GLBA Compliance Checklist: 7 Steps to Comply With
When it comes to cybersecurity for financial institutions, creating a system that is GLBA compliant is essential. To ensure that your company is in-line with GLBA, here are seven steps to follow, as well as how Ostra can help protect your data.
The Gramm-Leach-Bliley Act (GLB Act or GLBA) is a set of laws that financial institutions must keep up with if they want to avoid serious penalties. Enacted in 1999, GLBA is a federal act that controls how financial institutions deal with individuals’ private information
GLBA consists of three distinct sections that financial institutions be careful to follow:
- The Financial Privacy Rule – Regulates the collection and disclosure of private financial information
- The Safeguards Rule – Stipulates that financial institutions must implement security programs to protect such information
- The Pretexting Provisions – Prohibit the practice of pretexting (accessing private information using false pretenses)
In addition, GLBA requires that financial institutions give their customers a written privacy notice that explains in detail their information-sharing practices.
GLBA Compliance Checklist
1. Understand GLBA and How it Affects Your Organization
First and foremost, it’s crucial that you review GLBA in its entirety. Many business owners will sit down with a lawyer and review the act in detail. This will help you gain a better understanding of how it applies to your financial institution. Understanding is always the first step towards compliance.
2. Conduct a Robust Risk Assessment
It’s important to understand where your financial institution currently sits as it pertains to GLBA compliance. The best way to do this is to work with an external examiner that can help you pinpoint where any GLBA-related weaknesses reside.
3. Identify and Improve Upon Your Internal Controls (Working With a SaaS Provider)
Whether you’ve failed a GLBA compliance test in the past or want to ensure you pass your first one, working with an experienced cybersecurity SaaS (Software-as-a-Service) provider is one of the best ways to do so. A quality SaaS provider will be able to install cybersecurity software that can effectively check all the boxes of GLBA compliance.
For a smoother process of achieving GLBA compliance—and improving your internal controls—working with a team like Ostra is a must.
4. Put in Place Roadblocks for “Insider Threats”
While outside threats like cybercriminals and hackers should always be considered when creating a robust cybersecurity plan that covers GLBA compliance, they are far from the only ones you need to be worried about.
Employees accidentally or even maliciously comprising your customers’ or clients’ financial information is an even bigger threat. To ensure you avoid insider threats to your organization, be thorough in your employee recruitment and filter out potential security risks. Also, keep your employees up-to-date on the latest security best practices.
5. Make Sure All Your Service Providers Are GLBA Compliant
If you rely on any service providers to help carry out your own service for your customers or clients, you should ensure that they are GLBA compliant as well. Never assume that they are, and make sure that they provide proof that they are safe to work with.
6. Review and Revise Your Privacy Rule Requirements to Ensure Compliance
To meet the privacy rule requirements, you must provide customers with a “clear and conspicuous” privacy notice that describes in detail what information is collected and for what purpose. In some instances, you’ll also need to provide an annual disclosure to customers. If you’re failing to meet those requirements, revise your privacy rule requirements.
7. Assess and Update Your Disaster Recovery Plan
GLBA also requires an incident response plan. So, make sure you have an IT disaster recovery and business continuity plan in place to show that you have all the precautions in place to mitigate a disaster.
How Ostra Can Help Your Organization Achieve GLBA Compliance
It’s normal to feel stressed about ensuring your business is compliant with all these regulations. At Ostra, we regularly work with financial groups to help secure their provide data, and we how to fast track the process of becoming compliant with the Gramm Leach Bliley Act. By simply implementing Ostra within your system, you’ll be well on your way to achieving compliance. We’ll fill in any of the gaps to ensure your clients’ information is protected. That’s our promise.
To protect your customer data and improve your data security, contact us today.