From the summary of GAO’s findings in
INFORMATION SECURITY: Agency Responses to Breaches of Personally Identifiable Information Need to Be More Consistent (PDF, 67 pp.)
The eight federal agencies GAO reviewed generally developed, but inconsistently implemented, policies and procedures for responding to a data breach involving personally identifiable information (PII) that addressed key practices specified by the Office of Management and Budget (OMB) and the National Institute of Standards and Technology. The agencies reviewed generally addressed key management and operational practices in their policies and procedures, although three agencies had not fully addressed all key practices. For example, the Department of the Army (Army) had not specified the parameters for offering assistance to affected individuals. In addition, the implementation of key operational practices was inconsistent across the agencies. The Army, VA, and the Federal Deposit Insurance Corporation had not documented how risk levels had been determined and the Army had not offered credit monitoring consistently. Further, none of the agencies we reviewed consistently documented the evaluation of incidents and resulting lessons learned. Incomplete guidance from OMB contributed to this inconsistent implementation. As a result, these agencies may not be taking corrective actions consistently to limit the risk to individuals from PII-related data breach incidents.
According to agency officials, the Department of Homeland Security’s (DHS) role of collecting information and providing assistance on PII breaches, as currently defined by federal law and policy, has provided few benefits. OMB’s guidance to agencies requires them to report each PII-related breach to DHS’s U.S. Computer Emergency Readiness Team (US-CERT) within 1 hour of discovery. However, complete information from most incidents can take days or months to compile; therefore preparing a meaningful report within 1 hour can be infeasible. US-CERT officials stated they can generally do little with the information typically available within 1 hour and that receiving the information at a later time would be just as useful. Likewise, US-CERT officials said they have little use for case-by-case reports of certain kinds of data breaches, such as those involving paper-based PII, because they considered such incidents to pose very limited risk. Also, the agencies GAO reviewed have not asked for assistance in responding to PII-related incidents from US-CERT, which has expertise focusing more on cyber-related topics. As a result, these agencies may be expending resources to meet reporting requirements that provide little value and divert time and attention from responding to breaches.