Any data security program has to have three critical components. Those key components are the following:

First; risk assessment. You must test, retest, and retest your systems (including your staff) for gaps and vulnerabilities. Hackers are very sophisticated. Do what you can to stay ahead of the curve on understanding the risks to your systems and staff.

Second; training. You have to train everyone in your organization top to bottom on your data security protocols. When new protocols are rolled out, you have to train again. A well-trained staff can help you avoid such things as phishing scams and missteps in the event of a breach.

Third; an incident response plan. An incident response plan is like insurance; you make a large investment that you hope you never have to use. If you have a breach, then you have to have a detailed plan on what you are going to do about it. The plan should detail what you will do in the event of a breach vis a vis your regulators, your employees and your customers, how you will fix the gap and prevent it from happening again.

If your firm does not have these key elements in its data security program, you have set yourself up for disaster. Take the time, spend the funds necessary; protect yourself and your clients.