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Directors’ College 2007 Protecting Your Customers’ Privacy A Directors’ Guide to GLBA

Directors’ College 2007 Protecting Your Customers’ Privacy A Directors’ Guide to GLBA. By David Abbott, FDIC IT Examiner. The Regulations. Gramm-Leach-Bliley Act -Section 501(b). FINANCIAL INSTITUTIONS’ SAFEGUARDS .

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Directors’ College 2007 Protecting Your Customers’ Privacy A Directors’ Guide to GLBA

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  1. Directors’ College 2007Protecting Your Customers’ PrivacyA Directors’ Guide to GLBA By David Abbott, FDIC IT Examiner

  2. The Regulations • Gramm-Leach-Bliley Act -Section 501(b) FINANCIAL INSTITUTIONS’ SAFEGUARDS. In furtherance of the policy in subsection (a), each agency or authority described in section 505(a) shall establish appropriate standards for the financial institutions subject to their jurisdiction relating to administrative, technical, and physical safeguards (1) to insure the security and confidentiality of customer records and information; (2) to protect against any anticipated threats or hazards to the security or integrity of such records; and (3) to protect against unauthorized access to or use of such records or information which could result in substantial harm or inconvenience to any customer.

  3. The Response • Interagency Guidelines Establishing Standards for Safeguarding Customer Information • FDIC - 12 CFR Parts 308 and 364 • OCC - 12 CFR Part 30 • FRB - 12 CFR Parts 208, 211, 225, and 263 • OTS - 12 CFR Parts 568 and 570

  4. Appendix B to Part 364—Interagency Guidelines Establishing Information Security Standards Table of ContentsI.  Introduction   A.  Scope   B.  Preservation of Existing Authority   C.  Definitions II.  Standards for Safeguarding Customer Information   A.  Information Security Program   B.  Objectives III.  Development and Implementation of Customer Information Security Program   A.  Involve the Board of Directors   B.  Assess Risk   C.  Manage and Control Risk   D.  Oversee Service Provider Arrangements   E.  Adjust the Program   F.  Report to the Board   G.  Implement the Standards

  5. Is It Working????

  6. Breaches, Breaches and more Breaches* Over 100 Million Records Compromised Your Company !?!? * Source - www.privacyrights.org

  7. Public Bank Breaches* • Bank of America • Wachovia • PNC • Westborough Bank, MA • Citi Financial • J.P. Morgan Chase & Co. • North Fork Bank, NY • Firstrust Bank • La Salle Bank • People's Bank • Vystar Credit Union, FL • Nat'l Institutes of Health Federal Credit Union • U.S. Bank • Sovereign Bank • FirstBank • West Shore Bank, MI • Premier Bank, MO • Chase Bank * Source - www.privacyrights.org

  8. Will you be on the list? Would you know if your data was stolen?

  9. Common GLBA Examination Findings Findings • Partial inventories • Incomplete risk assessments • Weak Board reporting • Limited ongoing training • Lack of monitoring of suspicious activity for all customer information systems • Incomplete incident response plans • Weak oversight on service providers / vendors • Limited validation

  10. Inventory • Identifying the data • Where is the data? • Network, Servicer, Back-up, Physical • Who can access the data? • Employees, Vendors, Consultants, Programmers • How can the data be accessed? • Intranet, Internet, Database, Application

  11. Risk Assessment • How is the data threatened? • Internal and External; New and Old Threats • How is the data protected? • Encryption, Access Control, Security Configurations • How is the data monitored? • When, How Often, Independently • How is the data disposed of? • Shredded, Electronically Destroyed --- • FACTA (FIL-130-2004)

  12. Risk Assessment Conclusions • Are you mitigating all threats? • Would breaches be caught? • Are changes detectable? • Are you doing enough?

  13. Board Reporting Report to the Board.  Each bank shall report to its board or an appropriate committee of the board at least annually. This report should describe the overall status of the information security program and the bank's compliance with these Guidelines. The report, which will vary depending upon the complexity of each bank's program should discuss material matters related to its program, addressing issues such as: risk assessment; risk management and control decisions; service provider arrangements; results of testing; security breaches or violations, and management's responses; and recommendations for changes in the information security program.

  14. Training • Determine the frequency • Most companies perform annually • All new employees • “One Size Doesn’t Fit All” • Combine with other training

  15. Monitoring • Need to determine what needs monitoring • Alert triggers should be established • Should be done by independent person • Should be automated

  16. Incident Reponses • Need a definitive program • Should address responses for any/all anticipated incidents • Should consider walk-throughs and/or preparatory activities FIL-27-2005

  17. Service Providers and Vendors • It is your responsibility to ensure that your Service Providers and Vendors adhere to GLBA • All GLBA procedures should be conducted for all Service Providers and Vendors that have access or can gain access to Non-Public Customer Data • Just having a Contract Clause is NOT enough FIL 81-2000

  18. Validation • Vital part • Needs to be done independently of the controls • Frequency and Scope should be determined by your Risk Assessment

  19. References • Appendix B to Part 364—Interagency Guidelines Establishing Information Security Standards • http://www.fdic.gov/regulations/laws/rules/2000-8660.html • FFIEC GLBA Online Resources • http://www.ffiec.gov/exam/InfoBase/start.htm • Privacy Rights Clearinghouse • http://www.privacyrights.org/ • FFIEC Handbooks • http://www.ffiec.gov/ffiecinfobase/html_pages/it_01.html

  20. Appendix B to Part 364—Interagency Guidelines Establishing Information Security Standards http://www.fdic.gov/regulations/laws/rules/2000-8660.html

  21. FFIEC GLBA Online Traininghttp://www.ffiec.gov/exam/InfoBase/start.htm

  22. Privacy Rights Clearinghousehttp://www.privacyrights.org/

  23. FFIEC Handbookshttp://www.ffiec.gov/ffiecinfobase/html_pages/it_01.html

  24. Contacts • Paul Nadeau – BOS FED Supervisory Examiner • Federal Reserve Bank of Boston • 600 Atlantic Avenue - PO Box 2076 • Boston, Massachusetts 02106 • (617) 973-5976 • Peter Carter - OCC Lead Technology Expert • Office of the Comptroller of the Currency • 112 Madison Avenue - Suite 400 • New York, NY 10016 • (212) 779-4537 • peter.carter@occ.treas.gov • Robert Sargent - FDIC IT Specialist • 15 Braintree Hill Office Park • Braintree, Massachusetts 02184 • (781) 794-5535 • rsargent@fdic.gov • Thomas J. Donahue - OTS IT Exam Manager • 10 Exchange Place - 18th Floor • Jersey City, New Jersey 07302 • (201) 413-7510 thomas.donahue@ots.treas.gov

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