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Recommended Practices 1. Create a culture of security at 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. 2. Put into place 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.

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3. Manage user permissions to give customer information access only to those employees and service providers having a legitimate business need. 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 regularly to monitor patterns of irregular activity by users. Set your system to prevent downloading or file transfers of customer information to computers, USB memory sticks, PDAs, cell phones, tablets, or other remote devices, and disable PC PSTs. If you have a credit application on your website, make sure it is encrypted and begin safeguarding and tracking access to it from the time it is completed by the consumer and securely transmitted to your dealership. Keep your antivirus, anti-malware, and firewall software up to date. If you permit employees to use their own devices to access dealership information, do a risk assessment of BYOD issues and see if it is

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