Due diligence checklist, United States
GLBA Safeguards: what to ask a vendor
Gramm-Leach-Bliley Act: Interagency Guidelines Establishing Information Security Standards and the FTC Safeguards Rule. Federal banking agencies and the FTC. Service providers that handle customer information are overseen and bound to safeguard it.
What it is
Service providers that handle customer information are overseen and bound to safeguard it.
Who it applies to
Applies to every financial institution in the United States.
What to ask a vendor, and the evidence to request
| # | Ask the vendor for | Evidence to request |
|---|---|---|
| 1 | Contractual safeguards for customer information, including encryption and access control | A description of the security controls, the most recent control testing or penetration test summary, and the policies for vulnerability, change and access management. |
| 2 | An incident response capability and notice of unauthorised access to customer information | The incident notification clause and procedure: what counts as an incident, who is told, within what time, and a record of a past notification if one exists. |
In every case
- A named contact at the vendor responsible for this regime, and how the vendor tracks changes to it.
- Which named customers the vendor already serves under this regime, as references you may call.
This checklist is a starting point for a procurement team, not legal advice. Read it with the regulator's own page, your institution's policies and your legal and risk teams; the regime may have changed since the date on this document.
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