1. TAKE STOCK.
    Know what personal information you have in your files and on your computers.
    Effective data security starts with assessing what information you have and identifying who has access to it. Understanding how personal information moves into, through, and out of your business and who has—or could have—access to it is essential to assessing security vulnerabilities. You can determine the best ways to secure the information only after you’ve traced how it flows.

  2. Inventory all computers, laptops, mobile devices, flash drives, disks, home computers, digital copiers, and other equipment to find out where your company stores sensitive data. Also, inventory the information you have by type and location. Your file cabinets and computer systems are a start, but remember: your business receives personal information in a number of ways—through websites, from contractors, from call centers, and the like. What about information saved on laptops, employees’ home computers, flash drives, digital copiers, and mobile devices? No inventory is complete until you check everywhere sensitive data might be stored.

Track personal information through your business by talking with your sales department, information technology staff, human resources office, accounting personnel, and outside service providers. Get a complete picture of:
► Who sends sensitive personal information to your business. Do you get it from customers? Credit card companies? Banks or other financial institutions? Credit bureaus? Job applicants? Other businesses?


► How your business receives personal information. Does it come to your business through a website? By email? Through the mail? Is it transmitted through cash registers in stores?


► What kind of information you collect at each entry point. Do you get credit card information online? Does your accounting department keep information about customers’ checking accounts?

► Where you keep the information you collect at each entry point. Is it in a central computer database? On individual laptops? On a cloud computing service? On employees’ smartphones, tablets, or other mobile devices? On disks or tapes? In file cabinets? In branch offices? Do employees have files at home?


SECURITY CHECK
Question: Are there laws that require my company to keep sensitive data secure?
Answer: Yes. While you’re taking stock of the data in your files, take stock of the law, too. Statutes like the Gramm-Leach-Bliley Act, the Fair Credit Reporting Act, and the Federal Trade Commission Act may require you to provide reasonable security for sensitive information.
To find out more, visit business.ftc.gov/privacy-and-security 5 1 Take Stock

● Who has—or could have—access to the information? Which of your employees has permission to access the information? Do they need access? Could anyone else get hold of it? What about vendors who supply and update software you use to process credit card transactions? Contractors operating your call center?


● Different types of information present varying risks. Pay particular attention to how you keep personally identifying information: Social Security numbers, credit card or financial information, and other sensitive data. That’s what thieves use most often to commit fraud or identity theft.