Best Practices / Patterns for Enterprise Protection/Remediation of SSNs (Social Security Numbers)
- by Erik Neu
I am interested in hearing about enterprise solutions for SSN handling. (I looked pretty hard for any pre-existing post on SO, including reviewing the terriffic SO automated "Related Questions" list, and did not find anything, so hopefully this is not a repeat.)
First, I think it is important to enumerate the reasons systems/databases use SSNs: (note—these are reasons for de facto current state—I understand that many of them are not good reasons)
Required for Interaction with External Entities. This is the most valid case—where external entities your system interfaces with require an SSN. This would typically be government, tax and financial.
SSN is used to ensure system-wide uniqueness.
SSN has become the default foreign key used internally within the enterprise, to perform cross-system joins.
SSN is used for user authentication (e.g., log-on)
The enterprise solution that seems optimum to me is to create a single SSN repository that is accessed by all applications needing to look up SSN info. This repository substitutes a globally unique, random 9-digit number (ASN) for the true SSN. I see many benefits to this approach. First of all, it is obviously highly backwards-compatible—all your systems "just" have to go through a major, synchronized, one-time data-cleansing exercise, where they replace the real SSN with the alternate ASN. Also, it is centralized, so it minimizes the scope for inspection and compliance. (Obviously, as a negative, it also creates a single point of failure.)
This approach would solve issues 2 and 3, without ever requiring lookups to get the real SSN.
For issue #1, authorized systems could provide an ASN, and be returned the real SSN. This would of course be done over secure connections, and the requesting systems would never persist the full SSN. Also, if the requesting system only needs the last 4 digits of the SSN, then that is all that would ever be passed.
Issue #4 could be handled the same way as issue #1, though obviously the best thing would be to move away from having users supply an SSN for log-on.
There are a couple of papers on this:
UC Berkely: http://bit.ly/bdZPjQ
Oracle Vault: bit.ly/cikbi1
