GLBA & FTC Safeguards Rule Compliance
The revised Safeguards Rule reaches far beyond banks: CPAs, auto dealers, insurance agencies, and lenders all carry it. ASG implements the required controls and maintains the written program the FTC expects.
- ✓Written Information Security Program (WISP), built and maintained
- ✓The rule's named controls: MFA, encryption, monitoring, vendor oversight
- ✓A qualified security function without a full-time hire
You're probably a 'financial institution' now
The FTC's revised Safeguards Rule, fully enforced since June 2023, defines financial institutions broadly, and the list reaches further than most firms expect:
- Accounting and tax firms
- Auto dealerships that arrange financing
- Insurance agencies
- Mortgage brokers
- Collection agencies
If you handle customer financial information incidental to lending, tax, or insurance activity, the rule almost certainly reaches you. Many Connecticut firms discovered that through a carrier questionnaire or franchise audit rather than a lawyer. And since the Safeguards Rule is how the Gramm-Leach-Bliley Act gets enforced day to day, GLBA compliance and Safeguards compliance are, practically, the same project.
What the rule actually names
Unlike vaguer laws, the Safeguards Rule lists its requirements:
- A designated qualified individual accountable for the program
- A written risk assessment
- Access controls
- Encryption of customer information at rest and in transit
- Multi-factor authentication
- Continuous monitoring or annual penetration testing
- Secure disposal
- Vendor oversight
- An incident response plan
- Regular reporting to your board or owner
Miss the written artifacts and you're non-compliant even if the technology is fine. For credit unions and community banks, the same themes arrive through NCUA and FFIEC examinations: same substance, different examiner.
We build one program that satisfies both framings.
How ASG carries it
Most firms this size can't justify a full-time security officer, and the rule asks for something more attainable anyway: a qualified, accountable function. ASG operates the technical controls inside managed IT, maintains the written program and risk assessment, runs the monitoring, and produces the annual report your designated qualified individual signs.
Your name stays on the program; our work stands behind it.
Two people carry the ongoing weight. Your Technology Alignment Manager (TAM) audits your risk posture at least quarterly, so the written risk assessment reflects reality instead of the day it was drafted. Your vCIO (a virtual CIO on ASG's team) handles the strategy: writing policy, making recommendations, and addressing risk directly with your owners and executives, in their language.
Every named requirement, owned
Risk Assessment & WISP
The written risk assessment and information security program the rule requires, re-audited by your TAM at least quarterly instead of shelved.
MFA & Access Control
Multi-factor authentication and least-privilege access across systems holding customer information.
Encryption
Customer data encrypted at rest and in transit, with documented exceptions where genuinely infeasible.
Monitoring / Pen Testing
Continuous monitoring through our security stack, satisfying the rule's monitoring-or-testing requirement.
Vendor Oversight
Your service providers inventoried, assessed, and held to safeguards contractually.
Incident Response & Reporting
A written, practiced IR plan, plus the annual program report your vCIO prepares for your board or owner.
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