FTC Sticks With Keeping Security Current, Physical Media Safe

by Manatt, Phelps & Phillips, LLP
Contact

Manatt, Phelps & Phillips, LLP

In the latest blog posts in the Federal Trade Commission’s “Stick with Security” series, the FTC focused on the procedures companies should put in place that will keep their security current, will address vulnerabilities that may arise and will keep paper, physical media and devices safe.

Advocating for businesses to follow the slogan “Sound data security is a process, not a checklist,” the FTC frowned on approaching data security with a “one-and-done attitude.” Instead, companies should put procedures in place to stay on top of the ever-evolving risks posed by hackers and data thieves, wrote Acting Director Thomas B. Pahl of the FTC’s Bureau of Consumer Protection.

More specifically, businesses should update and patch software by reaching out to existing customers when a vulnerability arises, and take into account products that are still available on retail shelves. One helpful tip: plan how to deliver security updates in advance by building them into the product’s design, the FTC suggested.

For example, a thermostat company configured the default settings on a product to automatically search for and install security updates via its Internet connection, while a smart kitchen appliance features an alert button that provides a visual cue to let consumers know that a security update is available online.

Pahl also advised businesses to heed credible security warnings and move quickly to fix any problems. Designate a contact person at the company for security issues or create a monitored email account to flag concerns for possible investigation and action. “The lesson for companies committed to sticking with security is to create channels in advance to receive and send critical information about potential vulnerabilities,” the FTC wrote. “Move quickly to implement appropriate security remedies.”

However, a second blog post reminded businesses that some data thieves prefer “old school” methods of security violations—“rifling through file cabinets, pinching paperwork, and pilfering devices like smartphones and flash drives. As your business bolsters the security of your network, don’t let that take attention away from how you secure documents and devices,” the FTC cautioned.

Sensitive files should be securely stored (personnel files in locked cabinets within locked offices) and devices that process personal information should be protected by requiring employees to lock their smartphones with a passcode and encrypt data on the device. When data is on the move, security standards still apply, Pahl reminded companies. Data should be encrypted on an external hard drive when data is shipped to headquarters, or security training should be provided so that employees don’t leave bags filled with customers’ financial information in the back seat of their cars.

Disposal of sensitive data should also be handled in a secure fashion, the FTC said. “Just tossing documents in the bin or clicking DELETE is unlikely to deter infobandits,” according to the blog post. “To prevent them from reconstructing discarded files, responsible companies take the prudent step of shredding, burning, or otherwise destroying documents and using tech tools that truly render electronic files unreadable.”

To read the FTC’s blog post on procedures to keep security current and address vulnerabilities, click here.

To read the FTC’s blog post on securing paper, physical media and devices, click here.

Why it matters: As the FTC’s “Stick with Security” series winds down to a finish, the two blog posts emphasized the need to put procedures in place to keep security current and address vulnerabilities that arise, while remembering that paper, physical media and devices still need to be protected as part of a 360-degree approach to protecting confidential data.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Manatt, Phelps & Phillips, LLP | Attorney Advertising

Written by:

Manatt, Phelps & Phillips, LLP
Contact
more
less

Manatt, Phelps & Phillips, LLP on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up using*

Already signed up? Log in here

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
Privacy Policy (Updated: October 8, 2015):
hide

JD Supra provides users with access to its legal industry publishing services (the "Service") through its website (the "Website") as well as through other sources. Our policies with regard to data collection and use of personal information of users of the Service, regardless of the manner in which users access the Service, and visitors to the Website are set forth in this statement ("Policy"). By using the Service, you signify your acceptance of this Policy.

Information Collection and Use by JD Supra

JD Supra collects users' names, companies, titles, e-mail address and industry. JD Supra also tracks the pages that users visit, logs IP addresses and aggregates non-personally identifiable user data and browser type. This data is gathered using cookies and other technologies.

The information and data collected is used to authenticate users and to send notifications relating to the Service, including email alerts to which users have subscribed; to manage the Service and Website, to improve the Service and to customize the user's experience. This information is also provided to the authors of the content to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

JD Supra does not sell, rent or otherwise provide your details to third parties, other than to the authors of the content on JD Supra.

If you prefer not to enable cookies, you may change your browser settings to disable cookies; however, please note that rejecting cookies while visiting the Website may result in certain parts of the Website not operating correctly or as efficiently as if cookies were allowed.

Email Choice/Opt-out

Users who opt in to receive emails may choose to no longer receive e-mail updates and newsletters by selecting the "opt-out of future email" option in the email they receive from JD Supra or in their JD Supra account management screen.

Security

JD Supra takes reasonable precautions to insure that user information is kept private. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. However, please note that no method of transmitting or storing data is completely secure and we cannot guarantee the security of user information. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time.

If you have reason to believe that your interaction with us is no longer secure, you must immediately notify us of the problem by contacting us at info@jdsupra.com. In the unlikely event that we believe that the security of your user information in our possession or control may have been compromised, we may seek to notify you of that development and, if so, will endeavor to do so as promptly as practicable under the circumstances.

Sharing and Disclosure of Information JD Supra Collects

Except as otherwise described in this privacy statement, JD Supra will not disclose personal information to any third party unless we believe that disclosure is necessary to: (1) comply with applicable laws; (2) respond to governmental inquiries or requests; (3) comply with valid legal process; (4) protect the rights, privacy, safety or property of JD Supra, users of the Service, Website visitors or the public; (5) permit us to pursue available remedies or limit the damages that we may sustain; and (6) enforce our Terms & Conditions of Use.

In the event there is a change in the corporate structure of JD Supra such as, but not limited to, merger, consolidation, sale, liquidation or transfer of substantial assets, JD Supra may, in its sole discretion, transfer, sell or assign information collected on and through the Service to one or more affiliated or unaffiliated third parties.

Links to Other Websites

This Website and the Service may contain links to other websites. The operator of such other websites may collect information about you, including through cookies or other technologies. If you are using the Service through the Website and link to another site, you will leave the Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We shall have no responsibility or liability for your visitation to, and the data collection and use practices of, such other sites. This Policy applies solely to the information collected in connection with your use of this Website and does not apply to any practices conducted offline or in connection with any other websites.

Changes in Our Privacy Policy

We reserve the right to change this Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our privacy policy will become effective upon posting of the revised policy on the Website. By continuing to use the Service or Website following such changes, you will be deemed to have agreed to such changes. If you do not agree with the terms of this Policy, as it may be amended from time to time, in whole or part, please do not continue using the Service or the Website.

Contacting JD Supra

If you have any questions about this privacy statement, the practices of this site, your dealings with this Web site, or if you would like to change any of the information you have provided to us, please contact us at: info@jdsupra.com.

- hide
*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.