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Can I skip having an information security program in place in Mississippi? What are the requirements?

Information Security Program Requirements in Mississippi

No, you cannot skip having an information security program in place in Mississippi.

Mississippi has established an Enterprise Security Program to provide for coordinated oversight of cybersecurity efforts across all state agencies [1.1]. Additionally, each licensee in Mississippi is required to develop, implement, and maintain a comprehensive written information security program based on the licensee’s risk assessment and that contains administrative, technical and physical safeguards for the protection of nonpublic information and the licensee’s information system [2.1][2.2].

Requirements for Information Security Program

The requirements for an information security program in Mississippi are as follows [2.1][2.2]:

  1. Designate one or more employees, an affiliate, or an outside vendor designated to act on behalf of the licensee who is responsible for the information security program.
  2. Identify reasonably foreseeable internal or external threats that could result in unauthorized access, transmission, disclosure, misuse, alteration or destruction of nonpublic information, including the security of information systems and nonpublic information that are accessible to, or held by, third-party service providers.
  3. Assess the likelihood and potential damage of these threats, taking into consideration the sensitivity of the nonpublic information.
  4. Assess the sufficiency of policies, procedures, information systems and other safeguards in place to manage these threats.
  5. Implement information safeguards to manage the threats identified in its ongoing assessment, and no less than annually, assess the effectiveness of the safeguards’ key controls, systems and procedures.
  6. Design its information security program to mitigate the identified risks, commensurate with the size and complexity of the licensee, the nature and scope of the licensee’s activities, including its use of third-party service providers, and the sensitivity of the nonpublic information used by the licensee or in the licensee’s possession, custody or control.
  7. Determine which security measures listed below are appropriate and implement such security measures:
    • Place access controls on information systems, including controls to authenticate and permit access only to authorized individuals to protect against the unauthorized acquisition of nonpublic information.
    • Identify and manage the data, personnel, devices, systems and facilities that enable the organization to achieve business purposes in accordance with their relative importance to business objectives and the organization’s risk strategy.
    • Restrict physical access to nonpublic information, only to authorized individuals.
    • Protect by encryption or other appropriate means, all nonpublic information while being transmitted over an external network and all nonpublic information stored on a laptop computer or other portable computing or storage device or media.
    • Adopt secure development practices for in-house developed applications utilized by the licensee.
    • Modify the information system in accordance with the licensee’s information security program.
    • Utilize effective controls, which may include multi-factor authentication procedures for employees accessing nonpublic information.
    • Regularly test and monitor systems and procedures to detect actual and attempted attacks on, or intrusions into, information systems.
    • Include audit trails within the information security program designed to detect and respond to cybersecurity events and designed to reconstruct material financial transactions sufficient to support normal operations and obligations of the licensee.
    • Implement measures to protect against destruction, loss, or damage of nonpublic information due to environmental hazards, such as fire and water damage or other catastrophes or technological failures.
    • Develop, implement, and maintain procedures for the secure disposal of nonpublic information in any format.
  8. Include cybersecurity risks in the licensee’s enterprise risk management process.
  9. Stay informed regarding emerging threats or vulnerabilities and utilize reasonable security measures when sharing information relative to the character of the sharing and the type of information shared.
  10. Provide its personnel with cybersecurity awareness training that is updated as necessary to reflect risks identified by the licensee in the risk assessment.
  11. Establish a written incident response plan designed to promptly respond to, and recover from, any cybersecurity event that compromises the confidentiality, integrity or availability of nonpublic information in its possession, the licensee’s information systems, or the continuing functionality of any aspect of the licensee’s business or operations.

If the licensee has a board of directors, the board or an appropriate committee of the board shall require the licensee’s executive management or its delegates to develop, implement and maintain the licensee’s information security program [2.2].

Reporting Requirements

Each agency must report all information security incidents to the ITS Information Security Division (ISD) as soon as possible [3.1]. Information security incidents result from a validation of an information security event. Information security events are defined as any violation of computer security policies, network integrity, data confidentiality, or standard computer security practices. Detailed reporting procedures and a description of reportable events are provided in the ISD Cyber Security Incident Reporting Guidelines document [3.1].

Conclusion

In conclusion, Mississippi requires each licensee to develop, implement, and maintain a comprehensive written information security program based on the licensee’s risk assessment and that contains administrative, technical and physical safeguards for the protection of nonpublic information and the licensee’s information system. The requirements for an information security program in Mississippi are outlined in detail in [2.1][2.2]. Each agency must report all information security incidents to the ITS Information Security Division (ISD) as soon as possible [3.1].

Source(s):
Jurisdiction

Mississippi