In this series on crafting a cybersecurity plan for your business, the third aspect of a plan implements ways to protect the personal data gathered and used by your business. While the best protection of data depends on what kinds of data your business uses, protection involves four general areas: physical security, electronic security, personnel security, and contractor and vendor security. Use these guidelines to draft the protection component of your own cybersecurity plan.
Physical Security: The best defense here is essentially a locked door and written policies for access to personal data. Consider storing tangible items like papers, disks and jump drives in a locked file cabinet or locked room (or off-site storage facility), limiting access only to those employees who have a legitimate business need. Identify who has a key. Remind employees not to leave papers on their unattended desks. If you ship personal data, encrypt it and keep an inventory of what data is shipped. Secure items like PIN pads.
Electronic Security: This area includes password management, device security and Internet safety. Your written policy should require employees to use “strong” passwords that must be changed frequently and password-activated screen savers. It should also forbid the sharing of passwords and posting passwords at work stations. Change vendor-supplied default passwords for new software and equipment. Ensure your employees encrypt data sent digitally by e-mail or over public networks. Limit laptops and smartphone access to only those who need portability to perform their jobs. Use wiping programs to delete unneeded data on laptops. Require IT administrators to approve all downloads or changes to security settings, and regularly run anti-virus and anti-spyware programs. Consult your IT specialists for firewalls, security features of digital copiers, and an intrusion detection system.
Employee Security: With employees, it is imperative to not only draft employee policies for cybersecurity, but to also adhere and enforce those policies. Put your cybersecurity rules in employee handbooks. Ask employees to sign confidentiality agreements and security standards. Some employee policies implement protocols for responding to e-mails and telephone calls to avoid “phishing” scams. Require regular cybersecurity training for employees and update them with new risks and vulnerabilities.
Outside Vendor/Contractor Security: Your company’s security practices are only as successful as those who implement them. Carefully vet your company’s contractors and service providers by comparing their security practices to your own. In your contract with these providers, address specific security issues for the type of data the contractor will handle. Insist that they notify you of any security incidents even if data was not actually compromised.
By addressing these aspects of data protection, your cybersecurity plan will foster a heightened culture for security. But more so, a strong cybersecurity plan can serve to limit your liability in the event of an unfortunate data breach.
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].
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