Is your “Written Information Security Program” Ready for the March 1, 2010 Deadline? by Michael A. Gamboli, Esq.

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Mass. General Laws Chapter 93H requires every company that maintains or stores personal information (“PI”) of a resident of the Commonwealth of Massachusetts to provide extensive notification to authorities if PI is ever compromised. In order to prevent PI from ever being compromised, new regulations promulgated under this statute now require companies to develop, implement and maintain a comprehensive “Written Information Security Program” ("Program") to protect PI. The deadline for putting a Program in place is March 1, 2010. The level of detail required of a Program is generally considered excessive, which likely accounts for the fact that the deadline for compliance has been extended three times. However, further extension of the March 1, 2010 deadline is not anticipated.

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