Identify the information systems that contain non-public personal information
2
Create a risk management plan
3
Identify and assess risks to customer information in each operational area
4
Conduct an information security risk assessment
5
Develop a GLBA compliance policy
6
Establish a security program to protect the customer information
7
Develop controls to manage identified risks
8
Approval: Risk Management Team
9
Implement a training program for employees
10
Monitor, audit, and test the information security program
11
Establish procedures for responding to incidents and breaches of security
12
Review and update the GLBA compliance policy regularly
13
Ensure the third-party service providers are compliant with GLBA
14
Approval: Head of Cybersecurity
15
Prepare and update a written security program
16
Test the effectiveness of the security program
17
Approval: Compliance Officer
18
Prepare and submit the annual report to the board of directors
19
Review and update training materials
20
Maintain required records of compliance activities
Identify the information systems that contain non-public personal information
This task involves identifying all the information systems within the organization that store non-public personal information. The task aims to ensure that all systems containing sensitive data are identified and accounted for in order to develop appropriate security measures. The task requires conducting a thorough analysis of the organization's IT infrastructure and identifying all relevant systems.
1
Database
2
Network server
3
Cloud storage
4
Application software
1
Data encryption
2
Access controls
3
Audit logging
4
User authentication
5
Backup and recovery
Create a risk management plan
This task involves creating a comprehensive risk management plan to address potential risks to customer information. The plan should identify and assess risks, establish controls to mitigate those risks, and establish a monitoring and reporting system to ensure continuous compliance. The goal is to develop a proactive approach to risk management that protects customer information from both internal and external threats.
1
Identify potential risks
2
Evaluate likelihood and impact of risks
3
Determine risk prioritization
4
Develop risk mitigation strategies
Identify and assess risks to customer information in each operational area
This task requires identifying and assessing potential risks to customer information in each operational area of the organization. The goal is to ensure that all potential risks are identified and assessed so that appropriate controls can be implemented to mitigate those risks.
1
Finance
2
Human resources
3
Information technology
4
Marketing
5
Sales
1
Data breaches
2
Unauthorized access
3
Insider threats
4
Physical theft or loss
5
Vendor vulnerabilities
Conduct an information security risk assessment
This task involves conducting a comprehensive information security risk assessment to identify and assess potential risks to customer information. The goal is to assess the organization's overall security posture and identify any vulnerabilities or weaknesses that could be exploited by malicious actors.
1
Asset inventory
2
Threat identification
3
Vulnerability assessment
4
Likelihood and impact assessment
5
Risk prioritization
Develop a GLBA compliance policy
This task involves developing a GLBA compliance policy that outlines the organization's commitment to protecting customer information and complying with GLBA regulations. The policy should include the organization's objectives, responsibilities, procedures, and best practices for ensuring compliance.
Establish a security program to protect the customer information
This task requires establishing a comprehensive security program to protect customer information. The program should include policies, procedures, and controls designed to safeguard customer information from unauthorized access, use, disclosure, alteration, or destruction.
Develop controls to manage identified risks
This task involves developing controls to manage and mitigate the risks identified in the risk assessment process. The controls should be designed to prevent, detect, and respond to potential breaches or unauthorized access to customer information.
1
Access controls
2
Encryption
3
Firewalls
4
Intrusion detection and prevention systems
5
Incident response plan
Approval: Risk Management Team
Will be submitted for approval:
Create a risk management plan
Will be submitted
Identify and assess risks to customer information in each operational area
Will be submitted
Conduct an information security risk assessment
Will be submitted
Develop a GLBA compliance policy
Will be submitted
Establish a security program to protect the customer information
Will be submitted
Develop controls to manage identified risks
Will be submitted
Implement a training program for employees
This task requires implementing a training program to educate employees on GLBA compliance requirements, security policies and procedures, and best practices for protecting customer information. The training program should be designed to ensure that all employees are aware of their responsibilities and understand how to handle customer information securely.
Monitor, audit, and test the information security program
This task involves implementing a system for monitoring, auditing, and testing the organization's information security program. The goal is to ensure that the program remains effective and compliant with GLBA regulations and to identify and address any potential vulnerabilities or weaknesses in a timely manner.
1
Security audits
2
Vulnerability scanning
3
Penetration testing
4
Incident response drills
5
Compliance reviews
Establish procedures for responding to incidents and breaches of security
This task requires establishing procedures for responding to security incidents and breaches of customer information. The procedures should include steps to take in the event of a breach, including notifying affected customers, conducting internal investigations, and cooperating with law enforcement and regulatory authorities.
Review and update the GLBA compliance policy regularly
This task involves periodically reviewing and updating the organization's GLBA compliance policy to ensure that it remains current and aligned with changing regulatory requirements and industry best practices. The goal is to ensure that the policy continues to effectively guide the organization in protecting customer information.
Ensure the third-party service providers are compliant with GLBA
This task requires ensuring that all third-party service providers who have access to customer information are compliant with GLBA regulations. The goal is to ensure that customer information is adequately protected even when it is shared with external parties for purposes such as data processing or storage.
1
Cloud service providers
2
Data processing vendors
3
IT consultants
4
Legal service providers
5
Outsourced call centers
1
Security assessments
2
Contractual obligations
3
Ongoing monitoring
4
Breach notification agreements
5
Auditing rights
Approval: Head of Cybersecurity
Will be submitted for approval:
Implement a training program for employees
Will be submitted
Monitor, audit, and test the information security program
Will be submitted
Establish procedures for responding to incidents and breaches of security
Will be submitted
Review and update the GLBA compliance policy regularly
Will be submitted
Ensure the third-party service providers are compliant with GLBA
Will be submitted
Prepare and update a written security program
This task involves preparing and periodically updating a written security program that details the organization's policies, procedures, and controls for protecting customer information. The program should provide clear guidance to employees on how to handle and protect customer information and should reflect the current state of the organization's security practices.
Test the effectiveness of the security program
This task requires periodically testing the effectiveness of the organization's security program to ensure that it is adequately protecting customer information. The testing may include vulnerability scanning, penetration testing, and other assessments to identify any vulnerabilities or weaknesses that need to be addressed.
1
Vulnerability scanning
2
Penetration testing
3
Security awareness training
4
Social engineering testing
5
Intrusion detection system testing
Approval: Compliance Officer
Prepare and submit the annual report to the board of directors
This task involves preparing and submitting an annual report to the organization's board of directors regarding the status of GLBA compliance and the effectiveness of the organization's security program. The report should provide an overview of compliance activities, identified risks, control measures, and any incidents or breaches that occurred during the reporting period.
Review and update training materials
This task involves periodically reviewing and updating the organization's training materials for employees regarding GLBA compliance and the handling of customer information. The goal is to ensure that the training materials remain current, relevant, and effective in educating employees on their responsibilities for protecting customer information.
Maintain required records of compliance activities
This task requires maintaining records of all compliance activities related to GLBA regulations. The records should include documentation of risk assessments, security program development and implementation, training records, incident response logs, and any other relevant compliance documentation.