Audit the GLBA Compliance Memo

About this interactive

The Gramm-Leach-Bliley Act (GLBA) of 1999 protects consumers of financial products. It covers any organization that provides financial services or products, such as bank accounts, brokerage accounts or loans, so a pawn shop or a car dealership that provides loans has to comply as well as a bank. The lesson gives the law's highlights. Its financial privacy rules give customers rights over how their information is shared. It sets up regulatory oversight, so the organization's program can be checked. And it asks for controls, put in place by a process that runs in order: identify the threats to the customer data you store, assess the risk of what could happen to it, then put in controls sufficient to secure it and lower that risk. This audit is a car dealer's memo on all of that. A dealer that decides it is exempt because it is not a bank. A law read as protecting the business rather than its customers. Customer details sold without a word to the customers. Controls bought before anyone listed a threat, and a risk step skipped. A law said to have nobody checking it, and penalties said to stop at the company. Penalties reach the leadership as well: up to $100,000 per violation for the organization, and fines of up to $10,000 for its officers and directors. Some lines look odd and are exactly right: a $300,000 exposure for three violations, and laptops encrypted because their theft was rated a high risk.

What you'll learn

Review a car dealer's Gramm-Leach-Bliley Act (GLBA) compliance memo and find the lines that break what the lesson taught about who the law covers and protects, customer privacy, the risk process, oversight and penalties
Give the fix for each problem found

Aligned to

CompTIA Security+

5.4 Summarize elements of effective security compliance.

ISC2 CISSP

1.4 Understand legal, regulatory, and compliance issues that pertain to information security in a holistic context

NIST NICE

K0678 Knowledge of privacy laws and regulations

NIST CSF

GV.OC-03 Legal, regulatory, and contractual requirements regarding cybersecurity — including privacy and civil liberties obligations — are understood and managed.

Key terms

Gramm-Leach-Bliley Act: A U.S. federal law that requires financial institutions to explain how they share and protect customers' private financial information, and to implement security programs to safeguard that data. The GLBA Safeguards Rule mandates specific information security controls for financial institutions.
Financial Privacy Rule: A GLBA provision that requires financial institutions to notify consumers about their data collection and sharing practices and provide opt-out rights.
Risk Assessment: The process of identifying, analyzing, and evaluating risks to determine their potential impact.
Compliance: The act of adhering to the laws, regulations, standards, and internal policies that govern how an organization handles data and security. Compliance programs use audits and controls to demonstrate that requirements are being met.

Topics

Glba Financial Privacy Regulatory Compliance Risk Assessment Interactive Spot The Error

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