What It Is

Gramm-Leach-Bliley Act (GLBA), enacted in 1999, is a U.S. federal regulation establishing baseline privacy and security for consumer financial data. It targets nonpublic personal information (NPI) handled by financial institutions via a risk-based compliance framework through Privacy Rule (16 C.F.R. Part 313) and Safeguards Rule (16 C.F.R. Part 314).

Key Components

• **Privacy RuleInitial/annual notices, opt-out for nonaffiliate sharing.
• **Safeguards RuleWritten security program with 9+ elements including risk assessments, Qualified Individual designation, testing, vendor oversight.
• **Pretexting protectionsAnti-social engineering measures. No formal certification; enforced by FTC for non-banks.

Why Organizations Use It

• Mandatory for broad financial entities (banks, non-banks like tax firms, auto dealers).
• Mitigates enforcement risks (fines up to $100K/violation), enhances trust, reduces breach costs.
• Builds resilience, vendor controls, board governance.

Implementation Overview

Phased: scoping/data mapping, risk assessment, policy/tech controls (encryption, MFA), training, testing, continuous monitoring. Applies to U.S. financial activities; audits via regulators. Typical for mid-size: 6-12 months initial.

What It Is

APRA Prudential Standard CPS 234 (Information Security) is a binding prudential regulation issued by the Australian Prudential Regulation Authority. Effective from 1 July 2019, it mandates APRA-regulated financial entities to maintain information security capabilities commensurate with threats and vulnerabilities. Its risk-based approach emphasizes governance, controls, testing, and rapid incident reporting to ensure resilience against cyber incidents impacting confidentiality, integrity, or availability of information assets, including those managed by third parties.

Key Components

• 11 core requirements spanning board accountability, role definitions, policy frameworks, asset classification, lifecycle controls, incident response, systematic testing, and internal audit assurance.
• Built on CIA triad principles with commensurability to asset criticality/sensitivity.
• No fixed control count; compliance via evidence-driven assurance, not certification.

Why Organizations Use It

• Mandatory for APRA-regulated entities (banks, insurers, super funds) to avoid penalties, heightened supervision.
• Enhances operational resilience, stakeholder trust, third-party risk management.
• Provides competitive edge through robust cyber posture and regulatory alignment.

Implementation Overview

• Phased: gap analysis, governance setup, asset classification, control deployment, testing programs.
• Applies to all sizes in Australian financial sector; audits via internal/APRA review.