“A requirement to establish and maintain a comprehensive information security program, designed to protect the security, confidentiality, and integrity of personal information…” Sound familiar?

This is nothing new to those who have been bringing their businesses into compliance with the Massachusetts Standards for the Protection of Personal Information of Residents of the Commonwealth (the “Standards”), and for companies covered by the Standards and struggling with compliance, the latest Federal Trade Commission draft consent order should provide yet another impetus to get the required program in place.