MIT Privacy Protection of Job Applicant and Employee Information 6.805 th December 14 , 2005 Jacqueline Tio “MIT, MIT, let me in…” --- “Not by the hair of my chinny chin chin...”INTRODUCTION He huffed, and he puffed, and he blew the house down. Such were the fabled actions taken against the pig who did not build a house out of bricks. These actions may also be taken against those who ignore the full implications of the Internet and its effect on the privacy of job applicant and employee information. The Internet has not only created new modes of information access, but has also prompted rapid shifts toward using web-based systems and electronic databases to collect, process, and store job applicant and employee information. If these changes occur too carelessly, however, the unchecked dangers resulting from identity theft, information sharing, and fraud may create a gale force too mighty for these information systems to handle. The technology and policies in place for job applicants and employees at MIT provide a solid case study for determining the credibility of these concerns. Currently, almost all transactions involving employee information are in some way connected to the Internet. Job applicant and employee information are funneled through web-based systems such as Webhire and SAPweb. In-house processing of information in the Human Resources Department (HR) and Information Services and Technology (IS&T) also rely heavily on electronic communication. A review of MIT systems and of the policies of MIT, Harvard, the European Union, the United States, commercial job databases, and Hewlett Packard indicates that the current house safeguarding job applicant and employee information at MIT needs renovation. A set of recommendations based on this review proposes that privacy cannot be adequately protected unless significant measures are taken to change MIT policies. This includes explicitly protecting job applicant information, setting minimum standards for the electronic handling of job applicant and employee information, and increasing awareness among job applicants and employees of the fate and distribution of these types of information. Unless these recommendations are taken seriously, at present, MIT may have its bricks, but it still lacks the mortar needed to build a house that adequately safeguards both job applicant and employee information. 1THE STAKES Privacy Concerns of Job Applicant and Employee Information Numerous resume databases have made it easier than ever to search and apply for jobs. At the same time, the privacy of information posted online has become more vulnerable to both fraudulent and criminal behavior. Applicant information gleaned from resumes can be particularly invasive because of the types of information it provides such as home addresses, social security numbers, telephone numbers, and educational background. According to Pam Dixon, the executive director of the World Privacy Forum, resumes of mid-career professionals are particularly attractive to identity thieves because of the depth of information they provide. Some criminals have even gone so far as to post fake job positions online to solicit more 1personal information from their victims. Others have infiltrated job databases and amassed as 2much as 20,000 resumes before any red flags were raised. Although no case of job applicant information leakage has made headlines at MIT, the implications of these cases are chilling: a supply and demand for job applicant information has cultured a new black market, and the Internet in all its glory has empowered criminals to enter it with little or no detection. Compounding privacy concerns of job applicant information are that of employee information. In this regard, MIT has faced its own crisis with the accidental leakage of confidential employee information. In 2004, an MIT alumnus found the ID and social security numbers of over 11,000 MIT employees through Google. This information had accidentally been posted in a public directory for six months, and five employees suspected that they had 3been the victims of identity theft. In January 2005, Harvard also faced an information leakage nightmare after realizing that confidential drug procurement and contact information of students and employees were accessible through a loop-hole in the PharmaCare website. It is unclear whether this breach of protected information violated federal law, but concern arose over the potential violation of the Family Educational Rights and Privacy Act (FERPA), which grants certain students security protection, and the Health Insurance Portability and Accountability Act 1 “Online Resumes Turn Risky.” San Francisco Chronicle. 4 July 2005. 2 Dixon, Pam. “Resume Database Nightmare: Job Seeker Privacy at Risk.” Privacy Rights Clearinghouse. 19 February 2003. Online. 11 November 2005. Available: http://www.privacyrights.org/ar/Dixon-JobPrivacyRpt.htm 3 Lugovskaya, Tatyana. “MIT Employees’ Social Security Numbers Found in Public File.” The Tech. 16 April 2004. Online. Available: http://www-tech.mit.edu/V124/N20/20ssn.20n.html 2(HIPAA), which protects medical information. Although only the latter would apply to employee information, this incident suggests that the lack of protection of employee information 4is as dependent on general information practices as it is on employee information practices. Thus far, however, MIT and Harvard should count themselves lucky. At least the problems were accidental and investigative, not deliberate. Just this year in the course of only a few weeks, confidential information of roughly 180,000 people from Berkeley, Northwestern, 5and California State University were purposely breached by hackers and thieves. In light of this trend, the privacy of job applicant and employee information at MIT deserves a thorough review before an even bigger, meaner wolf decides to come and blow our house down. Electronic Information inside the House Since the mid-1970s, the MIT Human Resources department has been using electronic databases to store employee information. Today, the reliance on technology has progressed to the point where almost all campus employee information is handled electronically. Even resumes and documents submitted in paper form are scanned into electronic form by means of an electronic imaging system. Because of the reliance on electronic databases to enter, maintain, and update