California State Bill SB1386

From: Steve Zenone (zenoneat_private)
Date: Fri Mar 21 2003 - 17:03:14 PST

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    Hello,
    
    This message is in regards to getting clarification on what 
    to do in the event of a breach per SB1386.
    
    Starting on July 1, 2003, California State Bill SB1386 will 
    become operative. From a technical InfoSec perspective, I
    am unclear about a section of the bill.
    
    In a nutshell, to quote from the original bill text, SB1386
    will...
    
     "require a state agency, or a person or business that 
      conducts business in California, that owns or licenses 
      computerized data that includes personal information, 
      as defined, to disclose in specified ways, any breach of
      the security of the data, as defined, to any  resident 
      of California whose unencrypted personal information 
      was, or is reasonably believed to have been, acquired 
      by an unauthorized person." 
    
    The unclear part is the use of the word "unencrypted".
    For example, can someone jokingly use ROT13 to encrypt 
    data and say, "hey - it's encrypted!"?
    
     % cat data | tr 'a-zA-Z' 'n-za-mN-ZA-M' > encrypted
    
    In other words, what defines encryption so as to satisfy
    this bill's requirements?
    
    Secondly, What if I have an encrypted database, however,
    an "attacker" is able to monitor the plaintext traffic over 
    http from the front-end webserver (which is fed data from
    the encrypted DB) to the remote browser client. Obviously,
    there is a breach. The "attacker" isn't getting the entire
    database. Rather, they're able to get session specific 
    plaintext packet dumps. If the breach occurred on my 
    network, I take it that this would need to be disclosed 
    per the bill. What if the breach occurred outside of my 
    network and affected sessions between my network and
    provider XYZ. Does the bill still require me to disclose?
    
    This is hypothetical. Of course, it would make more sense
    using https as opposed to http. However, for the sake of
    trying to get clarification, I tossed out the above example.
    
    Last example, what if the data moves over the Net via SSL 
    to a remote user's workstation where it is then stored
    unencrypted. If the user's system is compromised and
    the data is "acquired by an unauthorized person", where
    do we go based upon the requirements of SB1386? 
    
    Thanks in advance for your insight.
    
    SB1386 original text:
     http://info.sen.ca.gov/pub/01-02/bill/sen/sb_1351-1400/sb_1386_bill_20020926_chaptered.html
    
    Regards,
    Steve
    
    
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