State Laws Require Businesses to Will o' WISP

In 2018, Michigan enacted its Data Security Act which applies to persons and entities with licenses from its Department of Insurance and Financial Services.

In order to comply with the act it is necessary to :

1. Prepare a Written Information Security Program (WISP).

2. File a certificate of compliance with the Department each year.

3. Report breaches to the Department within 10 days after discovery.

Massachusetts also has cybersecurity regulations which require that a WISP be filed. A template of a WISP that complies with Massachusetts law and the Gramm-Leach-Bliley Act has been prepared by Thomson Reuters and is available here on the website of the International Association of Privacy Professionals (IAPP). A WISP should cover the following:

1. Define personal information and sensitive information.

2. Designate a person responsible for implementing the WISP.

3. Provide for regular risk assessments.

4. Direct the distribution of information security policies within the organization.

5. Monitor service providers to ensure they comply with WISP.

6. Establish Incident response procedures.

Ohio Data Protection Act

In 2018, Ohio enacted the its Data Protection Act under which companies can get safe harbor from tort claims by compiling with one of below cyber security programs:

1. The NIST Cybersecurity Framework.

2. NIST Special Publication 800-171, or 800-53 and 800-53a.

3. The FedRAMP Security Assessment Framework.

4. The CIS (Center for Internet Security) Controls.

5. ISO 27000 Security Management Standards

Businesses that have sites on which financial transactions can be made, must also comply with Payment Card Industry’s Data Security Standards (PCI-DSS). A safe harbor affirmative defense is also available to businesses that meet the security requirements of HIPAA, and the Gramm -Leach-Bliley Act.

Stop Internet Explorer From Running Javascript

A potential security flaw in Windows is the ability of Internet Explorer to run Java scripts. A .dll file located in the system folder on the C drive enables IE to run Java:

. . . you can disable the ability of IE to run Java scripts in the Registry Editor under HKEY_LOCAL_MACHINE\SOFTWARE\Microsoft\Windows\CurrentVersion\Internet Settings\Zones\3

Change the value for 140D at this location to 3. This will cause the execution of the scripts to be disabled by default.