The Basics of Drafting a Security Guideline Program
In our recent article we talked about the FTC’s safety requirements for financial institutions that handle customer data. Because the definition has expanded since 2003 of what qualifies as a financial institution, more businesses now fall under the category. As such, they need to develop a comprehensive “security information program” which addresses new-age hazards and threats in the digital space.
This is not only to protect data, but avoid regulatory pitfalls and serious financial penalties. Some organizations have already drafted their program, but others – especially those now falling under the FTC Safety Standard guidelines – may not. Regardless, it’s still the responsibility of any financial institution to follow the standards.
While the process is unique to each organization, there are key elements in each program and draft. Bytagig will help you begin the foundations to your security program, allowing you to decisively build a comprehensive protective data house. There are over a dozen core concepts that are required for these programs, so we’ll provide a “cheat sheet” to get you started.
FTC Security Program Guideline Requirements
Establish a Qualified Individual
Much like any good plan, a “team lead” is necessary to oversee and assist with the drafting of the security program. The requirements for the lead are flexible. They can be from “in house,” a third-party provider, or someone with experience and familiarity with your organization’s needs.
Secondly, you will need to conduct a thorough risk assessment. Risk assessments are valuable as they test your organization’s level of security at every stage. They can demonstrate how strong, or weak, your infrastructure is. They’re not only required, but they paint a larger picture of the state of your data security, a steppingstone to create a fundamental security plan.
Next, once the results of the risk assessments have been analyzed, you’ll shift into the actual drafting and development of your security program.
This program has several requirements, which we’ll go over below. The goal is to create protective measures for the data flow in your organization, as revealed by the risk assessment.
Determine Access Controls
Access controls grants permissions to users within a business network, allowing – or disallowing – movement in the network based on their position. This require assessing who can peruse types of data, and whether that permission is necessary.
Create a Data Inventory
What kind of customer information does your enterprise manage? Where does it go? How is it stored? Mapping this out is a key part of the security plan, and allows you to identify risk zones based on the data utilized in network sectors. That also includes the people accessing data, the devices information is stored on, platforms, software, and how it’s modified. You’ll need to routinely conduct this.
Whenever possible, enable encryption for data transfer. Encryption is one of the best ways to safeguard customer information when in transit.
Multi-factor authentication is required in some capacity and must be enabled for your institution. The MFA requirements specifically need a device, a token, and biometrics for data access/management.
You can use an alternative, but only if the “Qualified Individual” has a written and comprehensive secondary option.
Evaluate App Security
If you utilize third party apps, build them in-house, and/or manage customer data through them, you’ll need to assess their data security levels. You should be able to do this with an extensive risk assessment test.
Appropriate Data Disposal Policy
If the need arises to remove, delete, or dispose of customer data, it must be done in a secure way where that information cannot be used or rediscovered. Maintenance or keeping a record of the data is only done if there is a legitimate business or legal need to do so.
Log Access Records
Maintaining a record of those who access your network is important, as it lets you check validity. It also lets you create logs of potentially invalid users and invalid access, so this is a critical aspect of digital record keeping for your enterprise.
Anticipate New Risks
The digital space isn’t static and threats will change over time. As such, so must your business. Changes in your infrastructure must also meet security and Safety Standards. As well, written plans like backup methods in anticipation of breaches or disaster are anticipation strategies that fit the Safety Standard protocol.
None of our tips and established guidelines will help without the right staff and resources. Therefore, integrate these tips into your Program as you finalize its draft. Remember, the Security Guideline must have a written document for submission.
- Routinely test the efficacy of your security guidelines
- Train staff with accessible but comprehensive goals to aid each level of your business and allow for easier introduction of guideline policies
- Clarify your expectations with providers or third-party resources if you have them, as they’ll need to meet your guideline protocols as well
- Keep any and all security programs/apps constantly updated, along with software routinely used for routine business operations
- Develop a comprehensive and written backup response plan in case of disaster, malicious or otherwise
We realize that the development and documentation of a comprehensive Security Guideline Program can prove immensely challenging. That’s especially the case for businesses and organizations that may have limited experience with these requirements, or now fall under the definition of a financial institution.
However, Bytagig can help. We have the resources and expertise to aid your development of a custom plan.
Bytagig is dedicated to providing reliable, full-scale cyber security and IT support for businesses, entrepreneurs, and startups in a variety of industries. Bytagig works both remotely with on-site support in Portland, San Diego, and Boston. Acting as internal IT staff, Bytagig handles employee desktop setup and support, comprehensive IT systems analysis, IT project management, website design, and more. Bytagig is setting the standard for MSPs by being placed on the Channel Future’s NexGen 101 list.