How to Build Your WISP – Step 1: Establish Your Information Security Policy
When it comes to cybersecurity, small business owners often hear about the importance of having a Written Information Security Plan (WISP). But let’s clear up a common misconception: a WISP is not just a document you fill out and forget. It’s a framework that guides how your business protects sensitive information and manages security risks. And the first step to building a real WISP? Establishing your Information Security Policy.
What Is an Information Security Policy?
Think of your Information Security Policy as the foundation of your WISP. It sets the rules and expectations for how your business handles, stores, and protects information. Without it, you don’t have a security plan—you just have a list of unconnected tasks.
Why Do You Need One?
An Information Security Policy helps:
Define how your business protects sensitive data.
Set expectations for employees regarding security behaviors.
Show regulators and clients that you take security seriously.
Reduce the risk of data breaches and cyber threats.
Meet legal and regulatory requirements such as the Gramm-Leach-Bliley Act (GLBA) and the FTC Safeguards Rule, which require businesses handling sensitive financial information to have a formal WISP.
What Should Your Information Security Policy Include?
A solid Information Security Policy doesn’t have to be long or full of legal jargon. Keep it practical and tailored to your business. Here are the key components:
1. Purpose & Scope
Explain why the policy exists and what it covers. Example:
This policy outlines the security measures our business takes to protect sensitive customer and company data from unauthorized access, loss, or theft. It applies to all employees, contractors, and third-party service providers handling sensitive data.
2. Roles & Responsibilities
Designate a qualified individual to oversee your security program, as required by the FTC Safeguards Rule. Define who is responsible for what:
Business Owner or Security Officer: Oversees and enforces security policies.
Employees: Follow security guidelines and report incidents.
IT Provider or Tech Support: Manages security controls, updates, and incident response.
3. Acceptable Use of Technology
Outline how company devices, email, and internet access should be used to minimize security risks. Example:
No sharing of work passwords.
No downloading unapproved software.
No clicking on suspicious links in emails.
All employees must sign an Employee/Contractor Acknowledgement of Understanding to confirm they understand and will follow security policies.
4. Data Protection & Access Control
Define how sensitive data should be handled. For example:
Only authorized employees can access customer records.
All sensitive files must be encrypted.
Multi-factor authentication (MFA) is required for key accounts.
Maintain an inventory of hardware and systems that store Personally Identifiable Information (PII) to track where sensitive data is stored and processed.
5. Incident Reporting
Provide a simple process for employees to report security incidents. Example:
If you suspect a security issue, email [designated contact] immediately.
Do not attempt to fix security breaches on your own.
Implement a Security Breach Notification Plan to ensure timely reporting of security incidents to authorities and affected individuals, as required by law.
6. Regular Reviews & Updates
Security policies need to evolve. Set a schedule to review and update your policy at least once a year.
The Data Security Coordinator (DSC) should conduct an annual security review to ensure policies remain relevant.
Employees must complete security training and sign an updated acknowledgment each year.
Changes in business operations, regulations, or security threats should trigger a policy review.
How Do I Put My Information Security Policy into Action?
Creating the policy is just step one. Now you need to make sure it actually gets used:
Communicate it – Share the policy with all employees.
Get buy-in – Explain why it matters and how it protects the business.
Make it easy to follow – Avoid complicated legalese; use plain language.
Train employees – Go over key points in onboarding and annual security training.
Store securely – Keep a copy in an accessible format (PDF or Word) and store it in a secure location.
Wrapping Up
If you're feeling overwhelmed by the process of building your WISP, you're not alone. At Zeus InfoSec, we understand that creating a security framework from scratch can be challenging, especially when juggling compliance requirements and daily business operations. Our resources and expertise can help you build a WISP that is both practical and effective, ensuring that security becomes an integrated part of your business, not just a document sitting on a shelf. Your Information Security Policy is the backbone of your WISP. It’s not just a formality—it’s the guiding document that informs every other security decision you make. A well-structured policy ensures compliance, protects customer data, and reduces risks.
In the next post, we’ll cover how to assign Roles, Responsibilities, and Permissions to ensure security isn’t just one person’s job, but a shared responsibility.
Need help creating your policy? Keep following this series for more step-by-step guidance!
