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About The Toolbox Guidelines at a Glance: Safeguarding Customer Information Section 501(b) of GLBA requires federal banking agencies to establish appropriate standards for the administrative, technical, and physical safeguards for customers’ “nonpublic personal information.” To accomplish this congressional mandate, each agency has issued guidelines that require each bank to establish an information security program. These guidelines are separate and apart from the privacy regulations and notice requirements contained in Section 501 of GLBA. A bank’s information security program must be designed to 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 such information that would result in substantial harm or inconvenience to any customer. Because the guidelines closely mirror existing agency guidance, in many instances financial institutions will already have information security programs that identify and control risks to information and information systems. While the guidelines cover only “customer information” as that term is defined, the agencies encourage institutions to use the approach provided by the guidelines to protect all customer and bank records. The agencies have promulgated a set of uniform examination procedures that we have incorporated intended to assist examiners in assessing the level of compliance with the security guidelines that we have incorporated in “Guidelines at a Glance: Safeguarding Customer Information.” We have used these guidelines as a roadmap throughout this toolbox as a reference guide to the key questions and considerations confronting your institution as you refine your security program. The guidelines allow each institution the discretion to design an information security program that suits its particular size and complexity and the nature and scope of its activities. At the same time, each institution must demonstrate that its security program addresses the following: AMERICAN BANKERS ASSOCIATION Role of the Board of Directors. The board of directors or an appropriate committee of the board is responsible for approving the written information security program and overseeing the program’s development, implementation, and maintenance, including assigning responsibility for its implementation. At least once a year, management should provide a status report to the board or the appropriate committee. Identify and Assess Risk. The institution should first assess risks to its customer information. An institution’s risk assessment should identify reasonably foreseeable internal and external threats that could result in unauthorized disclosure, misuse, alteration, or destruction of customer information or customer information systems. Additionally, the risk assessment should consider the likelihood and potential damage of these threats, taking into consideration the sensitivity of customer information. Finally, the assessment should consider the sufficiency of existing policies, procedures, customer information systems, and other arrangements intended to control the risks identified. Manage and Control of Risk. The institution should design an information security program to control the identified risks, commensurate with the sensitivity of the information and the complexity and scope of the bank’s activities. The guidelines highlight eight security measures that institutions should consider and adopt if appropriate. The information security program also should include training for staff and regular testing of the key controls, systems, and procedures. The nature and frequency of the tests should be determined by the institution’s risk assessment. To ensure objectivity, tests should be conducted or reviewed by third parties or staff who are independent of those who develop or maintain the security programs. Oversee Service Provider Arrangements. Institutions also have an obligation to oversee their service providers. Institutions that use service providers should exercise appropriate due diligence in selecting them, including conducting a review of the measures taken by the service providers to protect customer information. The contract between the institution and the service provider must require the provider to implement appropriate measures designed to meet the objectives of the guidelines. Wherever indicated by an institution’s risk assessment, the institution should monitor its service providers to confirm they are implementing the agreed-upon security measures. As part of this monitoring, an institution should review audits, summaries of test results, or other equivalent evaluations of its service providers. Adjust the Program. Risks to customer information change over time with changes in technology, the sensitivity of customer information, internal or external threats to information, and the institution’s own business arrangements, such as mergers and acquisitions, alliances and joint ventures, outsourcing arrangements, and changes to customer information systems. Therefore, institutions should monitor, evaluate, and adjust, as appropriate, their information security program. The regulatory agencies AMERICAN BANKERS ASSOCIATION 2 expects institutions to make the appropriate changes to their information security programs before any changes are made to their customer information systems. Implement the Guidelines. The guidelines were effective on July 1, 2001. However, there is a two-year grandfathering provision for service provider contracts. Existing service provider contracts (namely, contracts entered into until March 5, 2001) do not have to be renegotiated to comply with the guidelines until July 1, 2003. The regulatory agencies have adopted uniform examination procedures intended to assist examiners in assessing the level of compliance with the guidelines. These procedures are designed to apply to a wide range of banks, and as such examiners have been instructed that certain procedures may not apply to smaller or less complex institutions. Institutions should be prepared to detail for examiners the reasons why a particular procedure is not applicable, based on the institutions size, complexity, or risk assessment. Guidelines At A Glance: Safeguarding Customer Information Key Questions or Considerations I. Determining The Involvement Of The Board. A. Has the board or its designated committee approved a written Corporate Information Security Program that meets the requirements of the Information Security Guidelines (guidelines)? B. If the board has assigned responsibility for program implementation and review of management reports to an individual or committee, do they possess the necessary knowledge, expertise and authority to perform the task? C. Does the program contain the required elements? 1. If more than one information security program exists for the institution, are the programs coordinated across organizational units? D. Determine the usefulness of reports from management to the board (or its designated committee). Does the report adequately describe the overall status of the program, material risk issues, risk assessment, risk management and control decisions, service provider oversight, results of testing, security breaches and management's response, and recommendations for program changes? 1. How often does the board (or its designated committee) review reports? E. Overall, do management and the board (or its designated committee) adequately oversee the institution's information security program? AMERICAN BANKERS ASSOCIATION 3 II. Evaluating The Risk Assessment Process. A. Review the risk assessment program. 1. How does the institution assess risk to its customer information systems and non-public customer information? 2. Has the institution evaluated the risk to the entire customer information system? 3. Has the institution used personnel with sufficient expertise to assess the risks to its systems and customer information on an enterprise-wide basis? 4. Is the risk assessment part of a formal risk assessment process with timelines and milestones? If not, how will management ensure timely completion? 5. Does the institution have a process for identifying and ranking its information assets (data and system components) according to sensitivity? How does it use this process in its risk assessment? B. Assess adequacy and effectiveness of risk assessment process. 1. Does the institution identify all reasonably foreseeable internal and external threats that could result in unauthorized disclosure, misuse, alteration, or destruction of customer information or customer information systems? 2. Does the institution support its estimate of the potential damage posed by various threats? 3. Review the institution’s existing controls to mitigate risks. Does the institution’s analysis consider the current administrative, physical, and technical safeguards that prevent or mitigate potential damage? 4. Does the institution use test results to support its assessment of the adequacy and effectiveness of those controls? C. Does the institution identify and prioritize its risk exposure, decide on the risks it must mitigate, and create a mitigation strategy? Is the decision to accept risks documented and reported to the appropriate management levels? 1. Does the institution promptly act to mitigate risks that pose the immediate possibility of material loss? 2. How does the institution demonstrate that the mitigation strategy was reviewed by appropriate officials? 3. Does the risk assessment provide guidance for the nature and extent of testing? 4. Does the risk assessment include vendor oversight requirements? AMERICAN BANKERS ASSOCIATION 4 III. Evaluating The Adequacy Of The Program To Manage And Control Risk. A. Review internal controls and policies. Has the institution documented or otherwise demonstrated, at a minimum, that it considered the following controls, and adopted those it considered appropriate? 1. Access controls, such as controls to authenticate and permit access to customer information systems to authorized persons only. 2. Access restrictions at physical locations, such as buildings and computer facilities, to permit access to authorized persons only. 3. Encryption of electronically transmitted and stored customer data. 4. Procedures to ensure that systems modifications are consistent with the approved security program. 5. Dual control procedures, segregation of duties, and employee background checks. 6. Monitoring systems and procedures to detect actual and attempted attacks on or intrusions into customer information systems. 7. Response programs specifying actions to be taken by specific individuals when the institution suspects unauthorized access (i.e., incident response). 8. Measures to protect against destruction, loss, or damage of information from potential environmental hazards, such as fire and water damage or technological failures. B. Is staff adequately trained to implement the security program? 1. Obtain from management a listing of the training provided to all users of the institution’s system. C. Determine whether key controls, systems, and procedures of the information security program are regularly tested by independent third parties or qualified independent staff in accordance with the risk assessment. 1. Assess whether the nature and frequency of testing is consistent with the risk assessment. 2. Assess whether tests are conducted or reviewed by independent third parties or qualified staff independent of those that develop or maintain the security program. 3. Assess whether management reviews test results promptly. Assess whether management takes appropriate steps to address adverse test results. AMERICAN BANKERS ASSOCIATION 5 IV. Assessing The Measures Taken To Oversee Service Providers. A. Determine whether the institution exercises due diligence in selecting service providers. B. Determine what information is supplied to service providers. C. Obtain a copy of the contract(s) with the service provider(s). Determine whether contracts require service providers to implement appropriate measures to meet the objectives of the guidelines. D. If the institution’s risk assessment requires monitoring a service provider, then perform the following steps for each applicable service provider. 1. Determine whether the service provider contract provides for sufficient reporting from the service provider to allow the institution to appropriately evaluate the service provider’s performance and security, both in ongoing operations and when malicious activity is suspected or known. 2. Determine whether the institution’s actions adequately control information supplied to service providers, ensuring that the information is managed and secured properly. 3. Review financial condition of service provider. V. Determining Whether An Effective Process Exists To Adjust Program. A. Does the institution have an effective process to adjust the information security program as needed? Is the appropriate person assigned responsibility for adjusting the information security program? B. Review procedures that are in place to ensure that when the institution makes changes in technology and its business function the requirements of the guidelines are also considered. These changes can include: 1) Technology changes (e.g., software patches, new attack technologies and methodologies). 2) Sensitivity of information. 3) Threats (both nature and extent). 4) Upcoming changes to institution’s business arrangements (e.g., mergers and acquisitions, alliances and joint ventures, outsourcing arrangements). 5) Upcoming changes to customer information systems (e.g., new configurations or connectivity, new software). C. Determine whether appropriate expertise is applied to evaluate whether changes to the information security program are necessary. D. Determine whether appropriate controls exist to ensure changes to the information security program are properly implemented in a timely, risk-based manner. AMERICAN BANKERS ASSOCIATION 6