Compliance with GLBA has become a stumbling point for many businesses. The Gramm-Leach-Bliley Act was issued in 1999 to regulate data management, particularly in financial institutions. Its main focus is on transparency of data collection, safeguarding customer rights, minimizing security incidents, and properly responding to them, if any.
Failing to comply with the requirements can lead to severe consequences. But don’t worry. With this GLBA compliance guide, you’ll learn to mitigate all the risks and understand this act’s peculiarities.
GLBA Compliance Definition
The Gramm-Leach-Bliley Act is a 1999-imposed U.S. law requiring financial institutions to protect consumers’ personal information. It sets forth guidelines for customer financial privacy and safeguards. The GLBA safeguards rule checklist ensures organizations follow these rules, focusing on the security and confidentiality of customer data.
Even though this act can bring many inconveniences and raise multiple questions at first, you can handle it by addressing a trustworthy GLBA service provider. The professional will analyze the exact needs of your business and help you implement all the sufficient steps.
Data Covered by GLBA
The act’s main aim is to decrease the likelihood of informational breaches and help manage them if such instances occur. It also tries to minimize reputational and financial damages to particular institutions.
The act covers nonpublic personal information (NPI). This includes data provided by consumers to obtain financial products or services. NPI examples are:
- Names,
- Addresses,
- Birth dates,
- Biometrical data,
- Bank accounts,
- Education,
- Income,
- Tax information,
- etc.
The GLBA information security checklist ensures all this data is protected from unauthorized access and breaches. Institutions must also monitor and manage data sharing with third parties to comply with the act’s requirements.
Organizations Regulated by GLBA
It covers any institution involved with finance management, including all financial organizations that cannot disclose nonpublic personal information. In addition to the most obvious banks, brokers, and insurance, the law applies to companies that process loans and several other organizations.
Any institution which falls under the regulation must comply with it. However, specific US states still impose more stringent data privacy regulations. The examples here are California and Virginia.
Here’s the list of professionals and businesses subjected to the act:
- Accountants;
- Car rental companies;
- ATM operators;
- Hedge funds;
- Credit reporting organizations;
- Credit unions;
- Property appraisers;
- Retailers;
- Stockbrokers;
- etc.
Below is a standard GLBA compliance checklist that will help you ensure compliance. You can adapt it based on your organization’s needs.
Understand the Act and How It Affects Your Institution
In the first stage of this GLBA requirements checklist, you should understand all the peculiarities of the act. Some business owners closely examine their enterprise with a lawyer, which is the most appropriate approach. This way, they don’t miss a thing but get a clear view of how the regulation applies to their business.
Conduct a Risk Assessment
Now, you should understand how well your institution has already complied with the act. For risk assessment, you’ll usually have to invite independent financial advisory services to define and explain your strengths and weak points. The process may take some time because it requires a careful review of all the company departments and the completion of technical documentation on the current state of things. However, the result is totally worth it.
Improve Your Internal Controls
At this stage, it’s advisable to work with an experienced SaaS provider. Whatever your past experience with GLBA, you should be sure to implement all the current security controls this time.
The provider will install trustworthy cybersecurity software and ensure that your company has all the appropriate safeguards in place.
Collect Any Applicable Documents
Make sure to provide your reviewer with all the relevant information to allow them to define the sufficient steps. It may include:
- Systems inventory;
- Use Policy;
- Remote Access Policy;
- Firewall/Router/Switch Configuration;
- Data Retention and Disposal Procedures;
- Hiring Policy.
Mitigate the Risks
Once the assessment is completed, you should review and utilize all the steps your consultant came up with. You’ll commonly get a list of tasks to complete, resources to use, and controls that should be implemented.
Minimize Internal Threats
You should understand that GLBA primarily focuses on external threats such as cybercriminals or ransomware. However, some internal dangers are equally powerful and can be even more devastating.
But what does it mean? Some of your employees can compromise user data accidentally (or intentionally). Even though you cannot eliminate the danger completely, you can minimize it with the following measures:
- Be mindful of the people you hire and ensure they undergo rigorous checks.
- Conduct regular employee training programs to inform the staff of the latest data security trends. You can even invite outside coaches and lecturers to boost their awareness.
Check Your Service Providers for GLBA Compliance
If you employ outside services to conduct your activities, always check if those businesses are also compliant. Don’t take this for granted — take extra time to verify the information. It will bring you peace of mind and pay off in the long run.
Revise Your Privacy Rule Requirements
You cannot meet the act’s requirements without this step. This means you should properly inform your users on how you manage customers’ sensitive information and what types of data you use.
Sometimes, you may even need to provide annual disclosures to your customers.
Upgrade Your Disaster Recovery Plan
Unfortunately, data breaches can happen even if you comply with all the rules. That’s why you should have a reliable disaster recovery plan at hand (by the way, it’s also required by GLBA). Check out your current plan and upgrade it as needed. This way, you minimize the risks of financial and reputational damages to your business.
Conclusion
Adhering to the GLBA checklist is crucial for protecting customer information. In the long run, it is a matter of your company’s reputation. You can use this guide and adapt it as necessary to ensure ongoing compliance of the organization. Stay proactive in your efforts to maintain trust and security.
