You may not know that the Federal Trade Commission is using a broad definition of financial institution, and your organization may still be impacted. If your nonprof...
You may or may not have heard a little about the latest update to the Safeguards Rule of the Gramm-Leach Bliley Act (GLBA). If you’re not a financial institution, you may have determined that this update is not applicable to you.
However, you may not know that the Federal Trade Commission is using a broad definition of financial institution, and your organization may still be impacted. If your nonprofit organization is significantly engaged in financial activities, we encourage you to take a closer look at the details of the Safeguards Rule. A good place to start is CLA’s article FTC GLBA Safeguards Rule Compliance – Review How You’re Protecting Customer Data.
The Safeguards Rule calls for much tighter security and confidentiality around customer information and goes into effect on December 6, 2022. Examples of new requirements you may be subject to include conducting security awareness training for staff, engaging third-party penetration testing, and designating a qualified individual to oversee the information security program.
If you determine you fit the update’s definition of financial institution, CLA’s cyber team is here to help. Let’s get to work!
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