Alan Jaffa and Darren Kruk Discuss Building a Chain of Compliance
In its November issue, DSNews featured an article authored by Safeguard Properties CEO, Alan Jaffa, and Information Security Officer, Darren Kruk, titled Building a Chain of Compliance.
BUILDING A CHAIN OF COMPLIANCE
A layered approach maintains the integrity and strength of information security in the mortgage servicing industry.
There is an old proverb that says a chain is only as strong as the weakest link. This is true in the mortgage servicing industry when managing data security. Mortgage servicers, at the top of the chain, have systems and policies in place to protect private and confidential information at the highest levels.
In turn, servicers share certain information with their field service partners—the next link in the chain—when property preservation services are required to inspect and maintain vacant and defaulted properties. Those companies then provide access to data as required to other links in the chain—employees, inspectors, and contractors who monitor and perform services at those properties.
Every link in the chain must be equally strong in understanding and adhering to policies and procedures to protect the security and integrity of confidential information. Ongoing data security training is critical to ensure that every person who has access to sensitive information complies on a day-to-day basis with all applicable guidelines and requirements.
Those include the unique requirements of mortgage companies and their field service partners, as well as industry and regulatory guidelines of agencies such as the Consumer Financial Protection Bureau (CFPB), Fannie Mae, Freddie Mac, HUD, and the U.S. Department of Veterans Affairs (VA).
The challenge in protecting data through an entire chain of participants is that it becomes more difficult to ensure the confidentiality of data down each successive link. Small business contractors, for example, may not have the technical resources of a large mortgage servicer or national field service company but still must make sure the data they access is protected with the same vigilance. To ensure compliance, field services companies must not only educate their inspector and contractor networks on best practices for physical and information security, but they must also routinely monitor and audit them to ensure compliance.
Data asset management is a critical component of information security. Every company needs to understand the data it has collected, its classification, and how and where it is stored. Knowing the nature of this data is important for protection, and anyone who has access to confidential data should take appropriate measures to protect it.
Protecting Access and Passwords
Inspectors and contractors performing work at properties are granted limited access to field service and client systems that contain confidential information that they need to complete their work. All user names and passwords, as well as data housed on systems, must be kept confidential. This also applies to the inspectors’ and contractors’ own systems and accounts. IDs and passwords should not be shared or displayed in a public place.
As field servicing companies develop mobile applications to better service the needs of their clients, it becomes more important for inspectors and contractors to ensure their systems are secure.
People use computers and smartphones in almost every aspect of modern life. These devices, while they grant access to a variety of services and information, also can become coveted honeypots of information. If exploited, these devices can be susceptible to identity theft.
Inspector and contractor networks need to create complex passwords for all devices used in the office and in the field including computers, laptops, tablets, and smartphones. It also is important to change those passwords on a frequent basis to prevent attacks that may compromise accounts.
Anti-Virus and Firewall Programs
Most people understand the importance of anti-virus programs, especially those who have experienced the complications of a virus that has infected their computers or systems. Firewalls, while not as widely used, are just as important. These programs, when installed correctly, can help to prevent hackers from gaining access to systems, computers, files, and confidential data. They need to be renewed frequently with the latest virus definitions and firewall updates.
While keeping anti-virus software up-to-date, it is important to patch the operating system and programs, as well. There are new vulnerabilities that are discovered frequently within these programs and systems that may allow unwanted intruders to gain access to confidential data. The companies that create this software release security patches and updates to plug these holes. It is critical these systems are current, especially on mobile devices.
Encryption is the process of encoding data in a way that hackers cannot read it, but that authorized parties can. It is critical for not only the hard drives on computers, but also the easy-to-use external thumb drives. In the event of a loss, the encrypted data that resides on these drives would be useless to hackers who may look to improperly use the information contained within them.
Many different programs can be used to encrypt drives and systems. These include Bitlocker (included with Windows OS) and True Crypt (which can be used to encrypt external and thumb drives), as well as whole drive encryption programs such as those made by CheckPointe and Sophos.
Shred, Shred, Shred
The importance of a good confetti-cut shredder to destroy confidential documents cannot be overstated. Strip-cut shredders are not effective because the remnants can be reconstituted too easily. Policies should be in place to shred all documents that contain confidential data of any type.
Once a business identifies the types of data that are confidential, anything written down or printed out containing that sensitive information needs to be shredded rather than tossed in a trash bin.
Often forgotten are post-its or other notepads. People use them for everything from taking down phone numbers and account numbers to even remembering passwords. They attempt to hide them where they think no one else will find them, such as under their computer monitors or keyboards, and as a result, they often forget to shred them. Anything with confidential or classified information must be shredded to ensure full data security.
In addition to securing systems and devices, all businesses need to be aware of potential physical security concerns. All access to business systems and buildings should be protected. This must include access by every person who enters a facility, from the guy delivering water to the technicians who work on computer systems. Every person who enters a facility must be viewed as a potential data security risk and should be assessed and controlled accordingly.
At the same time, it’s important to recognize the need for different levels of security control based on the potential risk that a vendor or service provider may pose. For example, a grass-cut vendor will require different levels of control than a technician who is repairing computers. The technician, who may have more access to data within a company’s systems, presents a greater risk and thus the company should work under tighter controls. Does the technician require a master password to access all data or just what he needs to fix? Does he work for a reputable vendor? These are the types of questions that should be addressed before systems vendors and technicians are called in to complete work.
Physical access to computer systems is another important consideration. Most people do not realize that passwords are not needed if someone has physical access to a system. There are alternate ways to remove or change passwords on everything from networking devices to operating systems if someone has physical access to those devices. This applies to backups of data and systems as well as to originals. All outside technicians or vendors need to be monitored while completing work. A trusted company employee should be at a system vendor’s side throughout his or her entire visit.
Communication Is Sacred
Field service companies need to continually remind their inspector and contractor networks that electronically transmitted communications must be protected. When communicating in person, it is easy to control the audience. This is not the case with electronic communication.
Every day and in every business, people send emails, text messages, and voicemails to others and have no idea who else may have access to these messages. These forms of communications must be secured so that confidential data does not become compromised.
To ensure the security of all electronic communications, any websites being viewed on company computers need to have a secure sockets layer (SSL) when confidential data is being transferred, and any email provider must use transport layer security (TLS). SSLs and TLS provide communication security over the Internet and allow for data and message confidentiality. Any data transfers should proceed only if these protections are in place.
Being cautious when relaying confidential information applies to phone conversations as well. It is critical to validate who is on the other end of the phone line before discussing any sensitive data.
Use Common Sense
Every situation concerning confidential client and property information needs to be evaluated to strengthen every link in the information and data chain. The process requires common sense, vigilance, and ongoing training to ensure that all guidelines, regulations, and best practices established by mortgage companies, regulators, and field service companies are followed.
Inspectors and contractors in the field need to be aware of potential security breaches and take the necessary precautions to keep all confidential data secure. It is everyone’s job to make sure that each link of the chain is as strong as possible.
Alan Jaffa is the CEO and Darren Kruk is the information security officer of Safeguard Properties, the largest mortgage field service company in the United States.
Please click here to view the article in PDF.
Safeguard Properties is the largest mortgage field services company in the U.S. Founded in 1990 by Robert Klein and based in Valley View, Ohio, the company inspects and maintains defaulted and foreclosed properties for mortgage servicers, lenders, and other financial institutions. Safeguard employs approximately 1,700 people, in addition to a network of thousands of contractors nationally. Website: www.safeguardproperties.com.