Frameworks / GLBA / GLBA-Implementation-Roadmap-Examination GLBA
GLBA: Operationalisation through FTC Safeguards Rule, FTC Privacy Rule, SEC Reg S-P
GLBA GLBA-Implementation-Roadmap-Examination: GLBA Implementation Roadmap, Examination Readiness, Roles and Tooling GLBA implementation roadmap. ROLES: (a) GLBA OFFICER or CHIEF PRIVACY OFFICER (CPO) - strategic ownership + privacy notice + opt-out + Sec. 6802 + 6803 compliance; (b) QUALIFIED INDIVIDUAL (FTC Safeguards Rule 16 CFR 314.4(a)(1)) - designated information security program leader for non-bank financial institutions + reports to senior leadership + board; (c) CHIEF INFORMATION SECURITY OFFICER (CISO) - cyber-program ownership; (d) GENERAL COUNSEL + LEGAL - statutory + regulatory interpretation + breach response coordination; (e) COMPLIANCE OFFICER - examination readiness; (f) RISK COMMITTEE OF THE BOARD - 12-month risk assessment + annual report. EXAMINATION READINESS: regulators conduct GLBA-specific exams + identify deficiencies + issue MRBA (Matters Requiring Board Attention) + MRA (Matters Requiring Attention) + consent orders + monetary penalties. TOOLING: (a) information security platforms (NIST CSF aligned + ISO 27001 ISMS); (b) Privacy management platforms (OneTrust + TrustArc + Securiti); (c) IRM platforms (ServiceNow GRC + Archer + LogicGate + ProcessUnity); (d) GLBA-specific risk-assessment templates; (e) FTC Safeguards Rule readiness assessment + gap analysis; (f) SEC Reg S-P readiness assessments for 2025-2026 effective dates; (g) NAIC Insurance Data Security Model Law cross-state tracking; (h) NY DFS 23 NYCRR 500 compliance platform; (i) employee training platforms (KnowBe4 + Proofpoint Security Awareness); (j) Service provider questionnaires + SOC 2 + ISO 27001 review. METRICS: regulatory examinations + MRBA + MRA + open enforcement actions + 30-day FTC notifications + 30-day customer notifications (Reg S-P) + state breach notifications + employee training completion + service provider questionnaires + IR plan tests + risk assessment updates. ANNUAL CYCLE: 12-month privacy notice (Sec. 6803 + FAST Act exemption) + annual board reporting + annual risk assessment + annual employee training + quarterly service-provider reviews + monthly board metrics.
Maintained by Gerard Blokdyk · Control text last updated 21 May 2026 What else in your programme already covers this This control maps to 72 controls across 42 other frameworks. If you already hold one of them, the evidence you collected for it is the starting point here rather than new work.
BSI-18 Incident response planning and testing BSI-20 Incident reporting and notification BSI-21 Forensic analysis capabilities FFIEC-23 Regulatory reporting requirements FFIEC-24 Customer notification procedures FFIEC-25 Post-incident review and improvement APPI-A41 Preparation and Handling of Pseudonymized Personal Information APPI-A43 Preparation of Anonymized Personal Information CPS234-21 Implementation of Information Security Controls CPS234-25 Internal Audit Review of Information Security Controls ASD37-31 Hunt to discover incidents (Very Good) ASD37-33 Capture network traffic (Limited) 3.6 Encrypt Data on End-User Devices 3.6.1 Procedures are defined and implemented to protect cryptographic keys used to protect stored account data against disclosure and misuse that include: • Access to keys is restricted to the fewest number of custodians necessary. D.1 Incident Response Planning D.2 Incident Reporting CYB-5 Cyber Incident Response Plan USMTSA-2 Cybersecurity Assessment and CSO Designation CPS230-13 Board Accountability for Operational Risk Management 4.4.7 Emergency and Incident Response BB-DPA-20 Sections 50-60 - Registration and Responsibilities CA-12 Deploys Through Policies and Procedures 27400-6.5 Security monitoring and incident response 3.6.1 Procedures are defined and implemented to protect cryptographic keys used to protect stored account data against disclosure and misuse that include: • Access to keys is restricted to the fewest number of custodians necessary. NGCB-6 Incident Response, 72-Hour NGCB Notification, and Independent Investigation DSOMM-1 Culture, Organization, Education, and Governance OWASPTOP10-9 A09:2025 Security Logging and Monitoring Failures PAKPDPB-5 Security of Processing and Personal Data Breach Notification AUPRV-7 Notifiable Data Breaches (NDB) Scheme, Incident Response PSPF24-1 Security Culture, Governance, Risk Management SGCYBER-1 Critical Information Infrastructure (CII) Designation and Registration TEFCAREC-1 Common Agreement Conformance and Onboarding USSDWA-2 Cybersecurity Practices (Assessment, Access, Network, IR) VIETNAMCYBER-2 Prohibited Acts (Access, Interception, Forgery, Content) Every mapping shown was judged rather than inferred from wording similarity, and the ones that failed review are published too. See the coverage reports and what was rejected .
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