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Building Your Dealership’s Shield: The Essential Guide to Information Security Programs

Adam Crowell

When it comes to protecting customer information in your dealership, having a written Information Security Program that is robust is not just a good business practice—it’s a regulatory requirement. As auto dealers, you collect and store some of the most sensitive consumer information during your transactions. This makes you a prime target for data breaches and puts you squarely in the sights of regulators.

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What Is an Information Security Program?

An Information Security Program is a comprehensive framework designed to protect the confidentiality, integrity, and availability of customer information. Based on the risks identified in your written risk assessment (Step 2), this program establishes the safeguards necessary to protect customer data from both internal and external threats.

Key Components of an Effective Program

Administrative Safeguards

Administrative safeguards focus on the policies, procedures, and personnel aspects of information security. These include:

  • Clearly defined roles and responsibilities for employees and managers
  • Access control policies that limit data access to those who need it
  • Employee training programs on information security awareness
  • Vendor management procedures to ensure service providers protect data appropriately
  • Incident response plans to address security breaches

Technical Safeguards

Technical safeguards involve the technology and systems used to protect and control access to customer information. These include:

  • Data encryption for sensitive information both in transit and at rest
  • Multi-factor authentication for system access
  • Firewalls and intrusion detection systems
  • Regular security patches and updates
  • Continuous monitoring of systems for unauthorized access

Physical Safeguards

Physical safeguards protect the physical infrastructure that stores and processes customer information. These include:

  • Secured facilities with controlled access
  • Locked filing cabinets for physical documents
  • Clean desk policies
  • Proper disposal procedures for physical documents
  • Environmental controls to protect equipment

Making It Work for Your Dealership

An effective Information Security Program for auto dealers should be:

  1. Automotive-specific: Generic security programs don’t address the unique challenges faced by dealerships. Your program should account for industry-specific workflows, systems, and regulatory requirements.
  2. Custom-tailored: No two dealerships operate exactly alike. Your program should reflect your specific business operations, size, complexity, and risk profile.
  3. Clear and concise: Security policies that employees can’t understand won’t be followed. Make your program accessible and actionable for all staff members.
  4. Regularly evaluated: As your business evolves and new threats emerge, your program needs to adapt. Schedule periodic reviews to ensure it remains effective.

The Qualified Individual’s Role

Remember that your designated Qualified Individual (from Step 1) is responsible for implementing, overseeing, and enforcing your Information Security Program. This individual needs to work closely with your information security personnel to ensure the program meets regulatory requirements and addresses the specific risks identified in your assessment.

How KPA Helps

At KPA, we understand that creating and maintaining a comprehensive Information Security Program can be challenging for dealerships. That’s why we provide more than just templates—we help you develop a customized program based on your specific risk assessment.

Our experts work with your team to craft administrative, technical, and physical safeguards that protect customer information while allowing your business to operate efficiently. We help you document how things should be and reconcile that with how they actually are, creating practical solutions that work in the real world of automotive retail.

As regulations evolve and new threats emerge, KPA stays ahead of the curve, helping you adapt your program to maintain compliance and protect your customers’ data. With our automotive-specific expertise, we ensure your Information Security Program meets both regulatory requirements and the practical needs of your dealership.

Strengthen Your Shield, Secure Your Future

An effective Information Security Program is the backbone of your privacy and safeguards compliance strategy. By establishing comprehensive administrative, technical, and physical safeguards, you create a framework that protects customer information, satisfies regulatory requirements, and reduces the risk of costly data breaches.

Remember, this isn’t just about checking a compliance box—it’s about protecting your customers’ sensitive information and, by extension, your dealership’s reputation and financial health. With KPA’s help, you can develop and maintain an Information Security Program that accomplishes both goals, giving you and your customers peace of mind in an increasingly complex regulatory environment.

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Adam Crowell

Adam Crowell is a licensed practicing attorney and nationally recognized compliance expert and speaker that regularly contributes on a variety of compliance and risk mitigation subjects. He brings to KPA over 21 years of legal experience and thought leadership for the development of strategic relationships and solutions for proactively avoiding claims, fines, and lawsuits.

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