The Revised Safeguards Rule requires any financial institutions, included auto dealerships, to develop, implement, and maintain an information security program with administrative, technical, and physical safeguards designed to protect customer information. The Rule covers information about your own customers and information about custoemrs of other financial institutions that have provided that data to you.
To comply with the Rule, your dealership must:
- Designate a qualified individual to implement and supervise yoru company's information security program
- Conduct a risk assessment
- Design and implement safeguards to control the risks identified through your risk assessment
- Implement and periodically review access controls
- Know what you have and where you have it
- Encrypt customer information on your system and when it's in transit
- Assess your apps
- Implement multi-factor authentication for anyone accessing customer information on your system
- Dispose of customer information securely
- Anticipate and evaluate changing to your information system or network
- Maintain a log of authorized users' activity and keep an eye out for unauthorized access
- Regularly monitor and test the effectiveness of your safeguards
- Train your staff
- Monitor your service providers
- Keep your information security program current
- Create a written incident response plan
- Require your qualified individual to report to your Board of Directors