In the old days of storytelling, the will-o’-‘the-wisp was a sprite that lured foolish travelers astray into a marsh and deflected them from reaching their destination. A will-o’ the wisp came to mean anything that was an impractical or unattainable goal.
But happily, today, a WISP is both attainable and necessary for CPAs and other financial firms. It meets compliance goals for the company and gives clients confidence in the firm’s management practices and the security of their data.
In today’s rapidly evolving digital landscape, if you own a CPA/financial firm, you are likely a prime target for cyberattacks due to the sensitive nature of the data you handle. To mitigate these risks and ensure compliance with regulatory requirements, it is imperative for you to implement a comprehensive Written Information Security Plan (WISP). This article will explore what a WISP is, the legal reasons necessitating its adoption, and how to develop it.
Understanding a Written Information Security Plan (WISP).
A Written Information Security Plan (WISP) is a documented set of policies and procedures designed to protect sensitive information from unauthorized access, disclosure, alteration, and destruction. It encompasses various aspects of information security, including data encryption, access controls, network security, employee training, and incident response protocols.
A WISP serves as a blueprint for your company’s information security efforts, providing a clear and structured approach to safeguarding data.
Legal reasons for implementing a WISP.
A key aspect of implementing a WISP is the legal requirement for CPA and financial firms to comply with various regulations aimed at protecting customer data and maintaining the integrity of the financial system. These legal reasons include:
- Regulatory compliance: CPA and financial firms are subject to stringent regulations aimed at protecting customer data and maintaining the integrity of the financial system. Key regulations include:
- Gramm-Leach-Bliley Act (GLBA): The GLBA mandates that financial institutions establish measures to protect customer information. A WISP helps firms comply with the GLBA by outlining specific security protocols and practices.
- Sarbanes-Oxley Act (SOX): SOX requires publicly traded companies to implement internal controls and procedures for financial reporting. A robust WISP ensures that sensitive financial data is protected, thus aiding in SOX compliance.
- Federal Trade Commission (FTC) Safeguards Rule: This rule mandates that financial institutions develop, implement, and maintain a comprehensive information security program. A WISP is essential for meeting these requirements.
- State Data Protection Laws: Many states have enacted their own data protection laws, such as the California Consumer Privacy Act (CCPA) and the New York SHIELD Act. These laws often require financial firms a WISP to implement and maintain information security programs to protect consumer data.
- Protecting sensitive information: Financial professionals handle vast amounts of sensitive information, including personal identification information (PII), financial records, and proprietary data. A WISP is crucial for protecting this information from cyberthreats such as data breaches, ransomware attacks, and insider threats.
- Risk management: The financial sector is inherently high-risk due to the value of the assets managed and the potential for significant financial losses resulting from cyber incidents. A WISP helps your firm identify, assess, and mitigate these risks. In turn, it helps reduce the likelihood of costly data breaches and ensuring the continuity of your business.
- Reputation management: Data breaches can severely damage your firm’s reputation, eroding client trust and confidence. By implementing a WISP, your firms demonstrate your commitment to protecting customer data. It enhances your company’s reputation and help maintain your client trust with you.
How to develop a WISP for your firm.
Implementing a WISP might seem daunting, but by breaking it down into manageable steps, your firm can develop a robust security framework. Below are essential steps to help guide your efforts in creating an effective WISP:
Step 1: Define information sources and identify risks.
Begin by cataloging all the information sources within your firm. Consider the following:
- Data types: Identify the types of data you handle, such as personal identification information (PII), financial records, and proprietary information.
- Storage locations: Map out where this data resides. Are your critical files on local servers, in cloud storage, or in physical files?
- Risk assessment: List the potential cyberthreats you are most concerned about, such as data breaches, ransomware, or insider threats. Understanding these risks will help you tailor your security measures. If you are unsure how to proceed, our CMIT experts are here to help.
Step 2: Develop a comprehensive security strategy.
Once you have a clear understanding of your information sources and potential risks, start developing a comprehensive strategy to protect this data. Your strategy should include:
- Policies and procedures: Draft detailed security policies and procedures that align with regulatory requirements and industry best practices. Ensure these documents are accessible and understood by all employees.
- Access controls: Implement strict access controls to ensure that only authorized personnel can access sensitive information. This includes using strong passwords and password management, multi-factor authentication, and regular audits of access rights.
- Data encryption: Use robust encryption methods to protect data at rest and in transit. This adds an extra layer of security against unauthorized access.
- Incident response plan: Develop a plan outlining the steps to be taken in the event of a data breach or security incident. This should include notification procedures and steps to mitigate damage.
- Employee training: Educate employees on security best practices, phishing prevention, and incident response. Regular training sessions help foster a security-conscious culture within your organization.
Step 3: Implement technical safeguards.
After defining your strategy, it’s crucial to implement technical safeguards to protect your data. A few examples are:
- Firewalls and intrusion detection systems: Set up robust firewalls and intrusion detection systems to monitor and block unauthorized access attempts.
- Regular software updates: Ensure all software, including operating systems and applications, are regularly updated to patch security vulnerabilities.
- Data backup solutions: Implement backup solutions to ensure you can recover data in case of a cyber incident. Use both on-site and off-site backups for redundancy.
If you need assistance with any of the above and more, our experts can help you ensure you have the technology you need to implement any of the above.
Step 4: Regular monitoring and maintenance.
Continuous monitoring and maintenance are key to maintaining a strong security posture, including:
- Security audits: Conduct security audits on a set cadence to identify and address vulnerabilities. This includes penetration testing and vulnerability assessments.
- Log management: Maintain and routinely review security logs to detect any unusual activities that might indicate a breach.
- Incident response drills: Conduct periodical incident response drills to ensure your team is prepared to act swiftly and effectively in the event of a security incident.
Step 5: Stay informed and compliant.
The regulatory landscape is always evolving. You can stay informed by:
- Regulatory updates: Keep abreast of changes in regulations that impact your firm, such as updates to the GLBA, SOX, and state-specific data protection laws.
- Compliance checks: Regularly review your WISP to ensure it meets current regulatory requirements and industry standards.
How CMIT Solutions can assist.
While you may want to take on the plan yourself, partnering with a managed services provider like CMIT Solutions will help ensure the plan is done right. This will significantly enhance your information security efforts and allow you to focus on other areas of your business.
Our CMIT team specializes in the development, implementation and maintenance of robust WISPs tailored to the unique needs of your CPA or financial firm, ensuring comprehensive compliance with industry standards. We work closely with you to develop your WISP, and ensure your systems and security protocols follow the established policies. With our proactive monitoring, maintenance, and management of your IT, you can be assured that your WISP remains effective and compliant with evolving regulations, giving you peace of mind and robust protection against cyberthreats.
Contact us today to safeguard your client data, protect your business assets and reputation, and ensure your WISP is compliant with our expert support!
