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Identity Theft - Business Guide For
Protecting Personal Information:

Elements of A
Sound Data Security Plan:
Most companies keep sensitive personal information in their
files; names, Social Security numbers, credit card, or other
account data that identifies customers or employees.
This information often is necessary to fill orders, meet
payroll, or perform other necessary business functions. However,
if sensitive data falls into the wrong hands, it can lead
to fraud, identity theft, or similar harms. Given the cost
of a security breach; losing your customers trust and perhaps
even defending yourself against a lawsuit, safeguarding personal
information is just plain good business.
A sound data security plan is built on 5 key principles:
- Take stock. Know what personal information you
have in your files and on your computers.
- Scale down. Keep only what you need for your business.
- Lock it. Protect the information that you keep.
- Pitch it. Properly dispose of what you no longer
need.
- Plan ahead. Create a plan to respond to security
incidents.
Use the following checklists to see how your company's practices
measure up and where changes are necessary.
Review Symantec internet
security products.
Review ZoneAlarm internet
security products.
Free
Internet Security documents to help you start and manage your
business!
Data Security Plan Principle #1 - Take Stock:
Know what personal information you have in your files
and on your computers.
Effective data security starts with assessing what information
you have and identifying who has access to it. Understanding
how personal information moves into, through, and out of your
business and who has or could have access to it is essential
to assessing security vulnerabilities. You can determine the
best ways to secure the information only after you've traced
how it flows.
- Inventory all computers, laptops, flash drives, disks,
home computers, and other equipment to find out where your
company stores sensitive data. Also inventory the information
you have by type and location. Your file cabinets and computer
systems are a start, but remember: your business receives
personal information in a number of ways through websites,
from contractors, from call centers, and the like. What
about information saved on laptops, employees home computers,
flash drives, and cell phones? No inventory is complete
until you check everywhere sensitive data might be stored.
- Track personal information through your business by talking
with your sales department, information technology staff,
human resources office, accounting personnel, and outside
service providers. Get a complete picture of:
- Who sends sensitive personal information to your
business. Do you get it from customers? Credit card
companies? Banks or other financial institutions? Credit
bureaus? Other businesses?
- How your business receives personal information.
Does it come to your business through a website? By
email? Through the mail? Is it transmitted through cash
registers in stores?
- What kind of information you collect at each entry
point. Do you get credit card information online?
Does your accounting department keep information about
customers checking accounts?
- Where you keep the information you collect at
each entry point. Is it in a central computer database?
On individual laptops? On disks or tapes? In file cabinets?
In branch offices? Do employees have files at home?
- Who has or could have access to the information.
Which of your employees has permission to access
the information? Could anyone else get a hold of it?
What about vendors who supply and update software you
use to process credit card transactions? Contractors
operating your call center?
- Different types of information present varying risks.
Pay particular attention to how you keep personally identifying
information: Social Security numbers, credit card or financial
information, and other sensitive data. That's what thieves
use most often to commit fraud or identity theft.
Security Check Question: Are there laws that require
my company to keep sensitive data secure?
Answer: Yes. While you're taking stock of the data
in your files, take stock of the law, too. Statutes like the
Gramm-Leach-Bliley Act, the Fair Credit Reporting Act, and
the Federal Trade Commission Act may require you to provide
reasonable security for sensitive information.
To find out more, visit Federal
Trade Commission.
Data
Security Plan Principle #2 - Scale Down:
Keep only what you need for your business.
If you don't have a legitimate business need for sensitive
personally identifying information, don't keep it. In fact,
don't even collect it. If you have a legitimate business need
for the information, keep it only as long as its necessary.
- Use Social Security numbers only for required and lawful
purposes like reporting employee taxes. Don't use Social
Security numbers unnecessarily for example, as an employee
or customer identification number, or because you've always
done it.
- Don't keep customer credit card information unless you
have a business need for it. For example, don't retain the
account number and expiration date unless you have an essential
business need to do so. Keeping this information or keeping
it longer than necessary raises the risk that the information
could be used to commit fraud or identity theft.
- Check the default settings on your software that reads
customers credit card numbers and processes the transactions.
Sometimes its preset to keep information permanently. Change
the default setting to make sure you're not inadvertently
keeping information you don't need.
- If you must keep information for business reasons or to
comply with the law, develop a written records retention
policy to identify what information must be kept, how to
secure it, how long to keep it, and how to dispose of it
securely when you no longer need it.
Security Check Question: We like to have accurate
information about our customers, so we usually create a permanent
file about all aspects of their transactions, including the
information we collected from the magnetic stripe on their
credit cards. Could this practice put their information at
risk?
Answer: Yes. Keep sensitive data in your system only
as long as you have a business reason to have it. Once that
business need is over, properly dispose of it. If its not
in your system, it cant be stolen by hackers. Its as simple
as that.
Data
Security Plan Principle #3 - Lock It:
Protect the information that you keep.
What's the best way to protect the sensitive personally identifying
information you need to keep? It depends on the kind of information
and how its stored. The most effective data security plans
deal with four key elements: physical security, electronic
security, employee training, and the security practices of
contractors and service providers.
Key Element #1 - Physical Security
Many data compromises happen the old-fashioned way through
lost or stolen paper documents. Often, the best defense is
a locked door or an alert employee.
- Store paper documents or files, as well as CDs, floppy
disks, zip drives, tapes, and backups containing personally
identifiable information in a locked room or in a locked
file cabinet. Limit access to employees with a legitimate
business need. Control who has a key, and the number of
keys.
- Require that files containing personally identifiable
information be kept in locked file cabinets except when
an employee is working on the file. Remind employees not
to leave sensitive papers out on their desks when they are
away from their workstations.
- Require 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.
Tell employees what to do and whom to call if they see an
unfamiliar person on the premises.
- If you maintain offsite storage facilities, limit employee
access to those with a legitimate business need. Know if
and when someone accesses the storage site.
Key Element #2 - Electronic Security
Computer security isn't just the realm of your IT staff.
Make it your business to understand the vulnerabilities of
your computer system, and follow the advice of experts in
the field.
General Network Security
- Identify the computers or servers where sensitive personal
information is stored.
- Identify all connections to the computers where you store
sensitive information. These may include the Internet, electronic
cash registers, computers at your branch offices, computers
used by service providers to support your network, and wireless
devices like inventory scanners or cell phones.
- Assess the vulnerability of each connection to commonly
known or reasonably foreseeable attacks. Depending on your
circumstances, appropriate assessments may range from having
a knowledgeable employee run off-the-shelf security software
to having an independent professional conduct a full-scale
security audit.
- Don't store sensitive consumer data on any computer with
an Internet connection unless its essential for conducting
your business.
- Encrypt sensitive information that you send to third parties
over public networks (like the Internet), and consider encrypting
sensitive information that is stored on your computer network
or on disks or portable storage devices used by your employees.
Consider also encrypting email transmissions within your
business if they contain personally identifying information.
- Regularly run up-to-date anti-virus and anti-spyware
programs on individual computers and on servers on your
network.
- Check expert websites (such as www.sans.org) and your
software vendors websites regularly for alerts about new
vulnerabilities, and implement policies for installing vendor-approved
patches to correct problems.
- Scan computers on your network to identify and profile
the operating system and open network services. If you find
services that you don't need, disable them to prevent hacks
or other potential security problems. For example, if email
service or an Internet connection is not necessary on a
certain computer, consider closing the ports to those services
on that computer to prevent unauthorized access to that
machine.
- When you receive or transmit credit card information
or other sensitive financial data, use Secure Sockets Layer
(SSL) or another secure connection that protects the information
in transit.
- Pay particular attention to the security of your web applications
the software used to give information to visitors to your
website and to retrieve information from them. Web applications
may be particularly vulnerable to a variety of hack attacks.
In one variation called an injection attack, a hacker inserts
malicious commands into what looks like a legitimate request
for information. Once in your system, hackers transfer sensitive
information from your network to their computers. Relatively
simple defenses against these attacks are available from
a variety of sources.
Security Check Question: We encrypt financial data
customers submit on our website. But once we receive it, we
decrypt it and email it over the Internet to our branch offices
in regular text. Is there a safer practice?
Answer: Yes. Regular email is not a secure method
for sending sensitive data. The better practice is to encrypt
any transmission that contains information that could be used
by fraudsters or ID thieves.
Password Management
- Control access to sensitive information by requiring that
employees use strong passwords. Tech security experts say
the longer the password, the better. Because simple passwords
like common dictionary words can be guessed easily, insist
that employees choose passwords with a mix of letters, numbers,
and characters. Require an employees user name and password
to be different, and require frequent changes in passwords.
- Explain to employees why its against company policy to
share their passwords or post them near their workstations.
- Use password-activated screen savers to lock employee
computers after a period of inactivity.
- Lock out users who don't enter the correct password within
a designated number of log-on attempts.
- Warn employees about possible calls from identity thieves
attempting to deceive them into giving out their passwords
by impersonating members of your IT staff. Let employees
know that calls like this are always fraudulent, and that
no one should be asking them to reveal their passwords.
- When installing new software, immediately change vendor-supplied
default passwords to a more secure strong password.
- Caution employees against transmitting sensitive personally
identifying data Social Security numbers, passwords, account
information via email. Unencrypted email is not a secure
way to transmit any information.
Security Check Question: Our account staff needs access
to our database of customer financial information. To make
it easier to remember, we just use our company name as the
password. Could that create a security problem?
Answer: Yes. Hackers will first try words like password,
your company name, the software's default password, and other
easy-to-guess choices. They'll also use programs that run
through common English words and dates. To make it harder
for them to crack your system, select strong passwords, the
longer, the better that use a combination of letters, symbols,
and numbers. And change passwords often.
Laptop Security
- Restrict the use of laptops to those employees who need
them to perform their jobs.
- Assess whether sensitive information really needs to
be stored on a laptop. If not, delete it with a wiping program
that overwrites data on the laptop. Deleting files using
standard keyboard commands isn't sufficient because data
may remain on the laptops hard drive. Wiping programs are
available at most office supply stores.
- Require employees to store laptops in a secure place.
Even when laptops are in use, consider using cords and locks
to secure laptops to employees desks.
- Consider allowing laptop users only to access sensitive
information, but not to store the information on their laptops.
Under this approach, the information is stored on a secure
central computer and the laptops function as terminals that
display information from the central computer, but do not
store it. The information could be further protected by
requiring the use of a token, smart card, thumb print, or
other biometric as well as a password to access the central
computer.
- If a laptop contains sensitive data, encrypt it and configure
it so users cant download any software or change the security
settings without approval from your IT specialists. Consider
adding an auto-destroy function so that data on a computer
that is reported stolen will be destroyed when the thief
uses it to try to get on the Internet.
- Train employees to be mindful of security when they're
on the road. They should never leave a laptop visible in
a car, at a hotel luggage stand, or packed in checked luggage
unless directed to by airport security. If someone must
leave a laptop in a car, it should be locked in a trunk.
Everyone who goes through airport security should keep an
eye on their laptop as it goes on the belt.
Firewalls
- Use a firewall to protect your computer from hacker attacks
while it is connected to the Internet. A firewall is software
or hardware designed to block hackers from accessing your
computer. A properly configured firewall makes it tougher
for hackers to locate your computer and get into your programs
and files.
- Determine whether you should install a border firewall
where your network connects to the Internet. A border firewall
separates your network from the Internet and may prevent
an attacker from gaining access to a computer on the network
where you store sensitive information. Set access controls
settings that determine who gets through the firewall and
what they will be allowed to see to allow only trusted employees
with a legitimate business need to access the network. Since
the protection a firewall provides is only as effective
as its access controls, review them periodically.
- If some computers on your network store sensitive information
while others do not, consider using additional firewalls
to protect the computers with sensitive information.
Wireless and Remote Access
- Determine if you use wireless devices like inventory scanners
or cell phones to connect to your computer network or to
transmit sensitive information.
- If you do, consider limiting who can use a wireless connection
to access your computer network. You can make it harder
for an intruder to access the network by limiting the wireless
devices that can connect to your network.
- Better still, consider encryption to make it more difficult
for an intruder to read the content. Encrypting transmissions
from wireless devices to your computer network may prevent
an intruder from gaining access through a process called
spoofing impersonating one of your computers to get access
to your network.
- Consider using encryption if you allow remote access
to your computer network by employees or by service providers,
such as companies that troubleshoot and update software
you use to process credit card purchases.
Detecting Breaches
- To detect network breaches when they occur, consider using
an intrusion detection system. To be effective, it must
be updated frequently to address new types of hacking.
- Maintain central log files of security-related information
to monitor activity on your network so that you can spot
and respond to attacks. If there is an attack on your network,
the log will provide information that can identify the computers
that have been compromised.
- Monitor incoming traffic for signs that someone is trying
to hack in. Keep an eye out for activity from new users,
multiple log-in attempts from unknown users or computers,
and higher-than-average traffic at unusual times of the
day.
- Monitor outgoing traffic for signs of a data breach.
Watch for unexpectedly large amounts of data being transmitted
from your system to an unknown user. If large amounts of
information are being transmitted from your network, investigate
to make sure the transmission is authorized.
- Have in place and implement a breach response plan.
Key Element #3 - Employee Training
Your data security plan may look great on paper, but its
only as strong as the employees who implement it. Take time
to explain the rules to your staff, and train them to spot
security vulnerabilities. Periodic training emphasizes the
importance you place on meaningful data security practices.
A well-trained workforce is the best defense against identity
theft and data breaches.
- Check references or do background checks before hiring
employees who will have access to sensitive data.
- Ask every new employee to sign an agreement to follow
your company's confidentiality and security standards for
handling sensitive data. Make sure they understand that
abiding by your company's data security plan is an essential
part of their duties. Regularly remind employees of your
company's policy and any legal requirement to keep customer
information secure and confidential.
- Know which employees have access to consumers sensitive
personally identifying information. Pay particular attention
to data like Social Security numbers and account numbers.
Limit access to personal information to employees with a
need to know.
- Have a procedure in place for making sure that workers
who leave your employ or transfer to another part of the
company no longer have access to sensitive information.
Terminate their passwords, and collect keys and identification
cards as part of the check-out routine.
- Create a culture of security by implementing a regular
schedule of employee training. Update employees as you find
out about new risks and vulnerabilities. Make sure training
includes employees at satellite offices, temporary help,
and seasonal workers. If employees don't attend, consider
blocking their access to the network.
- Train employees to recognize security threats. Tell them
how to report suspicious activity and publicly reward employees
who alert you to vulnerabilities.
- Tell employees about your company policies regarding keeping
information secure and confidential. Post reminders in areas
where sensitive information is used or stored, as well as
where employees congregate. Make sure your policies cover
employees who telecommute or access sensitive data from
home or an offsite location.
- Warn employees about phone phishing.
Train them to be suspicious of unknown callers claiming
to need account numbers to process an order or asking for
customer or employee contact information. Make it office
policy to double-check by contacting the company using a
phone number you know is genuine.
- Require employees to notify you immediately if there
is a potential security breach, such as a lost or stolen
laptop.
- Impose disciplinary measures for security policy violations.
- For computer security tips, tutorials, and quizzes for
everyone on your staff, visit OnGuardOnline.gov.
OnGuardOnline.gov provides practical tips from the
federal government and the technology industry to help you
be on guard against Internet fraud, secure your computer,
and protect your personal information.
Security Check Question: I'm not really a tech type.
Are there steps our computer people can take to protect our
system from common hack attacks?
Answer: Yes. There are relatively simple fixes to
protect your computers from some of the most common vulnerabilities.
For example, a threat called an SQL injection attack can give
fraudsters access to sensitive data on your system, but can
be thwarted with a simple change to your computer. Bookmark
the websites of groups like the Open Web Application Security
Project, www.owasp.org, or SANS (SysAdmin, Audit, Network,
Security) Institutes Twenty Most Critical Internet Security
Vulnerabilities, www.sans.org/top20, for up-to-date information
on the latest threats and fixes. And check with your software
vendors for patches that address new vulnerabilities.
Key Element #4 - Security practices of contractors and service
providers
Your company's security practices depend on the people who
implement them, including contractors and service providers.
- Before you outsource any of your business functions payroll,
web hosting, customer call center operations, data processing,
or the like, investigate the company's data security practices
and compare their standards to yours. If possible, visit
their facilities.
- Address security issues for the type of data your service
providers handle in your contract with them.
- Insist that your service providers notify you of any
security incidents they experience, even if the incidents
may not have led to an actual compromise of your data.

Data Security Plan Principle #4 - Pitch It:
Properly dispose of what you no longer need.
What looks like a sack of trash to you can be a gold mine
for an identity thief. Leaving credit card receipts or papers
or CDs with personally identifying information in a dumpster
facilitates fraud and exposes consumers to the risk of identity
theft. By properly disposing of sensitive information, you
ensure that it cannot be read or reconstructed.
- Implement information disposal practices that are reasonable
and appropriate to prevent unauthorized access to or use
of personally identifying information. Reasonable measures
for your operation are based on the sensitivity of the information,
the costs and benefits of different disposal methods, and
changes in technology.
- Effectively dispose of paper records by shredding, burning,
or pulverizing them before discarding. Make shredders available
throughout the workplace, including next to the photocopier.
- When disposing of old computers and portable storage
devices, use wipe utility programs. They're inexpensive
and can provide better results by overwriting the entire
hard drive so that the files are no longer recoverable.
Deleting files using the keyboard or mouse commands usually
isn't sufficient because the files may continue to exist
on the computers hard drive and could be retrieved easily.
- Make sure employees who work from home follow the same
procedures for disposing of sensitive documents and old
computers and portable storage devices.
- If you use consumer credit reports for a business purpose,
you may be subject to the FTCs Disposal Rule. For more information,
see Disposing of Consumer Report Information? New Rule Tells
How at Federal
Trade Commission.
Security Check Question: My company collects credit
applications from customers. The form requires them to give
us lots of financial information. Once were finished with
the applications, were careful to throw them away. Is that
sufficient?
Answer: No. Have a policy in place to ensure that
sensitive paperwork is unreadable before you throw it away.
Burn it, shred it, or pulverize it to make sure identity thieves
cant steal it from your trash.
Data Security Plan Principle #5 - Plan Ahead:
Create a plan for responding to security incidents.
Taking steps to protect data in your possession can go a
long way toward preventing a security breach. Nevertheless,
breaches can happen. Here's how you can reduce the impact
on your business, your employees, and your customers:
- Have a plan in place to respond to security incidents.
Designate a senior member of your staff to coordinate and
implement the response plan.
- If a computer is compromised, disconnect it immediately
from the Internet.
- Investigate security incidents immediately and take steps
to close off existing vulnerabilities or threats to personal
information.
- Consider whom to notify in the event of an incident,
both inside and outside your organization. You may need
to notify consumers, law enforcement, customers, credit
bureaus, and other businesses that may be affected by the
breach. In addition, many states and the federal bank regulatory
agencies have laws or guidelines addressing data breaches.
Consult your attorney.
Security Check Question: I own a small business. Aren't
these precautions going to cost me a mint to implement?
Answer: No. There's no one-size-fits-all approach
to data security, and what's right for you depends on the
nature of your business and the kind of information you collect
from your customers. Some of the most effective security measures
using strong passwords, locking up sensitive paperwork, training
your staff, etc. will cost you next to nothing and you'll
find free or low-cost security tools at nonprofit websites
dedicated to data security. Furthermore, its cheaper in the
long run to invest in better data security than to lose the
goodwill of your customers, defend yourself in legal actions,
and face other possible consequences of a data breach.

Additional Resources
These websites and publications have more information on
securing sensitive data:
Review Symantec internet
security products.
Review ZoneAlarm internet
security products.
Free
Internet Security documents to help you start and manage your
business!
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