201 CMR 17.00 Written Information Security Program (WISP)
Massachusetts state law, formally known as 201 CMR 17.00, was put in place to safeguard the personal information of Massachusetts residents. This regulation establishes minimum standards to be met in connection with the safeguarding of personal information contained in both paper and electronic records.
The provisions of this regulation apply to all persons that own or license personal information about a resident of the Commonwealth.
The objectives of this regulation are to ensure the security and confidentiality of customer information in a manner fully consistent with industry standards; protect against anticipated threats or hazards to the security or integrity of such information, and protect against unauthorized access to or use of such information that may result in substantial harm or inconvenience to any consumer.
aNetworks, Inc. provides customized WISPs that comply with 201 CMR 17.00. This is a comprehensive, editable, easily implemented document that contains the policies, control objectives, standards, and guidelines your company needs to secure data and meet MA compliance requirements.
Our 201 CMR 17.00 WISP is designed to achieve the following best practices set forth by Massachusetts State Law:
- Every person that owns or licenses personal information about a resident of the Commonwealth shall develop, implement, and maintain a comprehensive written information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to the size, scope, and type of business of the person obligated to safeguard the personal information.
- Designating one or more employees to maintain the comprehensive written information security program.
- Identifying and assessing reasonably foreseeable internal and external risks to the security, confidentiality, and/or integrity of any electronic, paper, or other records containing personal information, and evaluating and improving, where necessary, the effectiveness of the current safeguards for limiting such risks.
- Ongoing employee (including temporary and contract employee) training.
- Employee compliance with policies and procedures; and means for detecting and preventing security system failures.
- Developing security policies for employees relating to the storage, access, and transportation of records containing personal information outside of business premises.
- Imposing disciplinary measures for violations of the comprehensive information security program rules.
- Preventing terminated employees from accessing records containing personal information.
- Oversee service providers, by taking reasonable steps to select and retain third-party service providers that are capable of maintaining appropriate security measures to protect such personal information consistent with these regulations and any applicable federal regulations.
- Requiring such third-party service providers by contract to implement and maintain such appropriate security measures for personal information.
- Reasonable restrictions upon physical access to records containing personal information, and storage of such records and data in locked facilities, storage areas, or containers.
- Regular monitoring to ensure that the comprehensive information security program is operating in a manner reasonably calculated to prevent unauthorized access to or unauthorized use of personal information, and upgrading information safeguards as necessary to limit risks.
- Reviewing the scope of the security measures at least annually or whenever there is a material change in business practices that may reasonably implicate the security or integrity of records containing personal information.
- Documenting responsive actions taken in connection with any incident involving a breach of security, and mandatory post-incident review of events and actions taken, if any, to make changes in business practices relating to the protection of personal information.
Furthermore, our 201 CMR 17.00 WISP is designed to comply with the following computer system security requirements:
Every person that owns or licenses personal information about a resident of the Commonwealth and electronically stores or transmits such information shall include in its written, comprehensive information security program the establishment and maintenance of a security system covering its computers, including any wireless system, that, at a minimum, and to the extent technically feasible, shall have the following elements:
- Secure user authentication protocols including control of user IDs and other identifiers.
- A reasonably secure method of assigning and selecting passwords, or use of unique identifier technologies, such as biometrics or token devices.
- Control of data security passwords to ensure that such passwords are kept in a location and/or format that does not compromise the security of the data they protect.
- Restricting access to active users and active user accounts only.
- Blocking access to user identification after multiple unsuccessful attempts to gain access or the limitation placed on access for the particular system.
- Secure access control measures that restrict access to records and files containing personal information to those who need such information to perform their job duties.
- Assign unique identifications plus passwords, which are not vendor-supplied default passwords, to each person with computer access, that are reasonably designed to maintain the
the integrity of the security of the access controls.
- Encryption of all transmitted records and files containing personal information that will travel across public networks, and encryption of all data containing personal information to be transmitted wirelessly.
- Reasonable monitoring of systems, for unauthorized use of or access to personal information.
- Encryption of all personal information stored on laptops or other portable devices.
- For files containing personal information on a system that is connected to the Internet, there must be reasonably up-to-date firewall protection and operating system security patches, reasonably designed to maintain the integrity of the personal information.
- Reasonably up-to-date versions of system security agent software which must include malware protection and reasonably up-to-date patches and virus definitions, or a version of such software that can still be supported with up-to-date patches and virus definitions, and is set to receive the most current security updates on a regular basis.
- Education and training of employees on the proper use of the computer security system and the importance of personal information security.
Apart from our WISP being completely customizable, it’s a fraction of the cost of writing one yourself or hiring an outside consultant to write one for you and it covers each of the policies and standards set forth by 201 CMR 17.00.
Benefits of a 201 CMR 17.00 WISP:
- Decreased costs – less reactive IT support
- Compliance coverage
- Improved productivity – decreased distractions
- Less virus & malware outbreaks – decreased downtime & expense
- More efficient operations – better performing network & computers
- Increased accountability of assets & resources
- Educated & trained employees
- Proper documentation to remove liability