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Last Update:  2/14/2013
The Integrity Center, Inc.

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[ Since 1984 ]
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PRESS RELEASE
The Integrity News
Vol. XII No. 30
ISSN 1081-2717

November 18, 2003


Enterprise Systems
November 12, 2003


TIPS for
Gramm-Leach-Bliley
Compliance

"The Gramm-Leach-Bliley Act (GLBA) requires  companies in the broadly defined financial services  sector to safeguard customer privacy by protecting  customer information."

HOWEVER, what all companies are really  grappling with is the "broader climate" of  privacy-related regulations covering both customers AND EMPLOYEES such as:

    Health Insurance Portability and Accountability Act (HIPAA)
    California Breach Notification Act (SB 1386)
    The Sarbanes-Oxley Act
    The Homeland Security Act
    The Patriot Act
    Visa's Cardholder Information Security Program (VISA CISP)
    BS 7799 (Britian)
    The Basel Capital Accord II (Europe) ISO 17799

"The bad news for companies is that the whole list is quite long, and each one of these regulations can have  significant implications for companies including penalties  up to criminal penalties.    The worse news is that companies can have obligations under several of these regulations at the same time."

On the other hand, the techniques used to meet one regulation will help when tackling others.

"There is a burden to be informed, a burden to be aware."    Companies need to perform frequent network self-assessments and use security testing techniques.    It is a company's responsibility to know if it's information is secure and being properly used.

"The giant killer requirement is that some of the new laws require that information security control must be  visible beginning at the Board of Directors level."

"Regulators like to see well-documented security programs."    They also like to see that the personnel involved in handling the information are well documented.    However, many companies really don't have their  programs committed to writing, and they do not address  both the physical and administrative safeguards.    That is a GLBA No-No."

Some good news is that companies have the latitude to assess risk in the way that they choose.     However, they must assess risk.    To help get there, the article recommends the following steps as a place to start.

    Put access controls on customer information systems.
    Put access restrictions at physical locations that contain
customer information.
    Encrypt electronic customer information.
    Have written procedures for modifications to systems
containing customer information.
    Consider dual control procedures.
    Segregate employees' duties.
    Do employee Background Checks.
    Monitor systems to detect actual/attempted attacks.
    Have a systematic response program for any events related
to the misuse of customer information.
    Take measures to protect against environmental hazards
that would make the company liable for information leaks.

The reality of the Information Age is that you can lose your privacy at the speed of light.    These new laws are meant to force organizations to spend the resources necessary to protect people's information.

Smaller organizations must realize that they are not immune from these new laws.    Even if a smaller company thinks that it is under the regulator's or examiner's radar, it must realize that it's larger clients are being examined, and as suppliers, the smaller organizations will likely have to supply information to complete the compliance picture for their larger clients.

We suggest that you call The Integrity Center, Inc. (972) 484-6140 to discuss our online Employee File offerings.    We have made the investment in a fully integrated online HR Information System (HRIS) so that our clients don't have to spend the time and money.

The system is easy to use, you can import your files at any time, and the cost is very low to maintain employee files and generate required reports.    We launched the HRIS portion of our client interface several years ago when we took a national survey and found that companies with up to 1,000 employees were often still using paper-based personnel files.    Their costs to generate the newly required reports is astronomical.

With our system, you can still have your paper-based files because the system quickly prints both individual and group reports.    Having all your employee information online makes it easy for you to check on anything in the files, at any time, from anywhere.    Being able to quickly and easily generate reports, will greatly increase your productivity and decrease your reporting response times.


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