It was inevitable, given how sloppy many companies are when handling the identity of their customers, that someone would eventually steal all my personal information. But no matter how much science you have in your back pocket, it hurts when you get slapped in the face.
The theory is clear: systems must be built to withstand being breached. But they often aren't.
One thing for sure: the system used at Countrywide Mortgage was so leaky that when I phoned my bank to ask how I should handle the theft, my advisor said, “I don't know. I'm trying to figure that out, since my information was stolen too.” We commiserated. It's not a good feeling.
And then we talked about the letter.
What a letter. It is actually demented. It's as though Countrywide's information systems didn't exist, and weren't a factor in any insider misbehavior.
I agree there was a bad employee. But is he the only guilty party? Was the system set up so employees could only get at my personal information when there was a need to know?
Was the need to know documented? Was there a separation of duties? Was there minimization of data? Can I see the audit trails? What was going on here? I want to know.
My checks rolled in to Countrywide with scientific precision. No one needed to contact me through emergency channels. Why would anyone get access to my personal information? Just on a whim?
How many of us were affected? We haven't been told. I want to know. Iit bears on need to know and storage technologies.
But I'm ahead of myself. I'll share the letter, sent by Sheila Zuckerman on behalf of “the President” (“President” who??).
We are writing to inform you that we recently became aware-that a Countrywide employee (now former) may have sold unauthorized personal information about you to a third party. Based on a joint investigation conducted by Countrywide and law enforcement authorities, it was determined that the customer information involved in this incident included your name, address, Social Security number, mortgage loan number, and various other loan and application information.
We deeply regret this incident and apologize for any inconvenience or concern it may cause you. We take our responsibility to safeguard your information very seriously and will not tolerate any actions that compromise the privacy or security of our customers’ information. We have terminated the individual's access to customer information and he is no longer employed by Countrywide. Countrywide will continue to work with law enforcement authorities to pursue further actions as appropriate.
I don't want to hear this kind of pap. I want an audit of your systems and how they protected or did not protect me from insider attack.
If you are a current Countrywide mortgage holder, we will take necessary precautions to monitor your mortgage account and will notify you if we detect any suspicious or unauthorized activity related to this incident. We will also work with you to resolve unauthorized transactions on your Countrywide mortgage account related to this incident if reported to us in a timely manner.
I find this paragraph especially arrogant. I'm the one who needs to do things in a timely manner although they didn't take the precautions necessary to protect me.
As an additional measure of protection, Countrywide has arranged for complimentary credit monitoring services provided by a Countrywide vendor at no cost to you over the next two years. We have engaged ConsumerInfo.com, Inc., an Experian® Company, to provide to you at your option, a two-year membership in Triple Advantage Credit Monitoring. You will not be billed for this service. Triple Advantage includes daily monitoring of your credit reports from the three national credit reporting companies (Experian, Equifax and TransUnion®) and email monitoring alerts of key changes to your credit reports.
Why are they doing this? Out of the goodness of their hearts? Or because they've allowed my information to be spewed all over the world through incompetent systems?
To learn more about and enroll in Triple Advantage, log on to www.consumerinfo.com/countrywide and complete the secure online form. You will need to enter the activation code provided below on page two of the online form to complete enrollment. If you do not have Internet access, please, call the number below for assistance with enrollment. You will have-90 days from the-date of-this letter-to-use the code to activate the credit monitoring product.
Borrower Activation Code: XXXXXXXXX
And now the best part. I'm going to need to hire a personal assistant to do everything required by Countrywide and still remain employed:
In light of the sensitive nature of the information, we urge you to read the enclosed brochure outlining precautionary measures you may want to take. The brochure will guide you through steps to:
Contact the major credit bureaus and place a fraud alert on your credit reports;
Review your recent account activity for unauthorized charges or accounts;
Be vigilant and carefully review your monthly credit card and other account statements over the next twelve to twenty-four months for any unauthorized charges; anTake action should any unauthorized activity appear on your credit report.
I need more information on why I only need to be vigilant for twelve to twenty-four months, when, thanks to Countrywide, my personal information has spilled out and I have no way to get it back!
We apologize again that this incident has occurred and for any inconvenience or worry it may have caused. If you have questions, please call our special services hotline at 1-866-451-5895, and a specially trained representative will be ready to assist you.
Countrywide Office of the President
O.K. This is going to be a long process. It drives home the need for data minimization. It underlines the need for stronger authentication. But EVERY case like this should make us deeply question the way our systems are structured, and ask why there are no professional standards that must be met in protecting private information.
When a bridge collapses, people look into the why of it all.
We need to do that with these identity breaches too. As far as I'm concerned, Countrywide has a lot of explaining to do. And as a profession we need clear engineering standards and ways of documenting how our systems are protected through “need to know” and the other relevant technologies.
Finally, we all need to start making insider attacks a top priority, since all research points to insiders and our number one threat.
2 thoughts on “Are Countrywide's systems designed around need to know?”
I was offered the monitoring service for a similar — though less severe — screwup.
The catch-22 is that, in order to have the Experian service watch for possible abuse of your SSN, you have to give /them/ your SSN. So then, who watches the watcher?
> Was the need to know documented? Was there a separation of duties?
> Was there minimization of data? Can I see the audit trails? What was going
> on here? I want to know.
Me too. I believe in the long run we will expect and demand that behind-the-scenes business workflows will be transparently viewable and testable. Ward Cunningham is WAY ahead of the curve here:
Countrywide seems to have played a (the?) major role in triggering the current global financial meltdown, which most commentators are attributing to a lack of supervision/regulation. IMHO we cannot expect companies/organization to regulate themselves when it comes to identity management anymore than was the case when dealing with risk management.
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