Standards Comparison

    GLBA

    Mandatory
    1999

    U.S. law for financial privacy notices and safeguards

    VS

    ISO 22301

    Voluntary
    2019

    International standard for business continuity management systems.

    Quick Verdict

    GLBA mandates privacy notices and NPI safeguards for US financial firms, enforced by FTC with heavy penalties. ISO 22301 provides voluntary BCMS framework for global resilience via PDCA cycles. Companies adopt GLBA for compliance, ISO 22301 for disruption recovery.

    Financial Privacy

    GLBA

    Gramm-Leach-Bliley Act (GLBA)

    Cost
    €€€€
    Complexity
    High
    Implementation Time
    12-18 months

    Key Features

    • Privacy notices and opt-out for nonaffiliated NPI sharing
    • Comprehensive risk-based information security program mandate
    • Broad activity-based definition of financial institutions
    • Qualified Individual designation with board reporting
    • 30-day FTC breach notification for 500+ consumers
    Business Continuity

    ISO 22301

    ISO 22301:2019 Business continuity management systems — Requirements

    Cost
    €€€
    Complexity
    Medium
    Implementation Time
    0-6 months

    Key Features

    • PDCA cycle with Annex SL high-level structure
    • Business Impact Analysis (BIA) and Risk Assessment (RA)
    • Leadership commitment and BCMS policy requirements
    • Operational planning, testing, and exercises
    • Performance evaluation and continual improvement

    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 U.S. federal regulation establishing privacy and security standards for financial institutions handling nonpublic personal information (NPI). It uses a dual-track, risk-based approach via the Privacy Rule (16 C.F.R. Part 313) and Safeguards Rule (16 C.F.R. Part 314), plus pretexting protections.

    Key Components

    • **Privacy RuleInitial/annual notices, opt-out for nonaffiliated sharing.
    • **Safeguards RuleWritten security program with administrative, technical, physical safeguards; Qualified Individual oversight; annual board reports.
    • Pretexting prohibitions. Built on transparency, choice, and protection principles; enforced by FTC for non-banks; no formal certification but audit/compliance model.

    Why Organizations Use It

    Mandated for broad financial entities (banks, non-banks like tax firms, auto dealers); mitigates enforcement penalties (up to $100K/violation); enhances risk management, customer trust, vendor oversight; provides competitive edge via demonstrated resilience.

    Implementation Overview

    Phased: scoping, risk assessment, policy development, technical controls (encryption, MFA), training, testing, continuous monitoring. Applies to U.S. financial activities; requires evidence for FTC exams; scalable for size/complexity.

    ISO 22301 Details

    What It Is

    ISO 22301:2019 is the international standard specifying requirements for a Business Continuity Management System (BCMS). It provides a framework to protect against, respond to, and recover from disruptions, ensuring continuity of critical products and services. Built on the PDCA (Plan-Do-Check-Act) cycle and Annex SL high-level structure (HLS), it adopts a risk-based approach through Business Impact Analysis (BIA) and risk assessment (RA).

    Key Components

    • Clauses 4-10 cover context, leadership, planning, support, operation, performance evaluation, and improvement.
    • Core elements: BIA/RA, operational controls, testing exercises, internal audits, and management reviews.
    • No fixed controls; flexible for organizational context.
    • Certification via accredited bodies with 3-year validity and annual surveillance.

    Why Organizations Use It

    Drives reduced downtime, cost savings, regulatory compliance (e.g., NIS Directive), and stakeholder trust. Mitigates risks from cyberattacks, disasters, supply chains; lowers insurance premiums, boosts competitiveness.

    Implementation Overview

    Gap analysis, BIA/RA, policy development, training, testing, audits. Applies to all sizes/sectors; accelerated by platforms like ISMS.online (e.g., 6 months). Two-stage certification process.

    Key Differences

    Scope

    GLBA
    Consumer financial privacy and NPI security
    ISO 22301
    Business continuity management system resilience

    Industry

    GLBA
    Financial institutions, non-banks (US)
    ISO 22301
    All industries worldwide

    Nature

    GLBA
    US federal regulation with FTC enforcement
    ISO 22301
    Voluntary international certification standard

    Testing

    GLBA
    Vulnerability/penetration testing annually
    ISO 22301
    Tabletop exercises, audits, simulations

    Penalties

    GLBA
    $100K per violation, imprisonment possible
    ISO 22301
    Loss of certification, no legal penalties

    Frequently Asked Questions

    Common questions about GLBA and ISO 22301

    GLBA FAQ

    ISO 22301 FAQ

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