Social Security Administration: Internet Access to Personal Earnings and
Benefits Information (Testimony, 05/06/97, GAO/T-AIMD/HEHS-97-123).

GAO discussed the Social Security Administration's (SSA) recent
experiences in providing personal benefits estimates to individuals via
the Internet, focusing on general privacy and security considerations
that federal agencies should address to safeguard any sensitive
information made available as a public service via the Internet.

GAO noted that: (1) SSA has recently tried to educate the public about
the importance of its programs and availability of information, such as
the Personal Earnings and Benefit Estimate Statement (PEBES); (2) as
part of this initiative, SSA last year began permitting individuals to
request PEBES through the Internet, with the document being sent by
mail; (3) according to SSA officials, before taking the step of
transmitting PEBES data over the Internet, they spent a year testing and
consulting with outside experts, including those in the areas of privacy
and computer security; (4) among the security features intended to
preserve individual privacy was the requirement for an individual to
enter five authenticating elements into the system in order to access
the data; (5) on April 9, after public outcry and concerns about the
privacy of sensitive information, the Acting Commissioner of Social
Security suspended on-line receipt of PEBES data; (6) despite the growth
and leap in ease of use, the Internet has inherent security risks
because of the way it was designed; (7) computer hackers have for years
exploited the security weaknesses of systems connected to the Internet;
(8) as a result, the need for secure information systems and networks
has never been greater; (9) for most organizations, a prudent approach
involves determining an appropriate level of protection, then ensuring
that any security breaches that do occur can be effectively detected and
countered; (10) this generally means establishing: (a) a comprehensive
program with top management commitment, sufficient resources, and
clearly defined roles and responsibilities; (b) clear, consistent, and
up-to-date security policies and procedures; (c) periodic vulnerability
assessments to identify security weaknesses; (d) security awareness
training; (e) sufficient time and training for systems administrators
and information security personnel; (f) efficient use of automated
security tools; and (g) a robust incident-response capability, so that
attacks can be detected and a response initiated quickly in order to
aggressively track and prosecute the offenders; (11) along with phased
testing of "PEBES-By-Mail" and interactive PEBES, SSA took a number of
measures that officials believed would adequately safeguard requesters'
privacy, the system itself, and the data it contains; and (12) GAO has
just initiated its work and therefore cannot yet conclude whether SSA i*

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  T-AIMD/HEHS-97-123
     TITLE:  Social Security Administration: Internet Access to Personal 
             Earnings and Benefits Information
      DATE:  05/06/97
   SUBJECT:  Computer crimes
             Computer security
             Hackers
             Computer networks
             Confidential communication
             Right of privacy
             Telecommunication
             Social security benefits
             Social security number
IDENTIFIER:  SSA Personal Earnings and Benefits Estimate Statement
             Internet
             
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Cover
================================================================ COVER


Before the Subcommittee on Social Security
Committee on Ways and Means
House of Representatives

For Release on Delivery
Expected at
3 p.m.
Tuesday
May 6, 1997

SOCIAL SECURITY ADMINISTRATION -
INTERNET ACCESS TO PERSONAL
EARNINGS AND BENEFITS INFORMATION

Statement of Joel C.  Willemssen
Director, Information Resources Management
and
Keith A.  Rhodes
Technical Director, Office of the Chief Scientist
Accounting and Information Management Division

GAO/T-AIMD/HEHS-97-123

GAO/AIMD-97-123T


(511219)


Abbreviations
=============================================================== ABBREV

  PEBES - Personal Earnings and Benefit Statement
  SSA - Social Security Administration

============================================================ Chapter 0

Mr.  Chairman and Members of the Subcommittee: 

We appreciate this opportunity to participate in the Subcommittee's
hearing on privacy and security concerns relating to the Social
Security Administration's (SSA) recent experiences in providing
personal benefits estimates to individuals via the Internet.  Mr. 
Chairman, both you and the Ranking Minority Member have expressed
concerns about whether SSA's interactive benefits estimates service
adequately protects the privacy of Americans and whether unauthorized
access to confidential information is taking place over the Internet. 
Such concerns are understandable.  SSA, as administrator of the
nation's largest federal benefits program, touches the life of almost
every American.  It is essential that citizens be able to trust that
the agency is safeguarding the personal information it collects. 

While we have just initiated a review of SSA's use of the Internet to
disseminate benefits estimates, we have, however, reported on
computer and Internet security and on the risks facing agencies in
providing electronic access to data.\1 Our remarks today will,
therefore, focus on general privacy and security considerations that
federal agencies should address to safeguard any sensitive
information made available as a public service via the Internet. 


--------------------
\1 See our report entitled Information Security:  Computer Attacks at
Department of Defense Pose Increasing Risks (GAO/AIMD-96-84 and
GAO/T-AIMD-96-92, May 22, 1996) and our testimony entitled
Information Security:  Computer Hacker Information Available on the
Internet (GAO/T-AIMD-96-108, June 5, 1996). 


   PROVIDING PERSONAL EARNINGS AND
   BENEFITS INFORMATION VIA THE
   INTERNET
---------------------------------------------------------- Chapter 0:1

As you know, Mr.  Chairman, for just under 10 years, SSA has been
providing a Personal Earnings and Benefit Estimate Statement (PEBES)
to any individual requesting it.  The statement includes a yearly
record of earnings, estimates of Social Security taxes paid,
estimates of retirement and disability benefits, and potential
survivor benefits should the individual die.  Legislation\2 mandated
that beginning in fiscal year 1995, PEBES be sent to all eligible
U.S.  workers aged 60 and over; beginning October 1, 1999, it is
scheduled to be sent annually to all eligible workers aged 25 and
over--an estimated 123 million people.\3

As we reported last year, the public has found PEBES to be a useful
financial planning tool.\4

SSA has recently tried to educate the public about the importance of
its programs and availability of information, such as the PEBES
statement; this initiative to provide "world class service" was--at
least in part--in reaction to surveys showing public confidence in
SSA programs at a low level.  While much of this perception may
relate to continual discussion about SSA's financial viability,
officials at the agency have stated that they are attempting to be
more responsive to customer desires.  As part of this initiative, the
agency last year began permitting individuals to request PEBES
through the Internet, with the document being sent by mail.  This was
seen as a new alternative to visiting an SSA office in person or
using its toll-free telephone number. 

In March of this year, in an effort to be as responsive as possible,
SSA began permitting on-line dissemination of the statement to
individuals.  Using the Internet for this purpose was a planned part
of the agency's electronic service delivery project, a component of
its business plan for fiscal years 1997-2001.  According to this
plan, the project would ensure that among other items, "integrity and
confidentiality of client data are safeguarded."\5

According to SSA officials, before taking the step of transmitting
PEBES data over the Internet, they spent a year testing and
consulting with outside experts, including those in the areas of
privacy and computer security.  Among the security features intended
to preserve individual privacy was the requirement for an individual
to enter five authenticating elements into the system in order to
access the data.  These elements were name, Social Security number,
date and place of birth, and mother's maiden name. 

In early April, press reports of privacy concerns over the
availability of this information via the Internet sparked widespread
reaction--including the fear that those not entitled to the
information could access it without difficulty.  Experts also
questioned the adequacy of the five key pieces of information needed
to obtain the data, pointing out that three of the five are available
in public databases.  With this publicity, according to SSA
officials, attempts to access the data at SSA's web site\6 escalated
from about 10 to 80 per second. 

SSA officials believed the situation was well in hand, that the
security measures taken were sufficient.  They pointed out that, as
of April 7, security screening denied access to about 9,000 of the
27,000 requests for on-line PEBES data.  SSA officials stated that
while they monitored many attempts to break into the system, none
succeeded. 

On April 9, after public outcry and concerns about the privacy of
sensitive information, the Acting Commissioner of Social Security
suspended on-line receipt of PEBES data. 

Mr.  Chairman, we see this issue as one of balance.  While SSA has
attempted to be responsive to the needs of its customers, the
question is how--and, given the risks involved, whether--to do this
via the Internet.  If the decision is made to use the Internet in
this way, the question is whether SSA is doing everything possible to
ensure that sensitive information is not compromised.  Convenience
with undue risk to security is no bargain. 

This is especially important because the interactive PEBES project is
just one of many initiatives planned for the next few years that are
intended to make greater use of technology.  Other SSA efforts under
the electronic service delivery umbrella include third-party access
(using technology to allow others, such as state or local government
employees or advocacy-group members, to assist individuals in dealing
with SSA), dial-up bulletin boards, touchtone telephone access (for
less sensitive customer records), and even interactive cable
television.\7


--------------------
\2 Public laws 101-239 (December 19, 1989) and 101-508 (November 5,
1990). 

\3 Besides the age requirement, eligibility entails having a Social
Security number, having wages or net earnings from self-employment,
not presently receiving Social Security benefits, and having a
current address obtainable by SSA. 

\4 See SSA Benefit Statements:  Well Received by the Public but
Difficult to Comprehend (GAO/HEHS-97-19, December 5, 1996). 

\5 Business Plan, Fiscal Years 1997-2001, SSA publication no. 
01-008, April 1996. 

\6 The World Wide Web (www), as its name implies, is a vast
collection of interconnected computers spanning the world.  A web
site refers to any computer on the web and its particular web
address.  SSA's web site, then, is the location at which its PEBES
data can be found. 

\7 These projects are described briefly in SSA publication no. 
01-008, April 1996. 


   INFORMATION SECURITY ON THE
   INTERNET
---------------------------------------------------------- Chapter 0:2

In the last few years, the use of the Internet has grown tremendously
and has placed a vast array of information at the fingertips of
millions of users.  This is due primarily to the availability of
tools that have made the Internet much easier to use.  As a result,
we have witnessed a rush to connect to the Internet; today there are
over 40 million users worldwide. 

Despite this growth and leap in ease of use, the Internet has
inherent security risks because of the way it was designed.  The
Internet is a complex network that has evolved over the last decade
from an initially limited and experimental link of interconnected
computers.  The network, developed for the most part by scientists
and engineers, was initially designed to test how a military command
and control system could get messages through in a post-nuclear
environment without regard to security.  To do this, the network was
built so that a message would use any available path to its
destination, regardless of how many "dead ends" it encountered.  The
most important element of the network was, therefore, its robustness,
or tenacity--not security. 

The relative insecurity of the Internet makes using it as a vehicle
for transmitting sensitive data--such as personal Social Security
information--a decision requiring careful consideration.  In such an
environment, one must weigh added convenience against the potential
compromise and misuse of such information--and the potential damage
to the database itself.  In considering such trade-offs, it is
important to remember that, whether on-line or not, Social Security
benefits information is available through means other than
electronic. 

Computer hackers\8 have for years exploited the security weaknesses
of systems connected to the Internet.\9 The growing number of people
having access to the Internet--any one of whom is a potential
hacker--coupled with the rapid growth of and reliance on
interconnected computers, has made cyberspace a dangerous frontier. 
Informal groups of hackers openly share information on how to break
into computer systems.  Despite security features that boast
ever-increasing sophistication, hackers have more tools and
techniques than ever before, and the number of attacks on systems is
growing each day.\10

As a result, the need for secure information systems and networks has
never been greater. 

This problem is directly affecting federal systems. 
Interconnectivity, combined with poor security management, is placing
billions of dollars' worth of assets at risk of loss, and vast
amounts of sensitive data at risk of unauthorized disclosure.  While
greater use of interconnected systems offers significant benefits,
such systems are much more vulnerable to malicious attack by
anonymous intruders--an increasing threat to our national welfare. 
Consequently, information security has been added to our list of
government programs designated as high-risk because of
vulnerabilities to waste, fraud, abuse, or mismanagement.\11


--------------------
\8 The term hacker refers to any individual who, though unauthorized,
attempts to penetrate a computer information system; browse, steal,
or modify data; deny access or service to others; or cause damage or
harm in some other way. 

\9 See GAO/AIMD-96-84 and GAO/T-AIMD-96-92, May 22, 1996, and
GAO/T-AIMD-96-108, June 5, 1996. 

\10 Testimony of Richard Pethia, Software Engineering Institute,
Carnegie Mellon University, Pittsburgh, before the Permanent
Subcommittee on Investigations, Committee on Governmental Affairs,
United States Senate, June 5, 1996. 

\11 High-Risk Series:  Information Management and Technology
(GAO/HR-97-9, February 1997). 


   IMPLEMENTING COMPUTER SECURITY: 
   PROTECT, DETECT, REACT
---------------------------------------------------------- Chapter 0:3

Making information systems more secure is complicated, not only by
the huge numbers of people having access to them, but also by the
complexity of most systems themselves.  Most large organizations
have, along with personal workstation computers, mainframes, software
applications, servers, routers, and external connections.  These
systems use a variety of products from a number of different vendors. 
Fully understanding the security weaknesses caused by the complex
interrelationships of these products is a difficult task. 
Accordingly, absolute computer security is not possible.  In
developing effective systems security, officials must, then, consider
what level of risk is acceptable.  Such a decision will hinge on
issues such as the type and sensitivity of the information, how
vulnerable to attack the computers and networks are, where potential
threats might come from, available countermeasures, and costs. 

For most organizations, a prudent approach involves determining an
appropriate level of protection, then ensuring that any security
breaches that do occur can be effectively detected and countered. 
This generally means establishing (1) a comprehensive program with
top management commitment, sufficient resources, and clearly defined
roles and responsibilities, (2) clear, consistent, and up-to-date
security policies and procedures, (3) periodic vulnerability
assessments to identify security weaknesses, (4) security awareness
training, (5) sufficient time and training for systems administrators
and information security personnel, (6) efficient use of automated
security tools, and (7) a robust incident-response capability, so
that attacks can be detected and a response initiated quickly in
order to aggressively track and prosecute the offenders. 

The first point just mentioned, about roles and responsibilities, is
essential.  In determining these, a decision must be made on
identifying the owners of information versus the stewards of
information.  Owners are ultimately responsible for the decision on
what level of security risk to accept, while stewards manage that
risk.  A recent example of a government agency's handling of
electronic data in the steward role rather than the owner role was
when the Internal Revenue Service introduced the proposal of
electronically filing tax returns.  In this case, it left the
decision of whether to put one's sensitive data into cyberspace with
the individual, the owner. 

Turning to detection of an attack once one has been made,
organizations use two basic methods:  system audits and monitoring. 
These terms are used loosely within the computer security community
and often overlap.  A system audit is a one-time or periodic security
evaluation.  Monitoring, in contrast, refers to an ongoing activity
that examines either the system or its users.  In general, the more
"real-time" an activity is, the closer it is to monitoring. 

In terms of reaction, an organization should address computer
security incidents by developing an incident-handling capability. 
Commonly referred to as a computer emergency-response team, it is
typically used to provide the ability to respond quickly and
effectively, contain and repair damage from incidents, and prevent
future damage. 


   SSA'S ACTIONS TO ADDRESS
   SECURITY
---------------------------------------------------------- Chapter 0:4

In developing Internet PEBES service, SSA used both government and
private consultants.  The Los Alamos National Laboratory provided a
detailed report, including suggested solutions for addressing
Internet security risks.  Extensive support was also received from
the CommerceNet consortium,\12 as well as from individual private
companies.  Along with phased testing of "PEBES-By-Mail" and
interactive PEBES, SSA took a number of measures that officials
believed would adequately safeguard requesters' privacy, the system
itself, and the data it contains.  For example, both the request data
and the on-line response utilize a form of encryption; further,
according to SSA, requesters cannot directly query, browse, or
download SSA records. 

SSA officials further state that automated transaction information is
continually captured electronically, allowing SSA to audit system use
and identify potential abuse; multiple attempts to obtain the same
data are automatically restricted; and bulk requests are not honored. 
SSA officials add that individuals are alerted to on-line risks
inherent in using the Internet to obtain PEBES data and are offered
alternative methods.  They are also warned of criminal penalties for
the intentional misuse of Social Security data.\13 Finally, other
measures were taken, whose disclosure by us today could compromise
their effectiveness. 

Despite these measures, however, detection of and action against
security breaches is not simple.  It is very difficult to track down
computer-system abusers and, existing laws notwithstanding,
prosecution is rare; one reason is that acceptable electronic
evidence is not yet clearly defined. 

Mr.  Chairman, as we stated earlier, we have just initiated our work
and therefore cannot yet conclude whether SSA implemented a prudent
approach to address the security risks in providing Internet PEBES
service.  Although the agency took steps it thought would render its
data and system secure, we do not know whether they have succeeded. 
However, we do offer the following observations. 

We commend the Acting Commissioner's decision to suspend the service
while investigating the adequacy of the security measures that have
been taken.  We also urge caution before any decision is made to
resume the program. 

The Internet security issue is so large and daunting that SSA, like
every other federal organization, will have to rely on commercial
solutions and outside expert opinion.  This reliance poses hurdles
because the commercial sector, experts, and standards-setting bodies
have not yet reached consensus on how to best solve Internet security
problems. 

It is important for SSA--and every other agency considering Internet
access--to decide whether it will be the steward or owner of the
information it holds.  Being the steward implies a vast job of making
the American public knowledgeable about computer security; being the
owner confers upon SSA the responsibility to assess the potential
threat to its data with the utmost care and restraint. 

Regardless of the direction it takes on the owner/steward issue, SSA
will need to demonstrate that it has performed a comprehensive risk
assessment of the data so that the level of protection required can
be clearly defined.  Accompanying this task will be the need to
provide an adequate training and awareness program that will enable
users to understand the risks of Internet access. 


--------------------
\12 CommerceNet is an industry consortium dedicated to accelerating
the growth of the Internet and creating business opportunities for
its members. 

\13 Four laws are cited:  42 U.S.C.  408 (misuse of Social Security
number), 5 U.S.C.  552(a) (Privacy Act), 18 U.S.C.  1030 (misuse of
computer), and 18 U.S.C.  1001 (false statements or entries). 
Penalties range from fines with maximums of $5000 or $10,000 and jail
terms up to 10 years. 


-------------------------------------------------------- Chapter 0:4.1

Mr.  Chairman, this concludes our statement.  We would be happy to
respond to any questions you or other Members of the Subcommittee may
have at this time. 


*** End of document. ***