WHITE PAPER: MASSACHUSETTS DATA SECURITY REGULATIONS

Save this PDF as:
 WORD  PNG  TXT  JPG

Size: px
Start display at page:

Download "WHITE PAPER: MASSACHUSETTS DATA SECURITY REGULATIONS"

Transcription

1 WHITE PAPER: MASSACHUSETTS DATA SECURITY REGULATIONS

2 Introduction Massachusetts regulations set forth minimum requirements for both the protection of personal information and the electronic storage or transmittal of personal information. These dual requirements recognize the challenge of conducting business in a digital world and reflect the manner in which most investment advisers presently conduct their advisory business. The Standards for The Protection of Personal Information of Residents of the Commonwealth (201 CMR 17.00) establishes a duty to protect personal information (defined as a combination of a name along with a Social Security number, bank account number, or credit card number); sets forth standards for the protection of such personal information and mandates the development of a security system covering a company s computers. In brief, the Massachusetts data security regulations require businesses that own or license personal information about Massachusetts residents to develop a comprehensive information security program that contains administrative, technical and physical safeguards for the protection of personal information. These measures must (i) be commensurate with the size and scope of their advisory business and (ii) contain administrative, technical and physical safeguards to ensure the security of such personal information. In addition, companies that store personal information on portable devices (e.g., laptops, PDAs and flash drives) or transmit personal information wirelessly on public networks must deploy encryption and protect against data leakage. The regulations define the phrase owns or licenses as receiving, maintaining, processing or otherwise having access to personal information. 2

3 Standards for Protecting Personal Information The Massachusetts regulations are quite specific as to what measures are required when developing and implementing an information security plan. Such measures include, but are not limited to: Designating one or more employees to maintain the comprehensive information security program; Identifying and assessing internal and external risks to the security, confidentiality and/or integrity of any electronic, paper or other records containing personal information and evaluating and improving, where necessary, current safeguards for minimizing risks, including, but not limited to: (i) ongoing employee (including temporary and contract employee) training; (ii) employee compliance with policies and procedures; and (iii) means for detecting and preventing security system failures; Developing security policies for employees relating to the storage, access and transportation of records containing personal information outside of business premises; Imposing disciplinary measures for violations of the comprehensive information security program rules; Preventing terminated employees from accessing records containing personal information; Taking reasonable steps to select and retain third-party services providers that are capable of maintaining appropriate security measures to protect such personal information consistent with the regulations and any applicable federal regulations; Requiring such third-party service providers by contract to implement and maintain such appropriate security measures for personal information; 3

4 Reasonable restrictions upon physical access to records containing personal information and storage of such records and data in locked facilities, storage areas or containers; Regular monitoring to ensure that the comprehensive information security program is operating in a manner reasonably calculated to prevent unauthorized access to or unauthorized use of personal information; and upgrading information safeguards as necessary to limit risks; Reviewing the scope of the security measures at least annually or whenever there is a material change in business practices that may reasonably implicate the security or integrity of records containing personal information; and Documenting responsive actions taken in connection with any incident involving a breach of security, and mandatory post-incident review of events and actions taken, if any, to make changes in business practices relating to protection of personal information. Computer System Security Requirements The Massachusetts regulations require that an information security program include security procedures that cover a company s computer systems. Pursuant to Massachusetts law, any business that uses computers to store personal information about Massachusetts residents must, at a minimum, have the following elements in its information security program: Secure user authentication protocols including (i) control of user IDs and other identifiers; (ii) a reasonably secure method of assigning and selecting passwords, or use of unique identifier technologies, such as biometrics or token devices; (iii) control of data security passwords to ensure that such passwords are kept in a location and/or format that does not compromise the security of the data they protect; (iv) restricting 4

5 access to active users and active user accounts only; and (v) blocking access to user identification after multiple unsuccessful attempts to gain access or the limitation placed on access for the particular system; Secure access control measures that (i) restrict access to records and files containing personal information to those who need such information to perform their job duties; and (ii) assign unique identifications plus passwords, which are not vendor supplied default passwords, to each person with computer access, that are reasonably designed to maintain the integrity of the security of the access controls; To the extent technically feasible, encrypt all transmitted records and files containing personal information that will travel across public networks, and encryption of all data to be transmitted wirelessly; Reasonably monitor systems for unauthorized use of or access to personal information; Encrypt all personal information stored on laptops or other portable devices; For files containing personal information on a system that is connected to the Internet, install reasonably up-to-date firewall protection and operating system security patches, reasonably designed to maintain the integrity of the personal information; Install reasonably up-to-date versions of system security agent software which must include malware protection and reasonably up-to-date patches and virus definitions, or a version of such software that can still be supported with up-to-date patches and virus definitions, and is set to receive the most current security updates on a regular basis; and Educate and train employees on the proper use of the computer security system and the importance of personal information security. 5

6 As can be seen from the above list, what the Massachusetts regulations have generously provided to advisers is, in effect, a shopping list that they can take to their nearest computer consultant. Investment advisers would be well-advised to turn each of the above listed elements into a computer security checklist, find a reputable computer specialist and outsource the project to those people who have the expertise to equip your computer system with the requisite security capabilities. 6

7 About the Author Scott Gottlieb is the founder and President of U.S. Compliance Consultants. Mr. Gottlieb brings to U.S. Compliance Consultants more than 17 years of experience in developing, implementing, and monitoring compliance programs for investment advisers and hedge funds. U.S. Compliance Consultants is a fullservice consulting firm that specializes in registration and compliance support services for investment advisers. U.S. Compliance Consultants services include investment adviser registration, development of written compliance and supervisory procedures, compliance training, annual compliance reviews and mock compliance audits. U.S. Compliance Consultants can customize a compliance solution to fit the exact needs of your advisory firm. 15 East Putnam Avenue, Suite 286 Greenwich, CT Phone (888) Fax (203)

Massachusetts Identity Theft/ Data Security Regulations

Massachusetts Identity Theft/ Data Security Regulations Massachusetts Identity Theft/ Data Security Regulations Effective March 1, 2010 Are You Ready? SPECIAL REPORT All We Do Is Work. Workplace Law. In four time zones and 45 major locations coast to coast.

More information

MONTSERRAT COLLEGE OF ART WRITTEN INFORMATION SECURITY POLICY (WISP)

MONTSERRAT COLLEGE OF ART WRITTEN INFORMATION SECURITY POLICY (WISP) MONTSERRAT COLLEGE OF ART WRITTEN INFORMATION SECURITY POLICY (WISP) 201 CMR 17.00 Standards for the Protection of Personal Information Of Residents of the Commonwealth of Massachusetts Revised April 28,

More information

Client Advisory October 2009. Data Security Law MGL Chapter 93H and 201 CMR 17.00

Client Advisory October 2009. Data Security Law MGL Chapter 93H and 201 CMR 17.00 Client Advisory October 2009 Data Security Law MGL Chapter 93H and 201 CMR 17.00 For a discussion of these and other issues, please visit the update on our website at /law. To receive mailings via email,

More information

Wellesley College Written Information Security Program

Wellesley College Written Information Security Program Wellesley College Written Information Security Program Introduction and Purpose Wellesley College developed this Written Information Security Program (the Program ) to protect Personal Information, as

More information

Navigating the New MA Data Security Regulations

Navigating the New MA Data Security Regulations Navigating the New MA Data Security Regulations Robert A. Fisher, Esq. 2009 Foley Hoag LLP. All Rights Reserved. Presentation Title Data Security Law Chapter 93H Enacted after the TJX data breach became

More information

Written Information Security Programs: Compliance with the Massachusetts Data Security Regulation

Written Information Security Programs: Compliance with the Massachusetts Data Security Regulation Written Information Security Programs: Compliance with the Massachusetts Data Security Regulation Melissa J. Krasnow, Dorsey & Whitney LLP A Note discussing written information security programs (WISPs)

More information

CONNECTICUT RIVER WATERSHED COUNCIL, INC. DOCUMENT MANAGEMENT & WRITTEN INFORMATION SECURITY POLICY

CONNECTICUT RIVER WATERSHED COUNCIL, INC. DOCUMENT MANAGEMENT & WRITTEN INFORMATION SECURITY POLICY CONNECTICUT RIVER WATERSHED COUNCIL, INC. DOCUMENT MANAGEMENT & WRITTEN INFORMATION SECURITY POLICY The Council s document management policy is intended to cover all documents produced and held by the

More information

Written Information Security Programs: Compliance with the Massachusetts Data Security Regulation

Written Information Security Programs: Compliance with the Massachusetts Data Security Regulation View the online version at http://us.practicallaw.com/7-523-1520 Written Information Security Programs: Compliance with the Massachusetts Data Security Regulation MELISSA J. KRASNOW, DORSEY & WHITNEY LLP

More information

Written Information Security Programs: Compliance with the Massachusetts Data Security Regulation

Written Information Security Programs: Compliance with the Massachusetts Data Security Regulation View the online version at http://us.practicallaw.com/7-523-1520 Written Information Security Programs: Compliance with the Massachusetts Data Security Regulation Melissa J. Krasnow, Dorsey & Whitney LLP

More information

Automation Suite for. 201 CMR 17.00 Compliance

Automation Suite for. 201 CMR 17.00 Compliance WHITEPAPER Automation Suite for Assurance with LogRhythm The Massachusetts General Law Chapter 93H regulation 201 CMR 17.00 was enacted on March 1, 2010. The regulation was developed to safeguard personal

More information

IDENTITY THEFT: DATA SECURITY FOR EMPLOYERS. Boston, MA 02110 Richmond, Virginia 23219 Tel. (617) 502.8238 Tel. (804) 783.7579

IDENTITY THEFT: DATA SECURITY FOR EMPLOYERS. Boston, MA 02110 Richmond, Virginia 23219 Tel. (617) 502.8238 Tel. (804) 783.7579 IDENTITY THEFT: DATA SECURITY FOR EMPLOYERS Daniel J. Blake, Esq. Vijay K. Mago, Esq. LeClairRyan, A Professional Corporation LeClairRyan, A Professional Corporation One International Place, Eleventh Floor

More information

Page 1. Copyright 2009. MFA - Moody, Famiglietti & Andronico, LLP. All Rights Reserved.

Page 1. Copyright 2009. MFA - Moody, Famiglietti & Andronico, LLP. All Rights Reserved. Page 1 Page 2 Page 3 Agenda Defining the Massachusetts Personal Data Security Law Becoming Compliant Page 4 Massachusetts Privacy Law Defining the Massachusetts Personal Data Security Law - 201 CMR 17.00

More information

MIT s Information Security Program for Protecting Personal Information Requiring Notification. (Revision date: 2/26/10)

MIT s Information Security Program for Protecting Personal Information Requiring Notification. (Revision date: 2/26/10) MIT s Information Security Program for Protecting Personal Information Requiring Notification (Revision date: 2/26/10) Table of Contents 1. Program Summary... 3 2. Definitions... 4 2.1 Identity Theft...

More information

WHITE PAPER: UNDERSTANDING INSIDER TRADING

WHITE PAPER: UNDERSTANDING INSIDER TRADING WHITE PAPER: UNDERSTANDING INSIDER TRADING What is Insider Trading? Insider trading is the buying or selling of a security, in breach of a fiduciary duty or other relationship of trust and confidence,

More information

Massachusetts Residents

Massachusetts Residents Identity Theft & Fraud Protection for Identity Theft & Fraud Protection for Massachusetts Residents Copyright Notice November 2009 Joe Burns All rights reserved This PowerPoint presentation is a part of

More information

Protecting Personal Information: The Massachusetts Data Security Regulation (201 CMR 17.00)

Protecting Personal Information: The Massachusetts Data Security Regulation (201 CMR 17.00) Protecting Personal Information: The Massachusetts Data Security Regulation (201 CMR 17.00) May 15, 2009 LLP US Information Security Framework Historically industry-specific HIPAA Fair Credit Reporting

More information

Written Information Security Plan (WISP) for. HR Knowledge, Inc. This document has been approved for general distribution.

Written Information Security Plan (WISP) for. HR Knowledge, Inc. This document has been approved for general distribution. Written Information Security Plan (WISP) for HR Knowledge, Inc. This document has been approved for general distribution. Last modified January 01, 2014 Written Information Security Policy (WISP) for HR

More information

MFA Perspective. 201 CMR 17.00: The Massachusetts Privacy Law. Compliance is Mandatory... Be Thorough but Be Practical

MFA Perspective. 201 CMR 17.00: The Massachusetts Privacy Law. Compliance is Mandatory... Be Thorough but Be Practical MFA Perspective 201 CMR 17.00: The Massachusetts Privacy Law Compliance is Mandatory... Be Thorough but Be Practical DEADLINE FOR FULL COMPLIANCE HAS BEEN EXTENDED FROM JANUARY 1, 2010 TO MARCH 1, 2010

More information

SAMPLE TEMPLATE. Massachusetts Written Information Security Plan

SAMPLE TEMPLATE. Massachusetts Written Information Security Plan SAMPLE TEMPLATE Massachusetts Written Information Security Plan Developed by: Jamy B. Madeja, Esq. Erik Rexford 617-227-8410 jmadeja@buchananassociates.com Each business is required by Massachusetts law

More information

MASSACHUSETTS IDENTITY THEFT RANKING BY STATE: Rank 23, 66.5 Complaints Per 100,000 Population, 4292 Complaints (2006) Updated January 17, 2009

MASSACHUSETTS IDENTITY THEFT RANKING BY STATE: Rank 23, 66.5 Complaints Per 100,000 Population, 4292 Complaints (2006) Updated January 17, 2009 MASSACHUSETTS IDENTITY THEFT RANKING BY STATE: Rank 23, 66.5 Complaints Per 100,000 Population, 4292 Complaints (2006) Updated January 17, 2009 Current Laws: Identity Crime: A person is guilty of identity

More information

ASCINSURE SPECIALTY RISK PRIVACY/SECURITY PLAN July 15, 2010

ASCINSURE SPECIALTY RISK PRIVACY/SECURITY PLAN July 15, 2010 ASCINSURE SPECIALTY RISK PRIVACY/SECURITY PLAN July 15, 2010 OBJECTIVE This Security Plan (the Plan ) is intended to create effective administrative, technical and physical safeguards for the protection

More information

Designation of employee(s) in charge of the program; Identifying and assessing risks/threats and evaluating and improving

Designation of employee(s) in charge of the program; Identifying and assessing risks/threats and evaluating and improving PRIVACY & DATA SECURITY LAW JOURNAL MASSACHUSETTS On September 22, 2008, Massachusetts adopted regulations that will require businesses, wherever located, that own, license, store, or maintain information

More information

The Massachusetts Data Security Law and Regulations

The Massachusetts Data Security Law and Regulations The Massachusetts Data Security Law and Regulations November 2, 2009 Boston Brussels Chicago Düsseldorf Houston London Los Angeles Miami Milan Munich New York Orange County Rome San Diego Silicon Valley

More information

Massachusetts MA 201 CMR 17.00. Best Practice Guidance on How to Comply

Massachusetts MA 201 CMR 17.00. Best Practice Guidance on How to Comply Massachusetts MA 201 CMR 17.00 Best Practice Guidance on How to Comply Massachusetts MA 201 CMR 17.00 Best Practices for Compliance 1 Overview MA 201 CMR 17.00 has been in the news for the last 18 months.

More information

A Practical Guide to Understanding and Complying with Massachusetts Data Security Regulations. February 2010

A Practical Guide to Understanding and Complying with Massachusetts Data Security Regulations. February 2010 A Practical Guide to Understanding and Complying with Massachusetts Data Security Regulations February 2010 Table of Contents Background... 1 Are You Required to Comply?... 1 What You Need to Do...2 Reference

More information

HELPFUL TIPS: MOBILE DEVICE SECURITY

HELPFUL TIPS: MOBILE DEVICE SECURITY HELPFUL TIPS: MOBILE DEVICE SECURITY Privacy tips for Public Bodies/Trustees using mobile devices This document is intended to provide general advice to organizations on how to protect personal information

More information

Estate Agents Authority

Estate Agents Authority INFORMATION SECURITY AND PRIVACY PROTECTION POLICY AND GUIDELINES FOR ESTATE AGENTS Estate Agents Authority The contents of this document remain the property of, and may not be reproduced in whole or in

More information

TASK -040. TDSP Web Portal Project Cyber Security Standards Best Practices

TASK -040. TDSP Web Portal Project Cyber Security Standards Best Practices Page 1 of 10 TSK- 040 Determine what PCI, NERC CIP cyber security standards are, which are applicable, and what requirements are around them. Find out what TRE thinks about the NERC CIP cyber security

More information

Supplier Information Security Addendum for GE Restricted Data

Supplier Information Security Addendum for GE Restricted Data Supplier Information Security Addendum for GE Restricted Data This Supplier Information Security Addendum lists the security controls that GE Suppliers are required to adopt when accessing, processing,

More information

February 22, 2011. (Revision 2)

February 22, 2011. (Revision 2) Real-Time Massachusetts Data Security Law Monitoring Leveraging Asset-Based Configuration and Vulnerability Analysis with Real-Time Event Management February 22, 2011 (Revision 2) Copyright 2011. Tenable

More information

PCI DSS Requirements - Security Controls and Processes

PCI DSS Requirements - Security Controls and Processes 1. Build and maintain a secure network 1.1 Establish firewall and router configuration standards that formalize testing whenever configurations change; that identify all connections to cardholder data

More information

Belmont Savings Bank. Are there Hackers at the gate? 2013 Wolf & Company, P.C.

Belmont Savings Bank. Are there Hackers at the gate? 2013 Wolf & Company, P.C. Belmont Savings Bank Are there Hackers at the gate? 2013 Wolf & Company, P.C. MEMBER OF PKF NORTH AMERICA, AN ASSOCIATION OF LEGALLY INDEPENDENT FIRMS 2013 Wolf & Company, P.C. About Wolf & Company, P.C.

More information

Compliance Challenges. Ali Pabrai, MSEE, CISSP (ISSMP, ISSAP) Member, FBI InfraGard. Increased Audits & On-site Investigations

Compliance Challenges. Ali Pabrai, MSEE, CISSP (ISSMP, ISSAP) Member, FBI InfraGard. Increased Audits & On-site Investigations Enabling a HITECH & HIPAA Compliant Organization: Addressing Meaningful Use Mandates & Ensuring Audit Readiness Ali Pabrai, MSEE, CISSP (ISSMP, ISSAP) Member, FBI InfraGard Compliance Mandates Increased

More information

FINAL May 2005. Guideline on Security Systems for Safeguarding Customer Information

FINAL May 2005. Guideline on Security Systems for Safeguarding Customer Information FINAL May 2005 Guideline on Security Systems for Safeguarding Customer Information Table of Contents 1 Introduction 1 1.1 Purpose of Guideline 1 2 Definitions 2 3 Internal Controls and Procedures 2 3.1

More information

How Much Do I Need To Do to Comply? Vice president SystemExperts Corporation

How Much Do I Need To Do to Comply? Vice president SystemExperts Corporation How Much Do I Need To Do to Comply? Richard E. Mackey, Jr. Vice president SystemExperts Corporation Agenda Background Requirements and you Risk language Risk Factors Assessing risk Program elements and

More information

Best Practices for Protecting Sensitive Data in an Oracle Applications Environment. Presented by: Jeffrey T. Hare, CPA CISA CIA

Best Practices for Protecting Sensitive Data in an Oracle Applications Environment. Presented by: Jeffrey T. Hare, CPA CISA CIA Best Practices for Protecting Sensitive Data in an Oracle Applications Environment Presented by: Jeffrey T. Hare, CPA CISA CIA Webinar Logistics Hide and unhide the Webinar control panel by clicking on

More information

REMOTE WORKING POLICY

REMOTE WORKING POLICY Reference number Approved by Information Management and Technology Board Date approved 30 April 2013 Version 1.0 Last revised Review date March 2014 Category Owner Target audience Information Assurance

More information

WHITE PAPER: FIXED-INCOME BEST EXECUTION

WHITE PAPER: FIXED-INCOME BEST EXECUTION WHITE PAPER: FIXED-INCOME BEST EXECUTION Background Among the most important of an investment adviser s fiduciary duties is the requirement that the adviser seek best execution. Best execution is not formally

More information

Third-Party Access and Management Policy

Third-Party Access and Management Policy Third-Party Access and Management Policy Version Date Change/s Author/s Approver/s Dean of Information Services 1.0 01/01/2013 Initial written policy. Kyle Johnson Executive Director for Compliance and

More information

HIPAA Security Alert

HIPAA Security Alert Shipman & Goodwin LLP HIPAA Security Alert July 2008 EXECUTIVE GUIDANCE HIPAA SECURITY COMPLIANCE How would your organization s senior management respond to CMS or OIG inquiries about health information

More information

Information Security Policy September 2009 Newman University IT Services. Information Security Policy

Information Security Policy September 2009 Newman University IT Services. Information Security Policy Contents 1. Statement 1.1 Introduction 1.2 Objectives 1.3 Scope and Policy Structure 1.4 Risk Assessment and Management 1.5 Responsibilities for Information Security 2. Compliance 3. HR Security 3.1 Terms

More information

NCUA LETTER TO CREDIT UNIONS

NCUA LETTER TO CREDIT UNIONS NCUA LETTER TO CREDIT UNIONS NATIONAL CREDIT UNION ADMINISTRATION 1775 Duke Street, Alexandria, VA DATE: August 2001 LETTER NO.: 01-CU-11 TO: SUBJ: ENCL: Federally Insured Credit Unions Electronic Data

More information

New Employee Orientation

New Employee Orientation New Employee Orientation Security Awareness August 7, 2007 Chuck Curry, Assistant Vice Chancellor for Information Security John Gale, Security Consultant Scott Robards, Security Consultant Our goal is

More information

10/29/2012 CONSUMER AFFAIRS AND BUSINESS REGULATION AND DATA SECURITY LAW

10/29/2012 CONSUMER AFFAIRS AND BUSINESS REGULATION AND DATA SECURITY LAW International Association of Privacy Professionals Practical Privacy Series New York City MASSACHUSETTS OFFICE OF CONSUMER AFFAIRS AND BUSINESS REGULATION AND DATA SECURITY LAW Barbara Anthony Undersecretary

More information

Subject: Safety and Soundness Standards for Information

Subject: Safety and Soundness Standards for Information OFHEO Director's Advisory Policy Guidance Issuance Date: December 19, 2001 Doc. #: PG-01-002 Subject: Safety and Soundness Standards for Information To: Chief Executive Officers of Fannie Mae and Freddie

More information

2011 2012 Aug. Sept. Oct. Nov. Dec. Jan. Feb. March April May-Dec.

2011 2012 Aug. Sept. Oct. Nov. Dec. Jan. Feb. March April May-Dec. The OCR Auditors are coming - Are you next? What to Expect and How to Prepare On June 10, 2011, the U.S. Department of Health and Human Services Office for Civil Rights ( OCR ) awarded KPMG a $9.2 million

More information

Service Children s Education

Service Children s Education Service Children s Education Data Handling and Security Information Security Audit Issued January 2009 2009 - An Agency of the Ministry of Defence Information Security Audit 2 Information handling and

More information

Information Technology Branch Access Control Technical Standard

Information Technology Branch Access Control Technical Standard Information Technology Branch Access Control Technical Standard Information Management, Administrative Directive A1461 Cyber Security Technical Standard # 5 November 20, 2014 Approved: Date: November 20,

More information

IT Security Procedure

IT Security Procedure IT Security Procedure 1. Purpose This Procedure outlines the process for appropriate security measures throughout the West Coast District Health Board (WCDHB) Information Systems. 2. Application This Procedure

More information

Responsible Access and Use of Information Technology Resources and Services Policy

Responsible Access and Use of Information Technology Resources and Services Policy Responsible Access and Use of Information Technology Resources and Services Policy Functional Area: Information Technology Services (IT Services) Applies To: All users and service providers of Armstrong

More information

Information Security Risk Assessment Checklist. A High-Level Tool to Assist USG Institutions with Risk Analysis

Information Security Risk Assessment Checklist. A High-Level Tool to Assist USG Institutions with Risk Analysis Information Security Risk Assessment Checklist A High-Level Tool to Assist USG Institutions with Risk Analysis Updated Oct 2008 Introduction Information security is an important issue for the University

More information

SUBJECT: SECURITY OF ELECTRONIC MEDICAL RECORDS COMPLIANCE WITH THE HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT OF 1996 (HIPAA)

SUBJECT: SECURITY OF ELECTRONIC MEDICAL RECORDS COMPLIANCE WITH THE HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT OF 1996 (HIPAA) UNIVERSITY OF PITTSBURGH POLICY SUBJECT: SECURITY OF ELECTRONIC MEDICAL RECORDS COMPLIANCE WITH THE HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT OF 1996 (HIPAA) DATE: March 18, 2005 I. SCOPE This

More information

LAMAR STATE COLLEGE - ORANGE INFORMATION RESOURCES SECURITY MANUAL. for INFORMATION RESOURCES

LAMAR STATE COLLEGE - ORANGE INFORMATION RESOURCES SECURITY MANUAL. for INFORMATION RESOURCES LAMAR STATE COLLEGE - ORANGE INFORMATION RESOURCES SECURITY MANUAL for INFORMATION RESOURCES Updated: June 2007 Information Resources Security Manual 1. Purpose of Security Manual 2. Audience 3. Acceptable

More information

Information Security Policy

Information Security Policy Information Security Policy Touro College/University ( Touro ) is committed to information security. Information security is defined as protection of data, applications, networks, and computer systems

More information

Small Business IT Risk Assessment

Small Business IT Risk Assessment Small Business IT Risk Assessment Company name: Completed by: Date: Where Do I Begin? A risk assessment is an important step in protecting your customers, employees, and your business, and well as complying

More information

Did you know your security solution can help with PCI compliance too?

Did you know your security solution can help with PCI compliance too? Did you know your security solution can help with PCI compliance too? High-profile data losses have led to increasingly complex and evolving regulations. Any organization or retailer that accepts payment

More information

Cyber Self Assessment

Cyber Self Assessment Cyber Self Assessment According to Protecting Personal Information A Guide for Business 1 a sound data security plan is built on five key principles: 1. Take stock. Know what personal information you have

More information

Ohio Supercomputer Center

Ohio Supercomputer Center Ohio Supercomputer Center Portable Security Computing No: Effective: OSC-09 05/27/09 Issued By: Kevin Wohlever Director of Supercomputer Operations Published By: Ohio Supercomputer Center Original Publication

More information

05.0 Application Development

05.0 Application Development Number 5.0 Policy Owner Information Security and Technology Policy Application Development Effective 01/01/2014 Last Revision 12/30/2013 Department of Innovation and Technology 5. Application Development

More information

PRIVACY OF CONSUMERS' FINANCIAL INFORMATION PART 12 501(b) AND BANK MANAGEMENT

PRIVACY OF CONSUMERS' FINANCIAL INFORMATION PART 12 501(b) AND BANK MANAGEMENT PRIVACY OF CONSUMERS' FINANCIAL INFORMATION PART 12 501(b) AND BANK MANAGEMENT RESOURCES PROVIDED THROUGH APRIL 2001 Slides Narration In the last presentation, you learned about some of the general responsibilities

More information

Name: Position held: Company Name: Is your organisation ISO27001 accredited:

Name: Position held: Company Name: Is your organisation ISO27001 accredited: Third Party Information Security Questionnaire This questionnaire is to be completed by the system administrator and by the third party hosting company if a separate company is used. Name: Position held:

More information

Newcastle University Information Security Procedures Version 3

Newcastle University Information Security Procedures Version 3 Newcastle University Information Security Procedures Version 3 A Information Security Procedures 2 B Business Continuity 3 C Compliance 4 D Outsourcing and Third Party Access 5 E Personnel 6 F Operations

More information

MOBILE DEVICE SECURITY POLICY

MOBILE DEVICE SECURITY POLICY State of Illinois Department of Central Management Services MOBILE DEVICE SECURITY Effective: October 01, 2009 State of Illinois Department of Central Management Services Bureau of Communication and Computer

More information

NETWORK SECURITY GUIDELINES

NETWORK SECURITY GUIDELINES NETWORK SECURITY GUIDELINES VIRUS PROTECTION STANDARDS All networked computers and networked laptop computers are protected by GST BOCES or district standard anti-virus protection software. The anti-virus

More information

DMA Information Security Management Requirements January 2012. DMA Standard: produced for the protection of electronic information.

DMA Information Security Management Requirements January 2012. DMA Standard: produced for the protection of electronic information. January 2012 DMA Standard: produced for the protection of electronic information. INTRODUCTION Information within an organisation can take many paths and can be used for many varied purposes. This data

More information

Information Security Policy and Handbook Overview. ITSS Information Security June 2015

Information Security Policy and Handbook Overview. ITSS Information Security June 2015 Information Security Policy and Handbook Overview ITSS Information Security June 2015 Information Security Policy Control Hierarchy System and Campus Information Security Policies UNT System Information

More information

P02.07.066. Mobile Device Security.

P02.07.066. Mobile Device Security. P02.07.066. Mobile Device Security. A. University employees and students using a laptop computer or mobile device (e.g. portable hard drives, USB flash drives, smartphones, tablets) are responsible for

More information

University of California, Riverside Computing and Communications. IS3 Local Campus Overview Departmental Planning Template

University of California, Riverside Computing and Communications. IS3 Local Campus Overview Departmental Planning Template University of California, Riverside Computing and Communications IS3 Local Campus Overview Departmental Planning Template Last Updated April 21 st, 2011 Table of Contents: Introduction Security Plan Administrative

More information

Approved 12/14/11. FIREWALL POLICY INTERNAL USE ONLY Page 2

Approved 12/14/11. FIREWALL POLICY INTERNAL USE ONLY Page 2 Texas Wesleyan Firewall Policy Purpose... 1 Scope... 1 Specific Requirements... 1 PURPOSE Firewalls are an essential component of the Texas Wesleyan information systems security infrastructure. Firewalls

More information

SECTION: SUBJECT: PCI-DSS General Guidelines and Procedures

SECTION: SUBJECT: PCI-DSS General Guidelines and Procedures 1. Introduction 1.1. Purpose and Background 1.2. Central Coordinator Contact 1.3. Payment Card Industry Data Security Standards (PCI-DSS) High Level Overview 2. PCI-DSS Guidelines - Division of Responsibilities

More information

Cyber Security Best Practices

Cyber Security Best Practices Cyber Security Best Practices 1. Set strong passwords; Do not share them with anyone: They should contain at least three of the five following character classes: o Lower case letters o Upper case letters

More information

Payment Card Industry Data Security Standard

Payment Card Industry Data Security Standard Payment Card Industry Data Security Standard Introduction Purpose Audience Implications Sensitive Digital Data Management In an effort to protect credit card information from unauthorized access, disclosure

More information

Sound Business Practices for Businesses to Mitigate Corporate Account Takeover

Sound Business Practices for Businesses to Mitigate Corporate Account Takeover Sound Business Practices for Businesses to Mitigate Corporate Account Takeover This white paper provides sound business practices for companies to implement to safeguard against Corporate Account Takeover.

More information

DATA SECURITY & PCI DSS COMPLIANCE PROTECTING CUSTOMER DATA

DATA SECURITY & PCI DSS COMPLIANCE PROTECTING CUSTOMER DATA DATA SECURITY & PCI DSS COMPLIANCE PROTECTING CUSTOMER DATA WHAT IS PCI DSS? PAYMENT CARD INDUSTRY DATA SECURITY STANDARD A SET OF REQUIREMENTS FOR ANY ORGANIZATION OR MERCHANT THAT ACCEPTS, TRANSMITS

More information

SAFEGUARDING PRIVACY IN A MOBILE WORKPLACE

SAFEGUARDING PRIVACY IN A MOBILE WORKPLACE SAFEGUARDING PRIVACY IN A MOBILE WORKPLACE Checklist for taking personally identifiable information (PII) out of the workplace: q Does your organization s policy permit the removal of PII from the office?

More information

HIGH-RISK SECURITY VULNERABILITIES IDENTIFIED DURING REVIEWS OF INFORMATION TECHNOLOGY GENERAL CONTROLS

HIGH-RISK SECURITY VULNERABILITIES IDENTIFIED DURING REVIEWS OF INFORMATION TECHNOLOGY GENERAL CONTROLS Department of Health and Human Services OFFICE OF INSPECTOR GENERAL HIGH-RISK SECURITY VULNERABILITIES IDENTIFIED DURING REVIEWS OF INFORMATION TECHNOLOGY GENERAL CONTROLS AT STATE MEDICAID AGENCIES Inquiries

More information

DHHS Information Technology (IT) Access Control Standard

DHHS Information Technology (IT) Access Control Standard DHHS Information Technology (IT) Access Control Standard Issue Date: October 1, 2013 Effective Date: October 1,2013 Revised Date: Number: DHHS-2013-001-B 1.0 Purpose and Objectives With the diversity of

More information

Table of Contents INTRODUCTION AND PURPOSE 1

Table of Contents INTRODUCTION AND PURPOSE 1 HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT OF 1996 ( HIPAA ) COMPLIANCE PROGRAM Adopted December 2008: Revised February 2009, May, 2012, and August 2013 Table of Contents INTRODUCTION AND PURPOSE

More information

BEFORE THE BOARD OF COUNTY COMMISSIONERS FOR MULTNOMAH COUNTY, OREGON RESOLUTION NO. 05-050

BEFORE THE BOARD OF COUNTY COMMISSIONERS FOR MULTNOMAH COUNTY, OREGON RESOLUTION NO. 05-050 BEFORE THE BOARD OF COUNTY COMMISSIONERS FOR MULTNOMAH COUNTY, OREGON RESOLUTION NO. 05-050 Adopting Multnomah County HIPAA Security Policies and Directing the Appointment of Information System Security

More information

BERKELEY COLLEGE DATA SECURITY POLICY

BERKELEY COLLEGE DATA SECURITY POLICY BERKELEY COLLEGE DATA SECURITY POLICY BERKELEY COLLEGE DATA SECURITY POLICY TABLE OF CONTENTS Chapter Title Page 1 Introduction 1 2 Definitions 2 3 General Roles and Responsibilities 4 4 Sensitive Data

More information

Patient Privacy and Security. Presented by, Jeffery Daigrepont

Patient Privacy and Security. Presented by, Jeffery Daigrepont Patient Privacy and Security Presented by, Jeffery Daigrepont Jeffery Daigrepont, SVP No Financial Conflicts to Report Jeffery Daigrepont, Senior Vice President of The Coker Group, specializes in health

More information

ONLINE BANKING SECURITY TIPS FOR OUR BUSINESS CLIENTS

ONLINE BANKING SECURITY TIPS FOR OUR BUSINESS CLIENTS $ ONLINE BANKING SECURITY TIPS FOR OUR BUSINESS CLIENTS Boston Private Bank & Trust Company takes great care to safeguard the security of your Online Banking transactions. In addition to our robust security

More information

California State Polytechnic University, Pomona. Desktop Security Standard and Guidelines

California State Polytechnic University, Pomona. Desktop Security Standard and Guidelines California State Polytechnic University, Pomona Desktop Security Standard and Guidelines Version 1.7 February 1, 2008 Table of Contents OVERVIEW...3 AUDIENCE...3 MINIMUM DESKTOP SECURITY STANDARD...3 ROLES

More information

Top Ten Technology Risks Facing Colleges and Universities

Top Ten Technology Risks Facing Colleges and Universities Top Ten Technology Risks Facing Colleges and Universities Chris Watson, MBA, CISA, CRISC Manager, Internal Audit and Risk Advisory Services cwatson@schneiderdowns.com April 23, 2012 Overview Technology

More information

Information Technology Security Procedures

Information Technology Security Procedures Information Technology Security Procedures Prepared By: Paul Athaide Date Prepared: Dec 1, 2010 Revised By: Paul Athaide Date Revised: September 20, 2012 Version 1.2 Contents 1. Policy Procedures... 3

More information

Small Firm Focus: A Practical Approach to Cybersecurity Friday, May 29 9:00 a.m. 10:15 a.m.

Small Firm Focus: A Practical Approach to Cybersecurity Friday, May 29 9:00 a.m. 10:15 a.m. Small Firm Focus: A Practical Approach to Cybersecurity Friday, May 29 9:00 a.m. 10:15 a.m. Topics: Explain why it is important for firms of all sizes to address cybersecurity risk. Demonstrate awareness

More information

BUSINESS ONLINE BANKING AGREEMENT

BUSINESS ONLINE BANKING AGREEMENT BUSINESS ONLINE BANKING AGREEMENT This Business Online Banking Agreement ("Agreement") establishes the terms and conditions for Business Online Banking Services ( Service(s) ) provided by Mechanics Bank

More information

Document No.: VCSATSP 100-100 Restricted Data Access Policy Revision: 4.0. VCSATS Policy Number: VCSATSP 100-100 Restricted Data Access Policy

Document No.: VCSATSP 100-100 Restricted Data Access Policy Revision: 4.0. VCSATS Policy Number: VCSATSP 100-100 Restricted Data Access Policy DOCUMENT INFORMATION VCSATS Policy Number: VCSATSP 100-100 Title: Restricted Data Access Policy Policy Owner: Director Technology Services Effective Date: 2/1/2014 Revision: 4.0 TABLE OF CONTENTS DOCUMENT

More information

PCI DSS Policies Outline. PCI DSS Policies. All Rights Reserved. ecfirst. 2010. Page 1 of 7 www.ecfirst.com

PCI DSS Policies Outline. PCI DSS Policies. All Rights Reserved. ecfirst. 2010. Page 1 of 7 www.ecfirst.com Policy/Procedure Description PCI DSS Policies Install and Maintain a Firewall Configuration to Protect Cardholder Data Establish Firewall and Router Configuration Standards Build a Firewall Configuration

More information

Guide to Vulnerability Management for Small Companies

Guide to Vulnerability Management for Small Companies University of Illinois at Urbana-Champaign BADM 557 Enterprise IT Governance Guide to Vulnerability Management for Small Companies Andrew Tan Table of Contents Table of Contents... 1 Abstract... 2 1. Introduction...

More information

POSTAL REGULATORY COMMISSION

POSTAL REGULATORY COMMISSION POSTAL REGULATORY COMMISSION OFFICE OF INSPECTOR GENERAL FINAL REPORT INFORMATION SECURITY MANAGEMENT AND ACCESS CONTROL POLICIES Audit Report December 17, 2010 Table of Contents INTRODUCTION... 1 Background...1

More information

micros MICROS Systems, Inc. Enterprise Information Security Policy (MEIP) August, 2013 Revision 8.0 MICROS Systems, Inc. Version 8.

micros MICROS Systems, Inc. Enterprise Information Security Policy (MEIP) August, 2013 Revision 8.0 MICROS Systems, Inc. Version 8. micros MICROS Systems, Inc. Enterprise Information Security Policy (MEIP) Revision 8.0 August, 2013 1 Table of Contents Overview /Standards: I. Information Security Policy/Standards Preface...5 I.1 Purpose....5

More information

Tenth Judicial Circuit of Florida Information Systems Acceptable Use Guidelines Polk, Hardee and Highlands Counties as of January 2014

Tenth Judicial Circuit of Florida Information Systems Acceptable Use Guidelines Polk, Hardee and Highlands Counties as of January 2014 Tenth Judicial Circuit of Florida Information Systems Acceptable Use s Polk, Hardee and Highlands Counties as of January 2014 The following guidelines define the acceptable use of information technology

More information

Section 5 Identify Theft Red Flags and Address Discrepancy Procedures Index

Section 5 Identify Theft Red Flags and Address Discrepancy Procedures Index Index Section 5.1 Purpose.... 2 Section 5.2 Definitions........2 Section 5.3 Validation Information.....2 Section 5.4 Procedures for Opening New Accounts....3 Section 5.5 Procedures for Existing Accounts...

More information

OSU INSTITUTE OF TECHNOLOGY POLICY & PROCEDURES

OSU INSTITUTE OF TECHNOLOGY POLICY & PROCEDURES Network Security 6-005 INFORMATION TECHNOLOGIES July 2013 INTRODUCTION 1.01 OSU Institute of Technology (OSUIT) s network exists to facilitate the education, research, administration, communication, and

More information

PCI Training for Retail Jamboree Staff Volunteers. Securing Cardholder Data

PCI Training for Retail Jamboree Staff Volunteers. Securing Cardholder Data PCI Training for Retail Jamboree Staff Volunteers Securing Cardholder Data Securing Cardholder Data Introduction This PowerPoint presentation is designed to educate Retail Jamboree Staff volunteers on

More information

Guidance for Data Users on the Collection and Use of Personal Data through the Internet 1

Guidance for Data Users on the Collection and Use of Personal Data through the Internet 1 Guidance for Data Users on the Collection and Use of Personal Data through the Internet Introduction Operating online businesses or services, whether by commercial enterprises, non-government organisations

More information

HIPAA SECURITY RISK ASSESSMENT SMALL PHYSICIAN PRACTICE

HIPAA SECURITY RISK ASSESSMENT SMALL PHYSICIAN PRACTICE HIPAA SECURITY RISK ASSESSMENT SMALL PHYSICIAN PRACTICE How to Use this Assessment The following risk assessment provides you with a series of questions to help you prioritize the development and implementation

More information