The GLBA Act
Companies follow some regulations that will help them to improve security provision on the information they are keeping. They are involved in providing the practices and guidance of their regulatory depending on the type of industry they are operating. If the organization does not comply with these regulations it may lead to being heavily fined or increase in information breaching. Companies that offer financial services and products such as loans, financial advice and insurance services are can comply with the Gramm- Leach- Bliley- Act (GLBA). The regulation requires that the financial institutions should explain to their consumers their information sharing practices and how they safeguard the sensitive data of their clients.
Compliance framework of GLBA
GLBA is a regulation that dictates how the organization should collect and how they should share the information. It’s a rule that requires high confidentiality of the clients’ information such as the account number, social security number as well as the credit history of the client. Therefore, it’s a regulation that requires the information of the organization’s customers to be protected against any threat or being disclosed to the third party. All the companies under GLBA are must inform their consumers about their information-sharing practice as well as informing consumers their rights about their information and hence the organization will have complied with the GLBA framework.
Current Risk Management Practices
Every organization is surrounded by risks that may have a potentially negative effect on the organization once it occurs. Therefore, the organization are required to have risk management practices that will help the organization to prevent its reputation or have that great effect to the organization once it happens. All the financial institution under GLBA may implement the following risk management practices; listing of each technology and all the vendor services and categorizing them depending with the data they process or stores, secondly they list the threats and vulnerability of each technology land identify the specific measures to be put in place for each technology. Thirdly, it involves categorizing of controls and defining the control adequacy and the residual risk as also applying them to each technology. Finally, the GLBA risk assessment they usually create a report that will show the vulnerability, controls and risk rating for each technology.
A diagram related to the common workflow of information and decisions at the major levels within the organization.
The critical cybersecurity that should be put in place to ensure compliance with the GLBA regulation.
The following are the steps or principles that can be put in place to ensure compliance with the GLBA regulations.
Understanding the regulation and how it applies to the organization. It’s the first step that every person will first research on to understand the Act through the help of the legal. It will help one to comply with the rule since they have a good foundation about the Act.
The second requirement is conducting a risk assessment. Risk assessment aims to identify threats and vulnerability of the information in the system. Therefore, the external examiner will test the compliance of an organization to GLBA by evaluating its risk assessment. Where they ensure that every technology assesses its risk and the vulnerability of its system. The other need is to ensure that all effective control measures are in place. A company will be perceived to have complied with the GLBA rule if all its threats match with the control measures that the company puts in place. The other thing that a company should consider is to protect themselves from insider threats. The company should be keen with the employees who compromise the company rules easily since they are the main threat to the organization. The management of the company should ensure that they are regular training of the employees and good communication about security policies. Since GLBA concentrates most with the prevention of the information of the consumers.
For a company to comply with the GLBA rule they should also ensure that they are using the service provider that is GLBA compliant. For instance, an institution that is using NPI for storage or processing will be complying with this rule. Since NPI is a service provider who is under GLBA scope. Where the management of the company should ensure that they provide the appropriate safeguard in place and have a written information security plan. Another need is to ensure that the organization is meeting all the privacy rule requirements. The leaders of the organization should ensure that the consumer is provided with clear information about the NPI information to be collected and creating awareness about the third party accessing the information of the client. They should also keep on updating their disaster- recovery (DR) and the business continuity plan (BCP). It involves explaining to the examiner the necessary steps that the organization will put in place to ensure in case a risk happens in the organization; linking of the information to unauthorized people. How will they react to disruptions of the business activities that will happen when the information breaches. The other factors include preparing a written security plan, writing a report to the board accompanied with receipts and lastly is reviewing, revising and improving the regulations.
In conclusion, GLBA is an Act that ensures that all the financial institution under it are ensuring the protection of the information of the client. The act involves implementation o the following three elements; the privacy rule which regulates the collection of the information and the use of NPI, safeguard rule where they require the financial institutions to implement a security program to protect all the information in NPI and lastly involves pretexting provisions which ensure NPI is protected from being accessed by unauthorized people.