Evaluate Gramm-Leach-Bliley Act compliance for financial institutions and healthcare organizations handling payment information, covering privacy notices, safeguards, and pretexting protection
16 CFR 313.5: Initial notice of privacy practices before establishing customer relationship
16 CFR 313.8: Annual notice unless exception applies (no info sharing)
16 CFR 313.6: Notice must describe categories of info collected, disclosed, and security
16 CFR 313.7: Opt-out required before disclosing NPI to non-affiliates
16 CFR 314.3(a): CISO or equivalent with authority and accountability
16 CFR 314.4(b): Identify reasonably foreseeable internal and external risks
16 CFR 314.3(b): Written information security program (WISP) required
16 CFR 314.4(e): Train staff on security threats and safeguarding customer info
16 CFR 314.4(i): Plan to respond to and recover from security incidents
16 CFR 314.4(c): Encryption of NPI during transmission and storage
16 CFR 314.4(d): MFA or equivalent authentication for accessing customer info
16 CFR 314.4(g): Secure development, testing, and change management
16 CFR 314.4(h): Monitor activity to detect and respond to security events
16 CFR 314.4(a): Restrict physical access to authorized personnel
16 CFR 314.4(a): Secure disposal prevents unauthorized access (shredding, wiping)
15 USC 6821: Pretexting Protection - verify customer identity before disclosure
Pretexting awareness: Phishing, vishing, impersonation tactics
16 CFR 314.4(d): Service provider due diligence and security capability
16 CFR 314.4(d): Contractual obligation to protect customer information
16 CFR 314.4(d): Ongoing oversight of vendor safeguards
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