The Canadian Privacy Law Blog: Developments in privacy law and writings of a Canadian privacy lawyer, containing information related to the Personal Information Protection and Electronic Documents Act (aka PIPEDA) and other Canadian and international laws.

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The author of this blog, David T.S. Fraser, is a Canadian privacy lawyer who practices with the firm of McInnes Cooper. He is the author of the Physicians' Privacy Manual. He has a national and international practice advising corporations and individuals on matters related to Canadian privacy laws.

For full contact information and a brief bio, please see David's profile.

Please note that I am only able to provide legal advice to clients. I am not able to provide free legal advice. Any unsolicited information sent to David Fraser cannot be considered to be solicitor-client privileged.

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The views expressed herein are solely the author's and should not be attributed to his employer or clients. Any postings on legal issues are provided as a public service, and do not constitute solicitation or provision of legal advice. The author makes no claims, promises or guarantees about the accuracy, completeness, or adequacy of the information contained herein or linked to. Nothing herein should be used as a substitute for the advice of competent counsel.

This web site is presented for informational purposes only. These materials do not constitute legal advice and do not create a solicitor-client relationship between you and David T.S. Fraser. If you are seeking specific advice related to Canadian privacy law or PIPEDA, contact the author, David T.S. Fraser.

Wednesday, August 10, 2005

Lessons learned from corporate security breaches 

Jay Cline, over at Computer World, is writing about "lessons learned" from the recent string of privacy/security breaches. He concludes with a bit of a "to do" list:

Lessons learned from corporate security breaches - Computerworld

"So what projects need to be at the top of your organization's agenda for the next 12 months?

  • Adopt a comprehensive information security program based on the ISO 17799 and Payment Card Industry standards.
  • Require any sensitive information stored on laptops to be encrypted.
  • Formalize a process where employees can contact a central phone number or e-mail to report suspicious activity with company information.
  • Validate the security of suppliers that handle your sensitive information, including backup tapes and documents.
  • Train employees on your security policies and procedures and performing periodic spot checks to measure compliance.

Completing these types of projects is no guarantee of avoiding a publicized security breach. But they'll go a long way in properly allocating your limited budgets toward the areas of greatest risk."

All that makes sense, but I'd add a few elements to the mix:

  1. Review all your information holdings to make sure that you only have information that you should, that the information has been collected with the consent of the individuals and that you are not retaining any information longer than is reasonably necessary for the purposes for which it was collected. (If you don't need it, don't keep it around. What you don't have can't be stolen or misused.)
  2. Adopt a privacy/security policy that strictly delineates what information can be collected, how it will be used and for how long it will be retained.
  3. Train all your employees to be sensitive to security and privacy issues.
  4. Encrypt all information on any computer, not just laptops. (Servers and desktop computers are easily stolen.)
  5. To the extent that's possible, keep all sensitive information on a central server that is well secured.
  6. Collect audit trail information for all access to sensitive information, so you know who had access to it and when. Review the audit records for anything suspicious.

This isn't comprehensive, but it's a start ...

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