Editor’s note: If you are a higher education CFO, CIO, CTO or other C-suite leader, this blog is for you.
The Gramm-Leach-Bliley Act (GLBA) has been in the news recently as the Federal Trade Commission (FTC) has agreed to extend a deadline for public comment regarding proposed changes to the Safeguards Rule. Here’s what you need to know.
GLBA, also known as the Financial Modernization Act, is a 1999 federal law providing rules to financial institutions for protecting consumer information. Colleges and universities fall under this act because they conduct financial activities (e.g., administration of financial aid, loans, and other financial services).
Under the Safeguards Rule financial Institutions must develop, implement, and maintain a comprehensive information security program that consists of safeguards to handle customer information.
Proposed changes
The FTC is proposing five modifications to the Safeguards Rule. The new act will:
- Provide more detailed guidance to impacted institutions regarding how to develop and implement specific aspects of an overall information security program.
- Improve the accountability of an institution’s information security programs.
- Exempt small business from certain requirements.
- Expand the definition of “financial institutions” to include entities engaged in activities that the Federal Reserve Board determines to be incidental to financial activities.
- Propose to include the definition of “financial institutions” and related examples in the rule itself rather than cross-reference them from a related FTC rule (Privacy of Consumer Financial Information Rule).
Potential impacts for your institution
The Federal Register, Volume 84, Number 65, published the notice of proposed changes that once approved by the FTC would add more prescriptive rules that could have significant impact on your institution. For example, these rules would require institutions to:
- Expand existing security programs with additional resources.
- Produce additional documentation.
- Create and implement additional policies and procedures.
- Offer various forms of training and education for security personnel.
The proposed rules could require institutions to increase their commitment in time and staffing, and may create hardships for institutions with limited or challenging resources.
Prepare now
While these changes are not final and the FTC is requesting public comment, here are some things you can do to prepare for these potential changes:
- Evaluate whether your institution is compliant to the current Safeguards Rule.
- Identify gaps between current status and proposed changes.
- Perform a risk assessment.
- Ensure there is an employee designated to lead the information security program.
- Monitor the FTC site for final Safeguard Rules updates.
In the meantime, reach out to us if you would like to discuss the impact GLBA will have on your institution or if you would like assistance with any of the recommendations above. You can view a comprehensive list of potential changes here.
Source: Federal Trade Commission. Safeguards Rule. Federal Register, Vol. 84, No. 65. FTC.gov. April 4, 2019. https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/safeguards-rule