Chief Information Security Officer of an organization

 

read the Florida statutes on the security of confidential personal information (501.171): http://www.leg.state.fl.us/Statutes/index.cfm?App_mode=Display_Statute&URL=0500-0599/0501/Sections/0501.171.htmlLinks to an external site.
• Summarize the salient features of the stature [300 words].
• Assume that you are the Chief Information Security Officer of an organization. What steps will you take to ensure compliance for your organization with the statute? [300 words].

 

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.

This question has been answered.

Get Answer
WeCreativez WhatsApp Support
Our customer support team is here to answer your questions. Ask us anything!
👋 Hi, Welcome to Compliant Papers.