GLBA/FFIEC Compliance Solutions
Financial Services Regulation
GLBA, FFIEC and the protection of consumer financial information
Financial services regulations on information security, initiated by the Gramm-Leach-Bliley Act (GLBA), require financial institutions in the United States to create an information security program to:
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As a critical technology service provider, SecureWorks undergoes periodic examinations by the member agencies of the Federal Financial Institutions Examination Council (FFIEC), as well as annual Statement on Auditing Standard 70 (SAS-70) Type II audits. |
- "Ensure the security and confidentiality of customer information;
- Protect against any anticipated threats or hazards to the security or integrity of such information; and
- Protect against unauthorized access to or use of customer information that could result in substantial harm or inconvenience to any customer."
The Federal Financial Institutions Examination Council (FFIEC) has supported this mission by providing extensive, evolving guidelines for compliance. These are collected in the FFIEC IT Examination Handbook (html version; pdf version), as well as updates issued by the five enforcing agencies.
Who's in Charge
The Financial Services Modernization Act, a.k.a. the Gramm-Leach-Bliley Act (GLBA) of 1999, first established a requirement to protect consumer financial information. The Federal Financial Institutions Examination Council (FFIEC) is charged with providing specific guidelines for evaluating institutions for compliance with GLBA (among other things). Enforcement falls to five agencies, the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), the Office of the Comptroller of the Currency (OCC), and the Office of Thrift Supervision (OTS). Different agencies may have additional requirements, such as this recent FDIC directive.
SecureWorks supports GLBA/FFIEC compliance in the following ways:
Section |
Summary |
Solutions |
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Security Process |
Implement an ongoing security process and institute appropriate governance for the security function, assigning clear and appropriate roles and responsibilities to the board of directors, management and employees. |
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Information Security Risk Assessment |
Maintain an ongoing information security risk assessment program that considers assets, data, threats to prioritize risk. |
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Information Security Strategy |
Develop a strategy that defines control objectives and establishes an implementation plan. The security strategy should include controls, processes and policies. |
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Security Controls Implementation
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Establish security controls to:
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Security Monitoring |
Financial institutions should gain assurance of the adequacy of their risk mitigation strategy and implementation by monitoring network and host activity to identify policy violations, anomalous behavior, unauthorized configuration and other conditions which increase the risk of intrusion or other security events. They should also analyze the results of monitoring to accurately and quickly identify, classify, escalate, report, and guide responses to security events; and responding to intrusions and other security events and weaknesses. |
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Security Process Monitoring and Updating |
Financial institutions should continuously gather and analyze information regarding new threats and vulnerabilities, actual attacks on the institution or others, and the effectiveness of the existing security controls. They should then use that information to update the risk assessment, strategy, and implemented controls. |
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