About Us | Contact Us
View Cart

Are You Ready to Discuss the GLBA?

By Dan Hadaway | Thursday, January 21, 2021 - Leave a Comment

A long overdue update, but an update nonetheless. . .


Another one of those Dan’s New Leaf Posts, meant to inspire thought about IT Governance . . . .


“To respond to heightened cybersecurity threat,” as they said, in fourth quarter of 2021, the Federal Trade Commission (FTC) published changes to the 2003 GLBA Safeguards Rule (Rule 314.4 (c) (3) for you compliance geeks). That new rule went into effect on 01/12/22.

It’s surreal that it has taken so long “to respond to heightened threats.”  After all, the FTC updates their rules once every twenty years, whether needed or not!

The changes bring the rule into alignment with modern practices and frameworks.  The rule still applies to all financial institutions, and also covers the fintech companies who have been avoiding scrutiny.  In reading the rule, we feel banks who are doing well in their examinations should be in good shape.

Still, if you have been delaying controls due to gray areas in the FFIEC guidance, the rule makes certain things clear.  Multi-Factor Authentication (MFA) is no longer an option.  Personally Identifiable Information (PII) will be encrypted at rest as well as in motion.  Not that it’s new for banks, but we of course like that system monitoring is spelled out in the new rule.  We’re disappointed the Incident Response Planning part of the new rule does not require incident response plans for organizations under 5,000 customers . . . the FTC needs to read The One Test.  Finally, we feel the rule is further promoting zero trust principles.  MSSPs and IAM providers are definitely happy with these changes.  In fact, they are saying “finally!”

The rule establishes specifics in the following areas:

  • Risk Assessments and Inventory of Systems and Data
  • Access Controls include MFA
  • Encryption of data in motion and at rest
  • Change Management
  • Data Destruction
  • Vendor Risk Management
  • Incident Response for FI’s with more than 5,000 customers
  • And, of course, our favorite: System Monitoring

We want to make sure our Clients are aware of this change, it may spark conversation in your next examination or audit.

I can’t wait for the next update!  I wonder, is it currently scheduled for 2042??


Original article by Dan Hadaway CRISC CISA CISM. Founder and Managing Partner, infotex

“Dan’s New Leaf” is a “fun blog to inspire thought in the area of IT Governance.”


Speaking of safety. Visit offerings.infotex.com to reach out to us and see how infotex can make your financial institution safer!


same_strip_012513


 

Latest News
    The Four Basic Truths of System Security Webinar-Video The last thirty years have seen an evolution of frameworks, laws, and assessment approaches to information security which can intimidate the management team with their complexity. This webinar will discuss the four basic truths of system security regardless of frameworks or approach, and eight control systems to […]
    Community Banking and their layers of security. . . Michael Hartke’s first post as Executive Vice President! Thinking back to my first talk to security professionals in community banking almost 10 years ago, the question continues to this day. First some background… infotex was moderating the Indiana Bankers Association Security Conference when one of the […]
    Reasons why we should be considered! infotex provides a number of services that can be checked out if you click over to offerings.infotex.com! We even made a movie with all the reasons why infotex should be your next MSOC!  
    infotex and GoTo To all infotex managed security service Clients: As recently reported by major news outlets there was a data breach affecting GoTo (formerly LogMeIn) wherein attackers stole encrypted backups containing customer information in November 2022.  Based on the advisory from GoTo the products they offer that are affected include LogMeIn Pro, LogMeIn Central, […]
    An option for increasing security for ALL organizations. . . The threat landscape is evolving daily, and it is becoming increasingly difficult for even large organizations providing cyber defense services to keep up. As Brandao (2021) notes, it is important for organizations to adapt holistic technologies that can correlate all attack events. Therefore, developing XDR […]
    Another awareness poster for YOUR customers (and users).  Now that we have our own employees aware, maybe it’s time to start posting content for our customers! Check out posters.infotex.com for the whole collection! Download the large versions here: Awareness Poster (Portrait) Awareness Poster (Landscape) You are welcome to print out and distribute this around your […]
    A relic of the internet’s less secure past, many small firms struggle to secure their email systems… An article review. With a great deal of cybersecurity related news focused on new threats and similarly new techniques aimed at combating them, it can be easy to forget some of the older threats that have never gone […]
    Seven Trends . . . …that small bank Information Security Officers face in 2023 Another one of those Dan’s New Leaf Posts, meant to inspire thought about IT Governance . . . . Welcome to the Magnificent Seven, my annual predictive article about the seven trends in technology that will impact the Information Security Officers of […]
    System Security and Cybersecurity are not the same thing. . . Another one of those Dan’s New Leaf Posts, meant to inspire thought about IT Governance . . . . Regarding “information security,” the last thirty years have seen an evolution of frameworks, laws, and assessment approaches which intimidate the management team with their complexity.  […]
    The cryptographic algorithm is vulnerable to attack and is no longer considered secure… An article review. NIST has announced that it plans to retire the SHA-1 cryptographic algorithm by the end of 2030, citing multiple vulnerabilities in the standard, effectively ending its use after nearly 30 years.  Introduced in 1995, SHA-1 used a 160-bit hash […]