B005MKCGKK Information Security Risk Management Of GLBA Privacy And Service Provider Oversight
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Notably, the revised rules require policies and procedures to secure physical devices and to monitor activity of unauthorized user access or use of customer information. Financial institutions should obtain third-party assurances that existing control frameworks are operating and effective to determine how best to comply and what if any changes may be necessary in light of the rule change.
Financial institutions should carefully examine existing third-party vendor agreements to ensure that data transfers are secured and agreements impose the appropriate control frameworks and requirements consistent with the revised rules and already-existing regulatory requirements. Financial institutions should update and revise existing incident response plans to ensure the plan is appropriately calibrated to account for the rule changes.
Changes in the proposed amendments On March 5, the FTC narrowly voted to move forward with proposed amendments to these rules. Expanded requirements to oversee service providers The proposed changes would also expand the existing requirement to oversee service providers — financial institutions would have to periodically assess such service providers based on the information security risk they present and the adequacy of their safeguards.
Scope of proposed changes remains unclear A number of questions and issues remain unresolved by the proposed amendments, including whether the multifactor authentication requirements apply only to online access or also to in-person customer access at a branch or other physical location.
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