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Who must comply with GLBA?
All
businesses, regardless of size, that are “significantly
engaged” in providing financial products or services
must comply. This includes check-cashing businesses,
payday lenders, mortgage brokers, nonblank lenders,
personal property or real estate appraisers,
professional tax preparers, and courier services. The
Safeguards Rule also applies to companies like credit
reporting agencies and ATM operators that receive
information about the customers of other financial
institutions.
There are many rules to ensuring compliance, which
include:
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Developing a written information security plan that
describes the process by which customer information is
safeguarded.
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Identifying and assessing the risks to customer
information in each area of a company’s operation, and
evaluating the effectiveness of the current safeguards
for controlling these risks.
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Designing and implementing a safeguards program that
is regularly monitored and tested.
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Selecting service providers that can maintain
appropriate safeguards, and making sure your contract
with them requires them to maintain the safeguards
they have in place.
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Evaluating and adjusting the program based on relevant
circumstances, including changes to your firms
business or operations, or the results of security
testing and monitoring.
ATIBA professionals
can help you establish the safeguards necessary to
protect the private information of your customers. We
will develop a comprehensive and structured information
security plan, and assist as needed with on-going
adjustments and testing.
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