Customer data needs to be encrypted both in transit and at rest. Fortunately, many software applications have system settings that can be configured to accomplish this at no cost. A review of the systems inventory should shed some light on where the data resides the requires encryption.
314.4 (c) (3)
Protect by encryption all customer information held or transmitted by you both in transit over external networks and at rest. To the extent you determine that encryption of customer information, either in transit over external networks or at rest, is infeasible, you may instead secure such customer information using effective alternative compensating controls reviewed and approved by your Qualified Individual;
Much like MFA most business software now offers encryption as a built-in feature. Implementation can be as easy as changing a setting at the administrator level of your software. If you need help setting up encryption at your dealership, Mosaic offers a free consultation and will provide recommendations for your encryption implementation. Often, if you are using a managed service provider they will be able to provide guidance and implement an encryption solution for you.