Know what personal information you have in your files and on your computers.
- Inventory all file storage and electronic equipment. Where does your company store sensitive data?
- Talk with your employees and outside service providers to determine who sends personal information to your business, and how it is sent.
- Consider all the ways you collect personal information from customers, and what kind of information you collect.
- Review where you keep the information you collect, and who has access to it.
Keep only what you need for your business.
- Use Social Security numbers only for required and lawful purposes. Don’t use SSNs as employee identifiers or customer locators.
- Keep customer credit card information only if you have a business need for it.
- Review the forms you use to gather data — like credit applications and fill-in-the-blank web screens for potential customers — and revise them to eliminate requests for information you don’t need.
- Change the default settings on your software that reads customers’ credit cards. Don’t keep information you don’t need.
- Truncate the account information on electronically printed credit and debit card receipts you give your customers. You may include no more than the last five digits of the card number, and you must delete the card’s expiration date.
- Develop a written records retention policy, especially if you must keep information for business reasons or to comply with the law.
Protect the information that you keep.
- Put documents and other materials containing personally identifiable information in a locked room or file cabinet.
- Remind employees to put files away, log off their computers, and lock their file cabinets and office doors at the end of the day.
- Implement appropriate access controls for your building.
- Encrypt sensitive information if you must send it over public networks.
- Regularly run up-to-date anti-virus and anti-spyware programs on individual computers.
- Require employees to use strong passwords.
- Caution employees against transmitting personal information via e-mail.
- Create security policies for laptops used both within your office, and while traveling.
- Use a firewall to protect your computers and your network.
- Set “access controls” to allow only trusted employees with a legitimate business need to access the network.
- Monitor incoming Internet traffic for signs of security breaches.
- Check references and do background checks before hiring employees who will have access to sensitive data.
- Create procedures to ensure workers who leave your organization no longer have access to sensitive information.
- Educate employees about how to avoid phishing and phone pretexting scams.
Properly dispose of what you no longer need.
- Create and implement information disposal practices.
- Dispose of paper records by shredding, burning, or pulverizing them.
- Defeat dumpster divers by encouraging your staff to separate the stuff that’s safe to trash from sensitive data that needs to be discarded with care.
- Make shredders available throughout the workplace, including next to the photocopier.
- Use wipe utility programs when disposing of old computers and portable storage devices.
- Give business travelers and employees who work from home a list of procedures for disposing of sensitive documents, old computers, and portable devices.
Create a plan for responding to security incidents.
- Create a plan to respond to security incidents, and designate a response team led by a senior staff person.
- Draft contingency plans for how your business will respond to different kinds of security incidents. Some threats may come out of left field; others — a lost laptop or a hack attack, to name just two — are unfortunate, but foreseeable.
- Investigate security incidents immediately.
- Create a list of who to notify — inside or outside your organization — in the event of a security breach.
- Immediately disconnect a compromised computer from the Internet.