that you consider doing, is preventative.

…

The State of Ohio is doing everything possible to recover the stolen device and protect the personal information that was on the device. We regret that the loss of this sensitive data may place an undue burden of concern on you.

The letter explains how I can sign up with Debix for their identity protection services, and provides a PIN for me to use. (So, now I can spread my SSN further. Wonderful.)

The last time I set foot in Ohio was over three years ago, when I testified about electronic voting security issues, so it seems odd that they would still have my SSN on file. I don’t recall if they specifically asked me for my SSN, but it’s common for these sorts of things to ask for it as part of reimbursing travel expenses. It’s also possible that my SSN was on this backup tape for other reasons. Some news stories say that sixty Connecticut citizen’s information were present on the tape; I’m from Texas, so that shouldn’t have affected me. The State of Ohio has its own official web site to discuss the incident, which apparently happened back in June, yet they’re only telling me now.

Okay, let’s see if we can figure out what’s going on here. First, the “back-up device” in question appears to be nothing more than a backup tape. They don’t say what kind of tape it was, but there are only a handful of options these days, and it’s not exact hard to buy a tape drive, making the “specialized knowledge and equipment” line seem pretty unlikely. (As long as I’ve been doing security work, I’ve seen similar responses. The more things change…) So what actually happened? According to the official web site:

The Inspector General investigation determined that: “OAKS administrators failed to protect confidential information by authorizing state employees, including college interns, to take backup tapes containing sensitive data to their homes for overnight storage”; “OAKS, OIT (Office of Information Technology) and OBM (Office of Budget and Management) officials failed to report the theft of confidential information to state and law enforcement officials in a timely manner”; and “OAKS administrators failed to protect confidential information by allowing personnel to store sensitive data in an unsecured folder on the OAKS intranet.” The Inspector General found no evidence to suggest state agencies or employees engaged in criminal or illegal behavior surrounding these circumstances.

At its core, Ohio apparently had fantastically poor procedures along with what Jerry Saltzer refers to as the “bad news diode“, i.e., bad news never flows up the chain of command. Combine those and it shouldn’t be surprising that something would eventually go wrong. In my case, such poor procedures make it believable that nobody bothered to delete my information after it was no longer necessary to retain it. Or, maybe they have some misguided anti-terrorist accounting rule where they hang onto this data “just in case.” Needless to say, I don’t know.

It’s reasonable to presume that this sort of issue is only going to become more common over time. It’s exceptionally difficult to keep your SSN truly private, particularly if reimbursement paperwork, among other things, unnecessarily requires the disclosure of a SSN. The right answer is probably an amalgamation of data destruction policies (to limit the scope of leaks when they happen), rational data management policies (to make leaks less likely), and federal regulations making it harder to convert a SSN into cash (to make leaked SSNs less valuable).

(Sidebar: when my wife and I bought a new car in 2005, the dealer asked for my SSN. “I’m paying cash. You don’t need it,” I said. They replied that I could either wait until the funds cleared, or I could let them run a credit check on me. I grumbled and caved in. At least they didn’t ask for my fingerprint.)