FIVE STEPS TO COMPLIANCE
by: Michael Hall, Chief Information Security Officer
Despite different industries being required to follow differently named guidelines, there’s a pretty good overlap for those information security items that IT really needs to worry about.
Although there will be some personal information that may not fall under any compliance standards, from an IT perspective, it’s safe to assume that any and all customer, employee or other personal information needs to be protected from breach, accidental exposure or other cybersecurity transgression.
In order to obtain and maintain compliance to any industry or government mandated information security protocol, you must have documented and validated data security policies and procedures that are in use by your company.
The steps you need to follow as IT regarding cybersecurity policies and procedures are fairly standard, regardless of the industry you serve:
Risk analysis
Development of policies and procedures
Implementation
Validation
Enforcement
Data Security Compliance: A Cheat Sheet for IT
1. Risk Analysis
Risk analysis, sometimes also called gap analysis or security risk assessment, is the first step toward developing a data security policy. Security risk assessments should be conducted annually, biannually or any time something changes, such as the purchase of new equipment or expansion of company services.
The purpose of risk analysis is to understand the existing system and identify gaps in policy and potential security risks. As explained by the SANS Institute, the process should work to answer the following questions:
What needs to be protected?
Who/What are the threats and vulnerabilities?
What are the implications if they were damaged or lost?
What is the value to the organization?
What can be done to minimize exposure to the loss or damage?
Areas to review for proper security:
Workstation and server configurations
Physical security
Network infrastructure administration
System access controls
Data classification and management
Application development and maintenance
Existing and potential threats
Methods of security to review:
Access and authentication: access should be physically unavailable to anyone who is not authorized
User account management
Network security
Monitoring
Segregation of duties
Physical security
Employee background checks
Confidentiality agreements
Security training
This document from SANS Institute gives excellent instruction for conducting a thorough risk analysis for your company.
2. Development of Policies and Procedures
Based on the outcome of the risk analysis conducted, information security policies and procedures for safeguarding data must be updated or, if none currently exist, written from scratch.
Identify, develop and document:
A comprehensive plan outlining data security and cybersecurity policies
Individual staff responsibilities for maintaining data security
Tools to be used to minimize data security risks, such as security cameras, firewalls or security software
Cybersecurity guidelines concerning use of internet, intranet and extranet systems
3. Implementation
Once your company information security policies and procedures have been identified, planned out and documented, they need to be implemented and followed.
Purchase security software and other tools that have been identified as necessary
Update existing software and operating systems that are out-of-date
Conduct mandatory security training and awareness programs for all employees, and require signatures on mandatory reading materials
Conduct background checks of all employees
Vet third-party providers to be sure that they maintain and document compliant information security protocols identical to or more robust than those in place within your company
4. Validation
In order to prove that your company is compliant with industry regulations, you must have a third-party data security company validate your company’s security protocols, procedures and the implementation of those policies and procedures. This should be done annually or biannually.
This process can be pricey, time-consuming and intrusive; however, this type of verification will both help your business to maintain data security, and add value to your services for use by your customers.
A SSAE18 SOC 2 Type II security protocol can cover a large spectrum of industry regulated data security requirements, including all of those discussed in this article:
HIPAA
GLBA
SOX
FERPA
FISMA
NIST
5. Enforcement
Information security policies and procedures can be enforced through education and penalties.
You may have noticed that education falls under both implementation and enforcement. This is absolutely the most important part of your company information security and must be offered continuously. Mandatory data security training and awareness programs must be scheduled for employees to ensure sensitive and confidential data is protected. Be sure that anybody who might touch protected data is trained on current policies and risks, and kept current as policies are updated or new risks identified.
For example, be sure that all relevant employees are aware of cybersecurity threats such as email phishing scams, how to identify them, what to do if somebody thinks they may be targeted and what to do if they have become a victim, possibly exposing protected data. As new types of scams come into being, send company-wide emails detailing methods of identification and protection.
The second part of enforcement is eliminating the temptation to ignore data security protocols and encouraging compliance. This can be done by issuing penalties, financial or otherwise, for those who do not follow important procedures.
THERE YOU GO—SIMPLE!
Okay, maybe it’s not exactly simple. But, if you want to avoid adding your business or your clients to the data breach stats, data security measures must be thorough. Industry compliance and overall data security will help maintain the safety of your organization’s data, and add a great selling point when pursuing clients.
FURTHER READING
Interested in knowing more about security at DriveSavers? Check out these links.
Cybersecurity Report: The Overlooked Risk in Third-party Data Recovery
Why is Data Security Important During Data Recovery?
Audited and Certified: SSAE 18 SOC 2 Type II
HIPAA Security Compliance
Video: DriveSavers Security During Data Recovery
