The new regulations require financial institutions to implement an information security program, a set of policies, procedures, and guidelines that an organization uses to protect its customer information. The program includes plans for managing access to data, detecting and responding to security incidents, security awareness training, and risk management. In addition, it sets forth the roles and responsibilities of the security team. The goal of an information security program is to protect information from unauthorized access or data breaches and can be an important part of an organization’s overall security strategy. Make sure to include these safeguards in your information security program:
Access Controls
Businesses must implement and periodically review access controls, which are security measures designed to administer who can access your customers’ information. For example, an organization might require employees to log in with a unique user ID and password, or they might use an electronic key card system. The key is to ensure that only authorized individuals can access customer information and that they can only access the information they need to do their job. Once access controls are in place, remember to review them regularly.
Inventory
One of the first steps in protecting your data is to conduct a periodic inventory, noting where and how data is gathered, stored, and transmitted. This will help you keep an accurate list of all systems, devices, platforms, and personnel that have access to your data. By keeping track of these things, you can quickly identify any potential security risks and take steps to mitigate them.
Encryption
Encryption is a process of transforming readable data into an unreadable format. It prevents anyone who does not have the key from being able to access the information. Encryption is critical to any comprehensive data security program and is necessary to comply with the FTC Safeguards Rule.
Custom Apps
If your business has developed custom applications that store, access, or transmit customers’ personal information, it is critical that you evaluate whether they meet FTC safeguarding standards.
Multi-Factor Authentication
Organizations are required to implement Multi-Factor Authentication (MFA) to access company applications or customer data. MFA adds an extra layer of security to data access by requiring users to provide more than one authentication factor when logging in.
Customer Information Disposal
Businesses must take reasonable measures to protect consumer information by securely disposing of any data within two years of serving a customer. The rule applies to paper records and electronic data, and it establishes guidelines for both the storage and destruction of customer information.
Change Management
Businesses must anticipate changes to their information systems to comply with the new regulations, including new equipment, technology, software, updates, or personnel changes that could affect customer information security.
Logs
Organizations are required to take steps to protect customer information from unauthorized access. It is recommended that businesses implement continuous monitoring protocols as they must keep a log of all access, including authorized users and unauthorized users, and take proactive steps to prevent it from happening in the first place.