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Harboring DataInformation Security, Law, and the Corporation$
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Andrea M. Matwyshyn

Print publication date: 2009

Print ISBN-13: 9780804760089

Published to Stanford Scholarship Online: June 2013

DOI: 10.11126/stanford/9780804760089.001.0001

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PRINTED FROM STANFORD SCHOLARSHIP ONLINE (www.stanford.universitypressscholarship.com). (c) Copyright Stanford University Press, 2021. All Rights Reserved. An individual user may print out a PDF of a single chapter of a monograph in SSO for personal use.date: 17 September 2021

Information Security of Financial Data

Information Security of Financial Data

Quasi-Secrets: The Nature of Financial Information and Its Implications for Data Security

(p.121) 7 Information Security of Financial Data
Harboring Data

Cem Paya

Stanford University Press

This chapter presents a technical critique challenging the most basic premises underlying the Gramm–Leach–Bliley Act—that “financial data” refers to data held by financial institutions. Instead, it argues that a better analysis starts with looking to the data, not the holder. After providing a primer on the basics of information security engineering, it asks whether there is something inherent in the nature of financial information that makes it a challenge for information security and any regulatory framework. Analyzing the two most common forms of financial information—credit card numbers and Social Security numbers—the chapter concludes that although the credit card industry appears to successfully mitigate risks of disclosure, the use of Social Security numbers as a financial identifier is inherently problematic and should be eliminated.

Keywords:   Gramm–Leach–Bliley Act, financial data, information security, financial information, credit card numbers, Social Security numbers, disclosure

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