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Network security is a critical consideration, but many of the same lessons apply to paperwork and physical media like hard drives, laptops, flash drives, and disks. FTC cases offer some things to consider when evaluating physical security at your business.
If it’s necessary to retain important paperwork, take steps to keep it secure. In the Gregory Navone case, the FTC alleged that the defendant maintained sensitive consumer information, collected by his former businesses, in boxes in his garage. In Lifelock, the complaint charged that the company left faxed documents that included consumers’ personal information in an open and easily accessible area. In each case, the business could have reduced the risk to their customers by implementing policies to store documents securely.
Securing information stored on your network won’t protect your customers if the data has already been stolen through the device that collects it. In the 2007 Dollar Tree investigation, FTC staff said that the business’s PIN entry devices were vulnerable to tampering and theft. As a result, unauthorized persons could capture consumer’s payment card data, including the magnetic stripe data and PIN, through an attack known as “PED skimming.” Given the novelty of this type of attack at the time, and a number of other factors, staff closed the investigation. However, attacks targeting point-of-sale devices are now common and well-known, and businesses should take reasonable steps to protect such devices from compromise.
Savvy businesses understand the importance of securing sensitive information when it’s outside the office. In Accretive Health, for example, the FTC alleged that an employee left a laptop containing more than 600 files, with 20 million pieces of information related to 23,000 patients, in the locked passenger compartment of a car, which was then stolen. The CBR Systems case concerned alleged unencrypted backup tapes, a laptop, and an external hard drive – all of which contained sensitive information – that were lifted from an employee’s car. In each case, the business could have reduced the risk to consumers’ personal information by implementing reasonable security policies when data is en route. For example, when sending files, drives, disks, etc., use a mailing method that lets you track where the package is. Limit the instances when employees need to be out and about with sensitive data in their possession. But when there’s a legitimate business need to travel with confidential information, employees should keep it out of sight and under lock and key whenever possible.
Paperwork or equipment you no longer need may look like trash, but it’s treasure to identity thieves if it includes personal information about consumers or employees. For example, according to the FTC complaints in Rite Aid and CVS Caremark, the companies tossed sensitive personal information – like prescriptions – in dumpsters. In Goal Financial, the FTC alleged that an employee sold surplus hard drives that contained the sensitive personal information of approximately 34,000 customers in clear text. The companies could have prevented the risk to consumers’ personal information by shredding, burning, or pulverizing documents to make them unreadable and by using available technology to wipe devices that aren’t in use.
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