By Lesley Fair

Taking steps to protect personal information in your files and on your computer can go a long way toward preventing a security breach.  Nevertheless, breaches can happen.  That’s why the Federal Trade Commission (FTC) recommends that companies have a plan in place to respond to security incidents before they occur.  Putting together a “What if?” action strategy now may help reduce the impact an information breach can have on your business, your employees, and your customers. Here are some tips from the FTC about customizing your company’s security response plan.

• View from the top.  Senior management sets the tone for any organization’s commitment to data security.  That’s why drafting, coordinating, and implementing your company’s response plan isn’t a job for a newcomer.  Designate a well-respected senior official to head up your response team.  Select someone with a reputation for working well with every part of your operation – sales, financial, personnel, information technology, etc. – and give him or her a hotline to the head of the company.
• Put a plan in place.  Once you’ve put together your response team, have them draft contingency plans for how your business will respond to different kinds of security incidents.  Some threats may come out of left field; others – a lost laptop or a hack attack, to name just two – are unfortunate, but foreseeable. 
• Trust your gut.  Experience sharpens intuition.  If your staff suspects a breach, investigate it immediately.  Waiting days to convene a committee or “run it up the corporate flagpole” can waste precious time.
• Pull the plug.   If you suspect a computer breach, immediately sever the compromised computer’s access to the Internet and to your network.  To assess the impact, ask your IT staff to preserve any available network logs, file transfer logs, system logs, and access reports.  Investigate if intruders opened files or placed new programs on your computer.  Did they release viruses or other malware?  By diagnosing the damage and retracing the fraudsters’ steps, you can help your company shore up unanticipated vulnerabilities.
• Making contact.  Consider whom to inform in the event of an incident, both inside and outside your company. You may need to notify consumers, law enforcement agencies, customers, credit bureaus, and other businesses that may be affected by the breach.  In addition, about 40 states have laws addressing data breaches.  Have that information on file before you need it.

For more information, read Protecting Personal Information: A Guide for Business at business.ftc.gov.

Lesley Fair is an attorney in the FTC’s Bureau of Consumer Protection who specializes in business compliance.