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MA 201 CMR 17.00 (1) Every person that owns or licenses personal information about a resident of the Commonwealth shall develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to (a) the size, scope and type of business of the person obligated to safeguard the personal information under such comprehensive information security program; (b) the amount of resources available to such person; (c) the amount of stored data; and (d) the need for security and confidentiality of both consumer and employee information. The safeguards contained in such program must be consistent with the safeguards for protection of personal information and information of a similar character set forth in any state or federal regulations by which the person who owns or licenses such information may be regulated.
(2) (a) Designating one or more employees to maintain the comprehensive information security program; ✓MA 201 CMR 17.00 requirement covered by WISP in the Information Assurance (IA) Policy and Appendix I (ISO Appointment Orders)
(2)(b) 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, including but not limited to: ✓MA 201 CMR 17.00 requirement covered by WISP in the Information Assurance (IA) Policy
(2)(b)(1) ongoing employee (including temporary and contract employee) training; ✓MA 201 CMR 17.00 requirement covered by WISP in the User Security Training Policy
(2)(b)(2) employee compliance with policies and procedures; and ✓MA 201 CMR 17.00 requirement covered by WISP in the Acceptable Use Policy and Appendix B (User Policy Acknowledgment Form)
(2)(b)(3)means for detecting and preventing security system failures. ✓MA 201 CMR 17.00 requirement covered by WISP in the Information Security Management System, Risk Assessment and Vulnerability Assessment Policies
(2)(c) Developing security policies for employees relating to the storage, access and transportation of records containing personal information outside of business premises. ✓MA 201 CMR 17.00 requirement covered by WISP in the Data Classification Policy
(2)(d) Imposing disciplinary measures for violations of the comprehensive information security program rules. ✓MA 201 CMR 17.00 requirement covered by WISP in the Acceptable Use Policy and Appendix B (User Policy Acknowledgment Form)
(2)(e) Preventing terminated employees from accessing records containing personal information. ✓MA 201 CMR 17.00 requirement covered by WISP in the Operational / Technical / Management Security Policy
(2)(f) Oversee service providers, by:
(2)(f)(1) 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; and ✓MA 201 CMR 17.00 requirement covered by WISP in the Service Provider Policy
(2)(f)(2) Requiring such third-party service providers by contract to implement and maintain such appropriate security measures for personal information; provided, however, that until March 1, 2012, a contract a person has entered into with a third party service provider to perform services for said person or functions on said person’s behalf satisfies the provisions of 17.03(2)(f)(2) even if the contract does not include a requirement that the third party service provider maintain such appropriate safeguards, as long as said person entered into the contract no later than March 1, 2010. ✓MA 201 CMR 17.00 requirement covered by WISP in the Service Provider Policy
(2)(g) Reasonable restrictions upon physical access to records containing personal information, and storage of such records and data in locked facilities, storage areas or containers. ✓MA 201 CMR 17.00 requirement covered by WISP in the Data Classification and Operational / Technical / Management Policies
(2)(h) 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. ✓MA 201 CMR 17.00 requirement covered by WISP in the Privacy & Monitoring Policy
(2)(i) 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. ✓MA 201 CMR 17.00 requirement covered by WISP in the Information Assurance (IA) and Risk Assessment Policies
(2)(j) 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 protection of personal information. ✓MA 201 CMR 17.00 requirement covered by WISP in the Incident Response Policy
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