To what extent should a brokerage with a website capable of handling personal information (e.g. credit card numbers) have to go to protect itself from “hackers”?
A. Assume that all personal information is sensitive and seek to achieve the highest level of security. For personal information held in electronic format, the Act suggests methods of protection that include the use of passwords and encryption. The standard by which you will be judged, however, will not be one of perfection but one that a reasonable person would consider appropriate in the circumstances.