GNYADA 2019 Membership Directory & Services Guide

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.

2019 membership directory & services guide / hot topics PG 141 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 3. Manage user permissions to give customer information access only to those employees and service providers having a legitimate business

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 feasible for your dealership to implement a policy to enable employees to use personal devices. If so, employ MDMS software to manage the devices. If not feasible, cease their ability to do so and require that only company-issued devices be used to access dealer databases and information. 4. Have an acceptable use policy. Help control risk by adopting an “acceptable use”policy that ensures employees are not sharing their device, are adhering to strong passwords, and that any corporate-owned data is encrypted. Text messaging should also be discouraged as it is discoverable from the device in litigation and the use of acronyms or shorthand often leads to misunderstandings.

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