■ Employee Training

While your data security plan may look great on paper, it’s only as strong as the employees who implement it. Take time to explain the rules to your staff, and train them to spot security vulnerabilities.

3 Check references or do background checks before hiring employees who will have access to sen- sitive data. Ask every new employee to sign an agreement to follow your company’s confidentiality and security standards for handling sensitive data.

3 Know which employees have access to consumers’ sensitive personally identifying information. Limit access to personal information to employees with a “need to know.”

3 Have a procedure in place for making sure that workers who leave your employ or transfer to anoth- er part of the company no longer have access to sensitive information. Terminate their passwords, and collect keys and identification cards as part of the check-out routine.

3 Create a “culture of security” by implementing a regular schedule of employee training. Make sure training includes employees at satellite offices, temporary help, and seasonal workers.

3 Require employees to notify you immediately if there is a potential security breach, such as a lost or stolen laptop.

■ Security Practices of Contractors and Service Providers

Your security practices depend on the people who implement them, including contractors and service providers.

3 Before you out- source any of your business functions – payroll, web hosting, custom- er call center operations, data processing, etc. – investigate the company’s data security practices and compare their standards to yours. If possible, visit their facilities.

3 Put your security expectations in writing in con- tracts with service providers. Insist that they notify you of any securi- ty incidents they experience, even if the incidents may not have led to an actual compromise of your data.

Mar/Apr | The Retailer Magazine | 27

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