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Getting Granular: Refreshing Your Privacy Program to Meet New GLBA Safeguards Requirements

AAP/APRP Credits: 1.2
CLE Eligible

For nearly 20 years the Safeguards Rule has required financial institutions to develop, implement, and maintain comprehensive information security programs to protect their customers’ personal information. In late October 2021, the FTC amended the Gramm-Leach-Bliley Act (GLBA) Safeguards Rule. The granularity of the controls announced are likely to influence financial institutions’ contract terms and has a myriad of practical considerations. In addition, the FTC proposed a further amendment requiring certain financial institutions to provide the FTC with notice in the event of certain security events. The proposed notification requirement would not allow for any delay of the 30-day reporting obligation for financial institutions cooperating with law enforcement. The comment period opened on December 9, 2021 and it closes on February 7, 2022.

In this webinar, you will hear from two former top officials at the FTC on the legal and practical effect of these recent developments in consumer privacy. Ms. Rich served in a variety of roles in the FTC’s Bureau of Consumer Protection (BCP), including as its Director from 2013 to 2017, and she authored the original Safeguards Rule. Ms. VanDruff served as an Assistant Director in BCP's Division of Privacy and Identity Protection (DPIP) where she enforced consumer privacy laws.

This session will provide substantive steps on how to update privacy programs to address the amended Safeguards Rule. The presenters will also provide insight into what to expect from the FTC in the next few years as it seeks to strengthen consumer privacy protection.

Questions to be answered.

• How will the amendments to the Safeguards Rule impact the payment industry?
• What are strategies for companies to address the specific requirements contained in the amended Rule?
• How may compliance with state laws be impacted by these recent developments?

Resources

Federal Trade Commission 16 CFR Part 314 Standards for Safeguarding Customer Information

Federal Trade Commission 16 CFR Part 314 Standards for Safeguarding Customer Information Final Rule

Continuing Legal Education

Kelley Drye is the CLE Accredited Provider for Nacha and is an accredited provider of NY, IL, CA and TX CLE. Continuing legal education sessions will offer California, Illinois and Texas general credits and New York non-transitional credit only. In accordance with the requirements of the New York State CLE Board, this non-transitional, CLE program is not approved for newly-admitted attorneys within the first two years of admission to the Bar. CLE credit will only be offered for up to 60 days after the program was published. Affirmation form.