2016 GNYADA Membership Directory

i. Put procedures in place to keep your security current and address vulnerabilities that may arise – Have a detailed security incident response program included in your Safeguards policy. Update your security software and procedures on a regular basis. j. Secure paper, physical media, and devices – Prevent NPI from being downloaded or copied onto remote devices like USBs or external hard drives. View-only access to NPI on a segregated server is a best practice. Create a culture of security in your dealership and get senior management buy-in. Limit permissions to access customer information to only those persons who need access to perform their jobs; require passwords to contain letters, symbols and numbers and be changed frequently. Know the flow of information that enters your system and monitor for any unusual data flows in or out. These may be signs that a hacker has entered your system and is compromising security. Keep logs of who accesses customer information and when they do so for both electronic and paper files. Train your employees on the importance of safeguarding customer information. Do not leave credit apps or credit reports out in the open or in unsecured file drawers. Consider using processes that can determine if your employees are actually following the policies and procedures in your Information Security Program. Regularly review access logs of the consumer information records and follow up promptly if you see any unusual spikes in any employee or other user accessing customer files. Lock down files at night and on weekends and implement a “clean desk” policy that requires all paper documents containing customer information to be locked up when not in use. The FTC fined a dealer in Georgia $30,000 for having documents containing customer information located in plain sight on a salesperson’s desk. Create an Information Security Program that details how you safeguard and securely dispose of all your consumer information. Include a detailed data security incident and security breach response plan in the Information Security Program. Follow FTC guidelines for Information Security Programs and know your state’s law on use, communication and display of Social Security numbers and consumer notification requirements in the event of a data breach. Avoid storing consumer information longer than is necessary or allowing access using widely-known simple passwords. Make sure your dealership’s Information Security Program includes detailed provisions for the secure disposal of consumer information, both paper and electronic. Train and re-train employees, perform stress tests to evaluate your systems regularly and update provisions as required. Destroy hard drives and flash drives on computers, copiers, fax machines and wireless devices using industry standard procedures before discarding them or trading them in for replacements. Disable USB flash memory drives. Try to store customer information only in secure central servers and preclude the ability to download it. Some states (for example, Massachusetts) require that customer information contained on laptops, tablets, cell phones and other remote devices must be encrypted. Massachusetts and Nevada also require personal information about residents be encrypted in transmissions, which is a best practice in any event and required for credit card data transmission. Manage user permissions to give customer information access only to those employees and service providers having a legitimate business need and give them only the permissions they need. More than half of all identity theft originates in the workplace according to a recent study. In addition to negligently making customer information available for theft by outsiders, employees can and do steal customer information and sell it to identity thieves. So it is critical that you keep event access logs of those persons who access your customer information in both paper and electronic files. Review the access logs

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