GLBA
US law for financial privacy notices and safeguards
ISO 19600
International guidelines for compliance management systems
Quick Verdict
GLBA mandates privacy notices and security programs for US financial firms protecting NPI, while ISO 19600 offers voluntary guidelines for building scalable compliance systems across all organizations. Firms adopt GLBA for legal compliance, ISO 19600 for structured risk management.
GLBA
Gramm-Leach-Bliley Act of 1999
Key Features
- Mandates privacy notices and opt-out for NPI sharing
- Requires comprehensive written information security program
- Applies broadly to non-banks handling financial data
- Designates Qualified Individual with board reporting
- Imposes 30-day FTC breach notification for 500+ consumers
ISO 19600
ISO 19600:2014 Compliance management systems — Guidelines
Key Features
- Risk-based PDCA management system structure
- Governance principles for compliance function independence
- Scalable to any organization size and complexity
- Broad compliance obligations including voluntary commitments
- Integration with other ISO management systems
Detailed Analysis
A comprehensive look at the specific requirements, scope, and impact of each standard.
GLBA Details
What It Is
The Gramm-Leach-Bliley Act (GLBA), enacted in 1999, is a US federal regulation establishing privacy and security standards for financial institutions handling nonpublic personal information (NPI). It uses a risk-based approach through the Privacy Rule and Safeguards Rule to ensure transparency and protection.
Key Components
- **Privacy Rule (16 C.F.R. Part 313)Initial/annual notices, opt-out rights for nonaffiliated sharing.
- **Safeguards Rule (16 C.F.R. Part 314)Written security program with administrative, technical, physical safeguards; Qualified Individual; board reporting; breach notification.
- **Pretexting provisionsAnti-social engineering protections. Built on risk assessment and continuous monitoring; enforced by FTC for non-banks.
Why Organizations Use It
- Legal compliance to avoid penalties up to $100,000 per violation.
- Protects against breaches, enhances customer trust.
- Manages vendor risks, supports operational resilience.
- Provides competitive edge in financial sectors via demonstrated safeguards.
Implementation Overview
Phased approach: scoping, risk assessment, policy development, technical controls (encryption, MFA), training, testing. Applies to broad financial entities (banks, non-banks like tax firms); requires ongoing audits, no formal certification but FTC enforcement.
ISO 19600 Details
What It Is
ISO 19600:2014, titled Compliance management systems — Guidelines, is an international standard providing non-certifiable guidance for establishing, implementing, evaluating, maintaining, and improving a Compliance Management System (CMS). It applies to all organization types and sizes, using a risk-based, scalable approach aligned with PDCA (Plan-Do-Check-Act) and ISO's high-level structure.
Key Components
- Core clauses: context, leadership, planning, support, operation, performance evaluation, improvement.
- **Principlesgood governance (e.g., compliance function independence), proportionality, transparency, sustainability.
- No fixed controls; emphasizes obligations identification, risk assessment, controls, monitoring.
- Non-certifiable; focuses on integration with other management systems like ISO 9001.
Why Organizations Use It
- Mitigates compliance risks (legal, regulatory, contractual, voluntary).
- Enhances governance, culture, and operational efficiency.
- Builds stakeholder trust; benchmark for regulators/courts.
- Strategic enabler for market access and penalty reduction.
Implementation Overview
- Phased: gap analysis, policy design, controls, training, monitoring.
- Scalable by size/complexity; no mandatory audits.
- Applicable universally; withdrawn 2021, succeeded by certifiable ISO 37301.
Key Differences
| Aspect | GLBA | ISO 19600 |
|---|---|---|
| Scope | Consumer financial privacy and security (NPI protection) | General compliance management systems (all obligations) |
| Industry | Financial institutions (broad, activity-based, US-focused) | All industries/organizations worldwide, scalable |
| Nature | Mandatory US federal law with FTC enforcement | Voluntary international guidelines (non-certifiable) |
| Testing | Risk assessments, penetration testing, vulnerability scans | Internal audits, management reviews, performance monitoring |
| Penalties | Civil penalties up to $100K/violation, imprisonment | No legal penalties (reputational/certification impacts) |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about GLBA and ISO 19600
GLBA FAQ
ISO 19600 FAQ
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