The New Year – and particularly 2016 – is a perfect time to review your company’s cybersecurity policies and make necessary changes. From governmental entities, to nonprofits who collect donations by credit card, to the health care industry’s collection of health data, to employers who store employees’ social security numbers, and to hotels and resorts that collect traveler data, nearly all businesses are susceptible to liability resulting from a data breach.
The list below outlines the five key precepts of a cybersecurity plan, and is a good starting point for you to use in reviewing, updating or even drafting a cybersecurity policy for your business.
- Know the location and kinds of data you collect and possess. Inventory all of your company’s devices and equipment to learn where your company stores sensitive data. Assess all of the different kinds of data in your possession. Know the source of the data, as well as who has access to it. It is imperative to both know and follow the laws governing receipt, security and storage of data.
- Collect only data that is necessary to your business needs. Maintain and collect only the data necessary to conduct your business. Check the default settings on your software that processes transactions because sometimes software is preset to permanently store information. If you must keep sensitive information for business reasons or to comply with the law, develop a written records retention policy to identify what information to keep, how to secure it, how long to keep it, and how to securely dispose of it.
- Protect the data. The kind of protection necessary for securing sensitive data turns on the type of information it is and how it’s stored. Physical protection ranges from locks to limiting access to data or even securing devices like PIN pads. Electronic security includes encryption, firewalls, monitoring the network for malware, limiting third-party connections to the network, and changing default settings on devices. Develop employee policies for passwords, mobile devices and digital copiers.
- Purge unneeded data. Identify reasonable and lawful disposal methods based on the sensitivity of the data.
- Create a response plan for a security breach. Create a “breach response plan,” investigating what data was compromised, ending vulnerabilities, and notifying those affected by the breach. Recent North Carolina legislation requires notifying consumers and the attorney general if personal information has been compromised in a security breach.
While each industry may be subject to other specific data laws and requirements, these five precepts apply generally to every business’s cybersecurity policy.
Kara Gansmann, a North Carolina native, is an associate in Cranfill Sumner & Hartzog LLP’s Wilmington office, where she focuses her litigation and appellate practice on various aspects of labor and employment law, business and contractual disputes, medical malpractice, and HOA matters. To contact Kara Gansmann, call (910) 777-6055 or email her at [email protected].