The Program Coordinator will establish and maintain a security system covering the Company’s computers, including any wireless system, which at a minimum will have the following elements:

(1) Secure user authentication protocols including:
• control of user IDs and other identifiers;
• a reasonably secure method of assigning and selecting passwords, or use of unique identifier technologies, such as biometrics or token devices;
• 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;
• restricting access to active users and active user accounts only; and
• blocking access to user identification after multiple unsuccessful attempts to gain access or the limitation placed on access for the particular system
(2) Secure access control measures that:
• restrict access to records and files containing Personal Information to those who need such information to perform their job duties; and
• 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
(3) To the extent technically feasible, encryption of all transmitted records and files containing Personal Information that will travel across public networks, and encryption of all data to be transmitted wirelessly.
(4) Reasonable monitoring of systems for unauthorized use of or access to personal information.
(5) Encryption of all Personal Information stored on laptops or other portable devices.
(6) For files containing Personal Information on a system that is connected to the Internet, reasonably up-to-date firewall protection and operating system security patches, which are reasonably designed to maintain the integrity of the personal information.
(7) 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 which can be supported with up-to-date patches and virus definitions and which is set to receive the most current security updates on a regular basis.
(8) Education and training of employees on the proper use of the computer security system and the importance of Personal Information security.