Heads up financial institutions: the Federal Trade Commission (FTC) announced the first cybersecurity updates to the Gramm Leach-Bliley Act (GLBA) Safeguards Rule since 2003. The new rule strengthens the required security safeguards for customer information. This includes formal risk assessments, access controls, regular penetration testing and vulnerability scanning, and incident response capabilities, among other things.
Several of these changes go into effect in November 2022, to provide organizations time to prepare for compliance. Below, we’ll detail the changes in comparison to the previous rule.
Background on the Safeguards Rule
GLBA requires, among other things, a wide range of “financial institutions” to protect customer information. Enforcement for GLBA is split up among several different federal agencies, with FTC jurisdiction covering non-banking financial institutions in the Safeguards Rule. Previously, the Safeguards Rule left the implementation details of several aspects of the information security program up to the financial institution, based on its risk assessment.
The Safeguards Rule broad definition of “financial institutions” includes non-bank businesses that offer financial products or services — such as retailers, automobile dealers, mortgage brokers, non-bank lenders, property appraisers, tax preparers, and others. The definition of “customer information” is also broad, to include any record containing non-public personally identifiable information about a customer that is handled or maintained by or on behalf of a financial institution.
Updates to the Safeguards Rule
Many of the other updates concern strengthened requirements on how financial institutions must implement aspects of their security programs. Below is a short summary of changes. Wher ..
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