Best Practices for Protecting Privacy in a Data Enclave

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Presentation transcript:

Best Practices for Protecting Privacy in a Data Enclave National Academy of Sciences Privacy of Employee Data Workshop June 6, 2017 Timothy Mulcahy Vice President, Program Director, NORC Data Enclave

What is a Data Enclave? A Data Enclave is a high-performance computational and analytical environment that provides authorized users secure remote access to confidential microdata and tools. * Researchers authenticate into the secure data center via an encrypted web and analyze sensitive data in a secure, remote environment that is both convenient and cost-effective.

An Ideal Data Enclave System Secure, flexible, low cost Meet replication standard: the only way to understand and evaluate an empirical analysis fully is to know the exact process by which the data were generated Metadata crucial to meet the standard Composed of documentation and structured metadata Create foundation for metadata documentation and extend data lifecycle

NORC Data Enclave® Developed and implemented in 2006 in partnership with the National Institute of Standards and Technology Clients span across state and federal governments, as well foundations, research institutes, and universities Currently support more than 800 researchers Results are used to inform a wide spectrum of policy and programming decisions across the public and private sector, as well as journal articles, books, book chapters, position papers, professional conferences, dissertations, etc.

Holistic Security Protocol Safe Projects Must have institutional approval and backing Safe People Trusted Researchers Safe Setting Data and processing housed in secure network Users access environment over secure connection Safe Outputs Strict disclosure review of all exports = Safe Use

Portfolio Approach to Secure Data Access Educational / training protection Statistical protection Legal protection Operational / technological protection

Educational / Researcher Training Remote / web-base, online modules Researcher locations (academic institutions, conferences AAEA, JSM, AOM, ASA, ASSA, NBER summer institute) Navigating through the enclave environment (drives, data views, statistical tools); data-specific training (metadata documentation, weighting), statistical disclosure control (import/exports) Note: The training is designed to go above and beyond current practice in terms of both frequency and coverage

Statistical Protection Remove obvious identifiers and replace with unique identifiers Statistical techniques chosen by agency (recognizing data quality issues)* Noise added? Full disclosure review of all data exported coordinated between NORC and Data Producer * Note: At discretion of producer and can go above and beyond the minimum level of protection

Ensuring Safe Derivative Outputs We work closely with our sponsors to define their statistical disclosure needs We develop a customized data protection plan that specifies all disclosure rules for statistical output review and safe release, processes, protocols and personnel for receiving, responding, and reviewing disclosure review requests Once output has been cleared for release it is delivered to researchers via a secure mobile file share mechanism.

Statistical Disclosure Review Online transfer site Secure Lab Data Work Area Researcher Logs in Disclosure Review Exports/Output Imports/Input

Legal Protection On an annual basis: Approved researchers sign Data User Agreements (legally binding the individual and institution) Researchers and NORC staff sign Non-disclosure Agreements specific to each dataset Researchers and NORC staff complete confidentiality training Penalties: CIPSEA violators subject to up to 5 years in prison and $250,000 fine

Data Protection / Operational Encrypted connection using virtual private network (VPN) technology prevents outsiders from reading the data transmitted between the researcher’s computer and NORC’s network. Users access the data enclave from a static or pre-defined narrow range of IP addresses. Citrix’s Web-based technology. All applications and data run on the server at the data enclave. Data enclave prevents users from transferring any data from data enclave to a local computer. Data files cannot be downloaded from the remote server to the user’s local PC. User cannot use the “cut and paste” feature in Windows to move data from the Citrix session. User is prevented from printing the data on a local computer. Audit logs and audit trails

Restrictions in the Data Enclave Access only to authorized applications Most system menus have been disabled Some control key combinations or right click functions are also disabled on keyboard Closed environment: no open ports, no access to Internet or email No output (tables, files) may be exported and no datasets imported without first being reviewed for disclosure issues File explorer is on default settings

IT, Systems, and Data Security The NORC’s Data Enclave IT Security Plan is fully compliant with the Federal Information Security Management Act (FISMA), provisions of mandatory Federal Information Processing Standards (FIPS), and meets all of NIST’s IT, data, system, and physical security requirements. Auditors conduct a design-level review of controls that support the security of the Data Enclave using NIST Special Publications 800-53 (Moderate-Impact assets) and HIPAA as the security standards, and an analysis of risks to electronic protected health information (ePHI) in the Data Enclave on an annual basis and after any significant changes to security infrastructure. The Data Enclave maintains a disaster recover site with redundant systems to guarantee a high level of availability. Privately managed datacenter allows for greater operational controls and data security.

IT, Systems, and Data Security (cont.) Multi-factor authentication provides access to a Citrix- based, encrypted terminal session, virtual private network Controlled laboratory environment for data analytics Limit who can access the data / limit data views All data and analyses conducted in secure HIPAA and FISMA compliant data center

Platform Infrastructure, Architecture, Technologies

Massive Parallel Processing Solutions Infrastructure: HP Vertica HP commodity servers EMC VNX/Dell Compellent SANs VMware Citrix XenApp / XenDesktop Analytic / Intelligence Suite (Tableau, SAS, R, SPSS, SQL) ** HortonWorks Hadoop v1 Distribution ** Red Hat Linux EOS v6.4 supported by StackIQ

Example Dashboards

Example Dashboards

Example Dashboards

Example Dashboards

Example Reports

Examples Reports

Enclave Clients Annie E. Casey Foundation Maine Health Data Organization Administration for Community Living, Administration on Aging Mellon Foundation Metadata Technology North America Bureau of Justice Statistics National Agricultural Statistics Service Centers for Medicare and Medicaid National Bureau of Economic Research Services National Institute of Standards and Technology Consumer Financial Protection Bureau Duke University National Science Foundation Economic Research Service Northeastern University Federal Communication Commission Ohio State University Financial Crisis Inquiry Commission Oregon State University Health Care Cost Institute Private Capital Research Institute Human Services Research Institute The College Board IMPAQ International, LLC. University of Chicago Kauffman Foundation Vermont Care Network Kresge Foundation MacArthur Foundation

Questions?