From time to time in the course of our business, Dorchester Awning Company LLC (“Dorchester” or “dorchester Awning”) will collect and maintain confidential information about our customers, particularly related to their credit card information, for which we will use for transacting business with the end-user customer (“Customer”).
To ensure that Dorchester is compliant with Massachusetts 201 CMR 17.00: STANDARDS FOR THE PROTECTION OF PERSONAL INFORMATION OF RESIDENTS OF THE COMMONWEALTH, we will employ the following protocols regarding such information.
“Confidential Information” shall mean a Massachusetts resident's first name and last name or first initial and last name in combination with their financial account number, or credit or debit card number, with or without any required security code, access code, personal identification number or password, that would permit access to a resident's financial account.
Dorchester shall not collect the following information: Social Security number or driver's license number or state-issued identification card number.
Dorchester’s information security program sets forth the following protocols:
1. The Chief Executive Officer (“CEO”) of Dorchester is to maintain the comprehensive information security program.
2. The CEO shall form a committee of one or more employees whose job it is to:
2.1. identifying and assessing reasonably foreseeable internal and external risks to the security, confidentiality, and/or integrity of any electronic, paper or other records containing personal information, and evaluating and improving, where necessary, the effectiveness of the current safeguards for limiting such risks, including but not limited to:
2.1.1. ongoing employee (including temporary and contract employee) training.
2.1.2. employee compliance with policies and procedures.
2.1.3. means for detecting and preventing security system failures.
3. The CEO or his designee shall develop security policies for employees relating to the storage, access and transportation of records containing personal information outside of business premises, as such:
4. All Confidential Data shall be maintained on a central computer system that conforms to the requirements of 201 CMR 17.00 as indicated by third party providers.
5. The CEO or his designee imposing disciplinary measures for violations of the comprehensive information security program rules.
6. The CEO or his designee preventing terminated employees from accessing records containing personal information.
7. The CEO or his designee shall oversee service providers, by:
7.1. Taking reasonable steps to select and retain third-party service providers that are capable of maintaining appropriate security measures to protect such personal information consistent with 201 CMR 17.00 and any applicable federal regulations; and
7.2. Requiring such third-party service providers by contract to implement and maintain such appropriate security measures for personal information.
8. The CEO or his designee shall establish reasonable restrictions upon physical access to records containing personal information, and storage of such records and data in locked facilities, storage areas or containers.
9. The CEO or his designee shall regularly monitor to ensure that the comprehensive information security program is operating in a manner reasonably calculated to prevent unauthorized access to or unauthorized use of personal information; and upgrading information safeguards as necessary to limit risks.
10. The CEO or his designee shall review the scope of the security measures at least annually or whenever there is a material change in business practices that may reasonably implicate the security or integrity of records containing personal information.
11. The CEO or his designee shall document responsive actions taken in connection with any incident involving a breach of security, and mandatory post-incident review of events and actions taken, if any, to make changes in business practices relating to protection of personal information.
The CEO or his designee is responsible for the establishment and maintenance of a security system covering its computers, including any wireless system, that:
1. Secure user authentication protocols including:
1.1. control of user IDs and other identifiers.
1.2. a reasonably secure method of assigning and selecting passwords, or use of unique identifier technologies, such as biometrics or token devices.
1.3. control of data security passwords to ensure that such passwords are kept in a location and/or format that does not compromise the security of the data they protect.
1.4. restricting access to active users and active user accounts only; and
1.5. blocking access to user identification after multiple unsuccessful attempts to gain access or the limitation placed on access for the particular system.
2. It shall be the policy of Dorchester that the CEO or his designee shall have access to the network passwords and each computer system that is operated by an employee shall have a unique ID and password, which shall be generated by the user. Any Confidential Information that is stored shall be maintained in a central database that is secure and accessible only by designated individuals.
3. The CEO or his designee shall secure access control measures that:
3.1. restrict access to records and files containing personal information to those who need such information to perform their job duties; and
3.2. assign unique identifications plus passwords, which are not vendor supplied default passwords, to each person with computer access, that are reasonably designed to maintain the integrity of the security of the access controls.
4. The CEO or his designee shall ensure that all transmitted records and files containing personal information that will travel across public networks shall be encrypted as shall be all data containing personal information to be transmitted wirelessly.
5. The CEO or his designee shall establish reasonable monitoring of systems, for unauthorized use of or access to personal information.
6. It shall be the policy of Dorchester that no personal information stored on laptops or other portable devices; for files containing personal information on a system that is connected to the Internet, there must be reasonably up-to-date firewall protection and operating system security patches, reasonably designed to maintain the integrity of the personal information. The CEO or his designee shall ensure that reasonably up-to-date versions of system security agent software which must include malware protection and reasonably up-to-date patches and virus definitions, or a version of such software that can still be supported with up-to-date patches and virus definitions and is set to receive the most current security updates on a regular basis.
7. Education and training of employees on the proper use of the computer security system and the importance of personal information security.
Dorchester Awning reserves the right to amend these policies.
Effective February 26, 2024
