In short: At this point, your 201 CMR 17 compliance plan should be added to your compliance program, your technical controls deployed (encryption, firewalls, etc.) and you need to select an independent 3rd party to conduct your audit.
Issued in September, the regulations require that businesses encrypt documents sent over the Internet or saved on laptops or flash drives, encrypt wirelessly transmitted data, and deploy up-to-date firewalls to create “an electronic gatekeeper” between the data and the outside world that only allows authorized users to access or transmit data.
Under the new deadline structure:
- The general compliance deadline for 201 CMR 17.00 is extended to May 1. The date is consistent with a new FTC Red Flag Rule requiring financial institutions and creditors to develop and implement written identity theft prevention programs.
- Third-party service providers now have until May 1 to prove they are capable of protecting personal information and are contractually obligated to do so. Meantime, the deadline for requiring written certification from third-party providers will be further extended to Jan. 1, 2010.
- The deadline to encrypt all laptops will be extended from Jan. 1 to May 1, and the deadline to encrypt other portable devices will be further extended to Jan. 1, 2010
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1 Comment
Comment by Tom Considine, CIPP — July 24, 2009 @ 17:23
Compliance with 201 CMR 17 doesn’t have to be difficult or complex, it requires a plan of attack and a little bit of knowledge or training to accomplish your goals.
Below are my procedures to help you begin the development of the Computer Systems Security Portion of your Written Information Security Program (WISP), it starts with the Risk Assessment survey.
You should start the process by asking some simple questions.
Physically-where is the data kept and how do you protect it from unauthorized access? If it’s on paper or media like a CD or tapes how do you keep track of who has access to it during normal daily operations? How and where do you store it when it’s not in use? How do you decide who has/needs access to it and who doesn’t need access to it? How do you destroy it when it’s no longer needed? Are your team members given security awareness training so they are aware of the threats to your business? Do you check your trash to make sure that protected data is not mistakenly discarded?
Logically- If you have some or no established programs at all, you “MUST” conduct a risk assessment survey identifying; what sensitive information you have, where you have it, and how you plan to protect it.
If the data is on a desktop or network what protective measures are in place? Do you use a firewall and antivirus protections? What are your policies on patches and hot fixes that the hardware and software manufacturers recommend for known vulnerabilities? Do you have a password policy? Is the physical security of the spaces containing ADP adequate? How often do you read your logs, or audit who has been accessing the protected data and how are they using it?
After you complete all the tasks above; you have just completed your ADP risk assessment! Now you implement the procedures necessary for identified risks based on industry best standards.
* Document as a policy the procedures how staff members are to utilize ADP in their day-to-day operations.
* Train your staff on the procedures established, and what’s expected of them, don’t forget to have them sign an acknowledgement of understanding, which includes disciplinary actions for failure to adhere to the requirements of the policy.
Congratulations! You have just created one portion of your Written Information Security Program (WISP).
Bottom line is; if you don’t ask questions on how the protection process works, can you have any confidence that your business will survive even if it is never audited? The law just requires that you take common sense steps to protect the information that your customers have entrusted to you.
Properly conducting the risk assessment, combined with some solid Lean Six Sigma practices, you will reduce duplicated operations and storage of unnecessary PI which helps to protect your business.
I Hope this help you get on the right road to compliance!
Regards,
Tom Considine, CIPP
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