Thursday, March 04, 2010

201 CMR 17

I've been hearing some buzz about this legislation lately. For those that have not heard, 201 CMR 17 is a Massachusetts state law that specifies standards for the access, storage and management of personal information for state residents. (Full text of the law can be found here.)
While this blog has been more of a forum about Identity Management rather than Identity Theft, I still thought this was an interesting thing to discuss.

For the first time there is real comprehensive discussion of how data should be managed for the general public. While HIPAA and SOX mandate similar practices, this is the first legislation that says all personal information is important, not just the information as it pertains to specific groups or industries.

I do think that this is good for the Identity Management industry for a few basic reasons:
  • There's no such thing as too much security
  • Laws like this promote development of good access management infrastructure
  • It gives us a chance to reexamine existing role / access assignments
Of course this is always interesting to an old fashioned provisioning guy like me since it means we need to develop the existing User Life-cycle process to make sure that we are building in stronger access management as noted above. Laws like this will make us think again about concepts of:
  • Attestation / Recertification
  • Role Assignment / Segregation of Duties
Sometimes this will be an audit of what rights / permissions users have over various File System / ERP / Database objects. Sometimes it will be a complete reassignment of these rights.

Planning for complying with this law will require planning and forethought. The state of Massachusetts has provided a FAQ and a checklist to help begin the planning process. However, I think at the very least a complete review of current processes combined with a through gap analysis from a knowledgeable project team.

As I think more on this, I will be posting my thoughts on what the 201 CMR 17 planning process will look like.

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