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Recent problems in the news
The massive security breach of Target's customer data may affect more than 110 million Americans — potentially about 1 in 3 persons living in the United States. Followed in quick succession by another 40 million customers of Neiman Marcus (and more disclosures expected soon from other retailers), it is time for us in the hotel industry to look at our own policies and procedures, and to think about how we should respond to these malicious attacks.
Hoteliers beware
Hotels are obvious targets for identity and financial theft for many reasons. Hotels transact business through credit cards, and those credit cards are kept on file and can be accessed multiple times during a guest's stay. The possibility that a credit card charge will be recorded occurs with each night's room charge, room service, bar or restaurant bill, spa charge, and so on. Every charge is another opportunity for an identity thief to access the information using sophisticated computer hacks and other malicious software, generally without the hotel's knowledge.
The need to respond to guest demands is another source of insecurity. The Identity Theft Resource Center noted, "The ability to connect to the Internet is an integral part of many individual's daily life. This has led to the increased demand for public WiFi." As a result, hotels find themselves compelled to offer wireless internet, and that service is almost always unsecured. But an unsecured wireless network is "just as dangerous as leaving files of your most important personal documents on a street curb for all to see. Hackers can easily get into an unsecured wireless network and get financial information, business records or sensitive e-mails." (PC World, "Got Wireless Security"). At the same time, hotels have little say in the matter. Guests demand wireless internet service.
Finally, hotels have employees — lots of employees — and many of them have access to the credit card and other personal information of guests. No matter how well trained and supervised, more personnel correlates to greater risk. The fact that low-level employees typically have access to key guest information, and that there is, historically, a high turnover in hotel employees, exacerbates the problem.
What happened to Target?
While investigations are continuing, sources have reported that investigators believe the attackers used similar techniques and pieces of malicious software to steal data from retailers. One of the pieces of malware is a RAM scraper, or memory-parsing software, which allows cyber criminals to grab encrypted data by capturing it when it travels through the live memory of a computer, where it appears in plain text, the sources said. While the technology has been around for many years, its use has increased in recent years as retailers have improved their security, making it more difficult for hackers to obtain credit card data using other approaches.
The lesson? Even as merchants become more vigilant and focus on the security of their systems, criminals have become more sophisticated and are investing more time and effort in crafting their own systems.
What should I do?
The fact that Target, and others, have been victimized might not seem, at first, to impact other businesses. Securing guest and corporate information is a key task, and the steps necessary to implement a secure environment are unique to each organization. However, there are some general considerations that all firms should be aware of that are essential to securing information:
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Inventory and Identify Information. Hotels operators should inventory potentially sensitive information and document on which computers, servers and laptops it's stored.
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Restrict Access and Collection of Data. Operators and owners should keep sensitive information on the fewest number of computers or servers, and be sure to segregate it — the fewer copies of data you have, the easier it is to protect.
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Use Technology. Hotels should utilize encryption and other means for storing, and secure connections for receiving or transmitting, credit card information and other sensitive data.
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Design and Implement Effective Policies and Procedures. Firms should design, institute and follow an effective privacy policy, including policies for using social media, and should be careful not to overstate the effectiveness of their measures. Remember – no system is completely safe.
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Passwords and Access. For internal communications and information, protect sensitive data with strong passwords and change passwords on a regular basis.
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Deal with Vendors. Much, if not most, of computer systems and services are handled by vendors — check their security practices. Hotels should review their agreements with vendors to ensure that they are implementing best practices, that they are responsible for the security of the information they handle, and that they work with and at the direction of the client in case of a breach.
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Review your Insurance. Cybersecurity insurance has gone through tremendous changes in just the past year; review your policies to ensure that they are effective and provide meaningful coverage.
Most of all, hotel companies need to make a commitment to secure the sensitive information of their companies and their guests, and to seek out informed consultants and advisors. Information security is a relatively new and rapidly changing area, and requires specialized knowledge; the investment today can protect a hotel from being front page news — for the wrong reasons — later.
Robert Braun is a senior member of the Global Hospitality Group at JMBM. The JMBM Data Security Group works with clients to establish and enforce data security policies, and assists clients when there are breaches. They have helped a variety of clients, including hospitality companies, in developing compliance programs, addressing data breach issues, and negotiating contracts with vendors and providers. Contact Bob Braun (RBraun@jmbm.com, 310.785.52331) for assistance. Bob Braun is a member of the International Association of Privacy Professionals and was the first and only "Super Lawyer" in Southern California in 2012 with a specialty in information technology.
This article was first published by Jim Butler of the Global Hospitality Group Hotel Lawyers, authors of the Hotel Law Blog.
