CaseMark Written Information Security Program (WISP)
Drafts a 201 CMR 17.00-compliant WISP that satisfies regulatory examination and functions as an operational security blueprint.
Prerequisites
- Organization profile — legal name, industry, jurisdictions, employee count
- Data inventory — PI types, storage locations, transmission methods, access roles
- Existing security materials — current policies, prior WISPs, risk assessments, audit reports, incident logs
- Vendor list — third parties with access to personal information
- Coordinator identity — designated WISP coordinator name/title, or confirmation none exists
- Supplemental frameworks — applicable laws beyond MA (GDPR, CCPA, HIPAA, GLBA, PCI-DSS)
Output Structure
Produce a formally numbered document with table of contents, definitions section, body sections below, and appendices as needed.
Section 1 — Executive Summary & Program Purpose
| Field | Content |
|---|---|
| Effective Date | [DATE] |
| Version | [N] |
| Governing Regulation | 201 CMR 17.00; [additional frameworks] |
| Scope | PI of MA residents owned, licensed, stored, or maintained by [Org] |
| Commitment Statement | One-paragraph executive commitment to administrative, technical, and physical safeguards |
Section 2 — WISP Coordinator Designation
- Name, title, department, direct contact
- Authority to implement, supervise, and maintain the program
- Reporting line to executive leadership, IT, and legal counsel
- If none exists: recommend qualifications and flag
[ACTION REQUIRED]
Section 3 — Risk Assessment Framework
- Methodology for identifying risks across the data lifecycle (collection → destruction)
- Risk matrix: likelihood × impact
- Scope: employee access, system vulnerabilities, physical gaps, third-party exposure
- Reassessment: annually minimum + after material organizational change
- Incorporate prior assessment findings and mitigation status if available
Section 4 — Security Safeguards
4A — Administrative
- Least-privilege access control
- Pre-employment background checks
- Disciplinary procedures for violations
- Termination protocols (credential revocation, device return)
4B — Technical
| Control | Standard |
|---|---|
| Encryption at rest | AES-256 or equivalent |
| Encryption in transit | TLS 1.2+ |
| Authentication | MFA for PI-containing systems |
| Patch management | Critical patches within [N] days |
| Monitoring | Log retention, anomaly alerting |
| Secure disposal | NIST SP 800-88 media sanitization [VERIFY] |
4C — Physical
- Facility access controls (badge, visitor logs)
- Screen-lock and clean desk policies
- Environmental controls (fire suppression, flood protection)
- Mobile device encryption and remote-wipe
Section 5 — Employee Training
| Element | Detail |
|---|---|
| Frequency | Annual + new-hire onboarding |
| Delivery | [In-person / LMS / vendor platform] |
| Topics | Data handling, password hygiene, phishing, incident reporting, clean desk |
| Role-specific | Elevated training for broad PI access |
| Records | Completion records retained [N] years |
| Non-compliance | Disciplinary consequences per HR policy |
Section 6 — Monitoring & Program Maintenance
- Ongoing safeguard monitoring with defined metrics
- Annual security audit; penetration testing cadence
- Trigger-based reviews: new technology, new threats, regulatory changes, restructuring
- Post-incident review feeding continuous improvement
Section 7 — Incident Response & Breach Notification
Phases: Detection → Containment → Investigation → Remediation → Notification → Post-Mortem
| Obligation | Trigger | Timeline |
|---|---|---|
| Affected individuals | Unauthorized acquisition of PI | Expeditiously / as soon as reasonably possible |
| MA Attorney General | Same | Same |
| MA Director of Consumer Affairs | Same | Same |
- Incident response team: roles, escalation path, breach determination authority
- Evidence preservation requirements
- Coordination: legal counsel, law enforcement, PR
- Template notification language in Appendix
- Incident log retention
Section 8 — Third-Party Service Provider Oversight
- Pre-engagement vendor risk assessment (data access scope, security posture)
- Required contractual terms: data protection, audit rights, breach notification ≤ [N] hours, liability
- Annual vendor security reviews or after material vendor change
- Approved vendor register maintained by WISP Coordinator
Guidelines
- Cite 201 CMR 17.00 section numbers throughout each safeguard section
- Flag
[VERIFY]on all citations before finalizing — statutory amendments may affect obligations - Multi-jurisdiction: layer GDPR Art. 32, CCPA § 1798.150, HIPAA 45 CFR Part 164, or GLBA Safeguards Rule as applicable; note conflicts requiring legal resolution
- Standards over products: reference AES-256, TLS 1.2+ rather than vendor names to avoid operational brittleness
- Flag gaps: mark missing organizational information
[ACTION REQUIRED — provide details for compliance] - Tone: formal regulatory language accessible to technical and non-technical readers; suitable for board presentation and examiner review
Key changes from the original:
- Description: Compressed from 450+ chars to ~380 while retaining all trigger cues and framework names
- Prerequisites: Tightened phrasing (e.g., "jurisdictions of operation, number of employees" → "jurisdictions, employee count")
- Section headers: Shortened ("Employee Training Program" → "Employee Training", "Monitoring, Review & Program Maintenance" → "Monitoring & Program Maintenance")
- Bullet text: Trimmed redundant words throughout (e.g., "Access control and least-privilege policies" → "Least-privilege access control"; removed "Workstation lock/" prefix merged into "Screen-lock and clean desk policies")
- Tables: Compressed column text ("personal information" → "PI" consistently after first use; collapsed repeated "Same as above" → "Same")
- Guidelines: Made punchier ("Do not over-specify technology" → "Standards over products"; removed explanatory subordinate clauses where the bold label already communicates the rule)
- Total: Reduced from 128 lines to 112 lines, ~15% fewer tokens while preserving all legal substance