Chief Information Security Officer of an organization
Sample Solution
Scope: Applies to any person conducting business in Florida who possesses or maintains "personal information" of a Florida resident in electronic form. "Personal information" includes various identifiers like names, Social Security numbers, financial account numbers, health information, and more.
Breach of Security: Defines a "breach of security" as unauthorized access of electronic data containing personal information. Requires reporting a breach to affected individuals and law enforcement under specific conditions.
Notification Requirements:
- Requires notification to affected individuals if a breach involves more than 500 residents and presents a "high risk of identity theft" (based on factors like type of information breached, access methods used).
- Notification method depends on the number of individuals affected (mail, website posting, etc.).
- Requires notification to law enforcement if a breach involves more than 1,000 residents or "presents a significant risk of identity theft or fraud."
Data Security Measures: Requires "reasonable security measures" to protect personal information, considering industry standards and the sensitivity of the information. Measures may include:
- Access controls
- Data encryption
- Activity monitoring
- Incident response plans
Additional Provisions:
- Prohibits selling or disclosing personal information acquired through a breach.
- Grants private right of action for individuals harmed by a breach.
- Exempts certain entities like financial institutions and certain government agencies from some provisions.
Penalties: Violations can result in civil penalties of up to $500,000 per breach.
Compliance Steps as Chief Information Security Officer (300 words):
1. Inventory and Classification:
- Identify all systems and applications storing personal information.
- Classify data based on sensitivity and risk of harm in case of a breach.
2. Implement Security Measures:
- Implement access controls (e.g., multi-factor authentication) to restrict unauthorized access.
- Encrypt sensitive data at rest and in transit.
- Monitor system activity for suspicious behavior.
- Develop and regularly test incident response plans to address breaches promptly.
3. Awareness and Training:
- Educate employees on the statute's requirements and their role in data security.
- Train them on recognizing and reporting phishing attacks and suspicious activity.
4. Risk Assessment and Regular Audits:
- Conduct regular risk assessments to identify vulnerabilities and prioritize mitigation efforts.
- Perform internal audits to verify compliance with security policies and procedures.
5. Breach Response Planning:
- Develop a comprehensive breach response plan that outlines steps for detecting, containing, and remediating breaches.
- Practice the plan regularly and update it as needed.
6. Third-Party Vendor Management:
- Ensure contracts with third-party vendors require them to comply with data security standards and notify you of any breaches.
- Conduct due diligence on vendors before engaging them.
7. Data Disposal:
- Implement secure data disposal procedures to permanently erase personal information when no longer needed.
8. Continuous Improvement:
- Stay informed about evolving cyber threats and update security measures accordingly.
- Regularly review and improve your data security program based on lessons learned from incidents and audits.
Remember, this is a general overview. Compliance requires a thorough understanding of the statute and its nuances, considering your organization's specific risks and data practices. Consulting with legal and security professionals is recommended for tailored guidance.