PC-1 Provide Clear Privacy Notices: Requires financial institutions to deliver clear, accessible privacy notices to customers, outlining data collection, sharing practices, and customer rights under GLBA.

• PC-1.1 Annual Notices

  Under the Gramm-Leach-Bliley Act (GLBA), financial institutions are required to provide annual privacy notices to their customers. These notices must clearly communicate how the institution collects, uses, and protects nonpublic personal information (NPI) and the customer’s rights regarding that information. The annual privacy notice should be provided on a yearly basis to ensure that customers are continuously informed about the institution's privacy practices.

• PC-1.2 Opt-Out Mechanisms

  Under the Gramm-Leach-Bliley Act (GLBA), financial institutions are required to provide their customers with the option to opt-out of certain types of information-sharing practices. This opt-out mechanism allows customers to prevent their nonpublic personal information (NPI) from being shared with non-affiliated third parties for purposes other than those directly related to providing financial services. This control ensures that customers have the ability to limit the dissemination of their personal information, thus enhancing their privacy rights.

• PC-1.3 Update Notices

  The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to keep their privacy notices up to date, reflecting any changes in their information-sharing practices or privacy policies. Financial institutions must update and deliver these privacy notices when there are material changes that affect the privacy of customers' nonpublic personal information (NPI). This ensures that customers are informed about how their data is being used, shared, and protected, and allows them to make informed decisions about their privacy preferences.

IR-1 Establish Incident Response Protocols: Requires financial institutions to develop and implement formal incident response protocols to address security breaches and ensure timely notification and remediation under GLBA requirements.

• IR-1.1 Develop Response Plan

  The "IR-1.1 Develop Response Plan" subcontrol under the Gramm-Leach-Bliley Act (GLBA) requires financial institutions to establish and develop an incident response plan to effectively address security breaches, including incidents involving nonpublic personal information (NPI). The plan should outline the steps the organization will take in response to data breaches or security incidents, ensuring a coordinated and systematic approach to containment, mitigation, investigation, and recovery.
  
  Having a robust response plan ensures that the institution is prepared to handle incidents swiftly and effectively, minimizing the impact on customers, the organization, and regulatory compliance. The plan must address critical factors such as notification requirements, investigation procedures, and the roles and responsibilities of key stakeholders.

IM-1 Notify Authorities of Breaches: Requires financial institutions to promptly notify relevant authorities, such as the FTC and regulators, of data breaches involving nonpublic personal information (NPI) under GLBA.

• IM-1.2 Customer Notification

  In the event of a breach involving nonpublic personal information (NPI) under the Gramm-Leach-Bliley Act (GLBA), financial institutions are required to notify affected individuals whose personal data has been compromised. This notification must be timely, clear, and provide information on the nature of the breach, the type of data exposed, and steps customers can take to protect themselves. The customer notification process is essential to comply with GLBA’s privacy and security provisions and to maintain customer trust.

• IM-1.1 FTC Notification

  In the event of a data breach involving nonpublic personal information (NPI) as defined under the Gramm-Leach-Bliley Act (GLBA), the financial institution must notify the Federal Trade Commission (FTC) as part of the regulatory compliance process. This notification serves to alert the FTC about the breach, ensuring the financial institution is taking the necessary steps to address the situation and that federal authorities are aware of potential threats to consumer privacy and financial security.

TPM-1 Oversee Third-Party Security: Requires financial institutions to assess, manage, and monitor third-party vendors' security practices to ensure the protection of customer data and compliance with GLBA requirements.

• TPM-1.1 Vendor Due Diligence

  Conduct thorough due diligence on third-party vendors before entering into agreements to ensure they meet security, privacy, and compliance standards required by the Gramm-Leach-Bliley Act (GLBA). This process involves assessing the vendor’s ability to safeguard customer information and identifying any potential risks associated with outsourcing services or sharing sensitive data.

• TPM-1.2 Contractual Obligations

  Ensure that third-party vendors are contractually bound to adhere to appropriate data protection measures, comply with GLBA requirements, and maintain security standards throughout the duration of their engagement. This includes including specific data protection clauses in contracts, clearly defining the vendor’s responsibilities, and establishing consequences for non-compliance.

• TPM-1.3 Monitor Vendor Compliance

  Implement a continuous monitoring program to assess third-party vendor compliance with data protection and security requirements under the Gramm-Leach-Bliley Act (GLBA). This includes tracking vendor performance, conducting audits, reviewing reports, and addressing non-compliance issues to ensure ongoing protection of sensitive customer data.

EA-1 Employee Training on Data Protection: Requires financial institutions to provide regular training to employees on safeguarding nonpublic personal information (NPI) and complying with data protection regulations under GLBA.

• EA-1.1 Training Sessions

  Develop and implement regular training sessions to educate employees on data protection principles, their roles in safeguarding customer information, and compliance requirements under the Gramm-Leach-Bliley Act (GLBA). These training sessions aim to ensure that employees are aware of data protection practices and understand how to identify and respond to security threats.

• EA-1.2 Role-Specific Training

  Provide role-specific training for employees to ensure they understand their unique responsibilities in protecting customer information and complying with the Gramm-Leach-Bliley Act (GLBA). This training is tailored to the specific duties of different job functions, focusing on relevant risks, tools, and procedures for safeguarding sensitive data.

• EA-1.3 Testing Knowledge

  Implement regular knowledge tests and assessments to evaluate employees' understanding of data protection principles, GLBA compliance requirements, and their specific roles in safeguarding customer information. These tests help to verify that employees retain the knowledge gained during training sessions and can apply it effectively in their daily tasks.

DP-1 Implement Robust Safeguards: Requires financial institutions to implement comprehensive safeguards, including technical, administrative, and physical controls, to protect customer data and ensure compliance with GLBA privacy requirements.

• DP-1.1 Technical Controls

  Implement robust technical controls to protect customer information from unauthorized access, use, disclosure, alteration, and destruction. These controls must align with best practices and regulatory requirements under the Gramm-Leach-Bliley Act (GLBA).

• DP-1.2 Administrative Controls

  Establish and maintain administrative controls, including policies, procedures, and training programs, to manage and oversee the protection of customer information. These controls ensure that employees and third parties adhere to the organization’s data protection standards in compliance with the Gramm-Leach-Bliley Act (GLBA).

• DP-1.3 Physical Controls

  Implement physical controls to safeguard customer information from unauthorized access, theft, or destruction. These controls are necessary to protect data stored in physical locations and prevent physical breaches that could compromise the confidentiality and integrity of sensitive information under the Gramm-Leach-Bliley Act (GLBA).

RM-1 Conduct Regular Risk Assessments: Requires financial institutions to regularly assess risks to customer data, identifying potential vulnerabilities and ensuring adequate measures are in place to mitigate those risks under GLBA.

• RM-1.1 Identify Risks

  Systematically identify risks to customer information by evaluating internal and external threats, vulnerabilities, and potential impacts. This process establishes the foundation for effective risk management and compliance with the Gramm-Leach-Bliley Act (GLBA).

• RM-1.2 Prioritize Risks

  Establish a structured process to evaluate and prioritize identified risks based on their likelihood and potential impact on customer information. Prioritization ensures that resources are allocated efficiently to address the most significant risks in alignment with GLBA requirements.

• RM-1.3 Mitigate Risks

  Implement appropriate measures to mitigate identified and prioritized risks to customer information. Risk mitigation strategies should align with the organization's risk tolerance, legal obligations under the Gramm-Leach-Bliley Act (GLBA), and best practices for safeguarding sensitive data.

GOV-2 Board of Directors or Senior Management Involvement: Ensures that senior management or the board is actively involved in overseeing and approving the institution’s information security and privacy practices under GLBA.

• GOV-2.1 Oversight and Approval

  Ensure that the Board of Directors or senior management actively oversees and approves the Information Security Program (ISP). This includes reviewing program objectives, assessing risks, allocating resources, and ensuring alignment with the Gramm-Leach-Bliley Act (GLBA) requirements and organizational goals.

GOV-1 Designate a Security Expert: Requires financial institutions to appoint a dedicated security expert to oversee and ensure the implementation of security measures protecting customer data under GLBA.

• GOV-1.1 Appoint Security Officer

  Appoint a qualified Security Officer to oversee the organization’s Information Security Program (ISP), ensuring compliance with the Gramm-Leach-Bliley Act (GLBA) and the effective implementation of security measures. The Security Officer acts as the central authority for managing and coordinating information security efforts across the organization.

• GOV-1.2 Establish Oversight Framework

  Develop and implement an oversight framework to monitor, evaluate, and guide the activities of the appointed Security Officer and the overall Information Security Program (ISP). The oversight framework ensures accountability, alignment with organizational goals, and compliance with the Gramm-Leach-Bliley Act (GLBA) requirements.

The GLBA control ISP-1 requires organizations to develop, implement, and maintain a comprehensive Written Information Security Program (WISP) to protect sensitive customer information from unauthorized access, misuse, or disclosure.

• ISP-1.1 Program Scope and Objectives

  Define and document the scope and objectives of the Information Security Program (ISP) to ensure it aligns with organizational goals, regulatory requirements, and risk management strategies. The scope should encompass all systems, processes, and data covered under the Gramm-Leach-Bliley Act (GLBA).

• ISP-1.2 Program Elements

  Identify and define the critical elements of the Information Security Program (ISP), ensuring that these elements provide a structured approach to safeguard customer information and comply with the Gramm-Leach-Bliley Act (GLBA). Program elements should include policies, processes, tools, and personnel required to manage and mitigate security risks effectively.