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As the former Global head of Santander’s 2nd Line of Defence for Cyber risk, this regulation is one to watch. The US cyber regulatory agenda is moving at pace across Federal Government, with international impact.
The Federal Trade Commission (https://lnkd.in/dUdhMRBB) has released its final ruling on ‘Safeguarding Customer Information’, under the Gramm-Leach-Bliley Act. The rule delivers clarity for financial institutions development of information security programs. Setting out clear requirements for cyber-risk management, data protection, including
1. Employee training
2. The designation of a key ‘qualified’ individual’ at each institution to be responsible for overseeing and enforcing the information security program
3. Scheduled periodic information security reporting.
4. Changing the scope of companies covered to move regulatory oversight to service providers of FS institutions.
Will this lead to the data security role becoming an approved function? With the role of CISO and DPO becoming an approved person under the approved person regime? In my view if the CRO, CFO and CEO are approved persons then the CISO and DPO should be, given the authority and impact of the roles in securing the balance sheet and protecting CNI?
Along with other US regulators and Federal Agencies the FTC are looking at requirements for data incident reporting. In alignment with other legislative proposals recurrently making their way through capitol Hill.
Ted Dziekanowski‚Â Brian McCarthy‚Â Jason Spezzano
#ransomware‚Â #fisma‚Â #ofac‚Â #theaugustagroup‚Â #theaugustaplan‚Â #cybersecurity‚Â #supplychainriskmanagement‚Â #cyberriskmanagement‚Â #compliance‚Â #regulatorycompliance‚Â #regulatoryoversight‚Â #esg‚Â #scrm‚Â #cscrm‚Â #fca‚Â #cybercompliance‚Â #cyberregulation‚Â #cybergovernance‚Â #falseclaimsact‚Â #afcea‚Â #afceacyber‚Â #aws
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