Standards Comparison

    GLBA

    Mandatory
    1999

    U.S. federal law for financial privacy and safeguards

    VS

    ISO 27701

    Voluntary
    2019

    International standard for privacy information management systems.

    Quick Verdict

    GLBA mandates privacy notices and safeguards for US financial firms handling NPI, enforced by FTC with heavy penalties. ISO 27701 offers voluntary global PIMS certification for PII processors, providing auditable privacy governance. Firms adopt GLBA for compliance, ISO 27701 for assurance.

    Financial Privacy

    GLBA

    Gramm-Leach-Bliley Act (GLBA)

    Cost
    €€€€
    Complexity
    High
    Implementation Time
    6-12 months

    Key Features

    • Requires initial and annual privacy notices with opt-out rights
    • Mandates comprehensive Safeguards Rule security program
    • Applies to broad range of non-bank financial entities
    • Designates Qualified Individual for program oversight
    • Imposes 30-day FTC breach notification requirement
    Privacy Management

    ISO 27701

    ISO/IEC 27701:2025 Privacy Information Management

    Cost
    €€€
    Complexity
    High
    Implementation Time
    6-12 months

    Key Features

    • Privacy Information Management System (PIMS) framework
    • Controller and processor-specific controls (Annex A/B)
    • Risk-based assessments and DPIAs
    • GDPR and ISO 27001 alignments/mappings
    • Auditable certification for PII accountability

    Detailed Analysis

    A comprehensive look at the specific requirements, scope, and impact of each standard.

    GLBA Details

    What It Is

    Gramm-Leach-Bliley Act (GLBA) is a U.S. federal regulation enacted in 1999. It establishes privacy and security standards for financial institutions handling nonpublic personal information (NPI). Primary purpose: protect consumer financial data through transparency and safeguards. Adopts a risk-based approach via Privacy Rule and Safeguards Rule.

    Key Components

    • Privacy Rule (16 C.F.R. Part 313): notices, opt-outs for nonaffiliated sharing.
    • Safeguards Rule (16 C.F.R. Part 314): written security program with administrative, technical, physical controls.
    • **Pretexting provisionsanti-social engineering protections. Built on interconnected privacy-security framework; no certification, but FTC enforcement.

    Why Organizations Use It

    Mandated for financial institutions (banks, non-banks like tax firms). Mitigates enforcement risks (fines up to $100K/violation), enhances trust, reduces breach impacts. Builds resilience, vendor oversight; strategic for reputation in finance.

    Implementation Overview

    Phased: scoping, risk assessment, controls (encryption, MFA), training, testing. Applies to broad entities handling NPI; U.S.-focused. Requires audits, board reporting, no formal certification.

    ISO 27701 Details

    What It Is

    ISO/IEC 27701:2025 is an international standard providing requirements and guidance for establishing, implementing, maintaining, and improving a Privacy Information Management System (PIMS). It focuses on managing personally identifiable information (PII) lifecycle for controllers and processors, using a risk-based PDCA (Plan-Do-Check-Act) approach aligned with ISO/IEC 27001:2022.

    Key Components

    • Clauses 4–10 extend management system requirements for privacy.
    • Annex A (controllers) and Annex B (processors) specify privacy controls.
    • Mappings to GDPR (Annex D) and other standards.
    • Certification via accredited bodies, often integrated with ISO 27001 audits.

    Why Organizations Use It

    • Demonstrates accountability for global privacy laws (GDPR, CCPA).
    • Mitigates regulatory fines, breach risks, and vendor exclusions.
    • Builds trust, differentiates in B2B markets, harmonizes compliance.

    Implementation Overview

    • Phased: discover/scope, design/plan, implement/operate, validate/improve.
    • Involves PII inventory, DPIAs, DSR processes, training.
    • Suits all sizes/industries handling PII; voluntary certification.

    Key Differences

    Scope

    GLBA
    Consumer financial privacy and security (NPI)
    ISO 27701
    Privacy management system (PII lifecycle)

    Industry

    GLBA
    Financial institutions (broad, US-focused)
    ISO 27701
    All sectors processing PII (global)

    Nature

    GLBA
    Mandatory US federal law with FTC enforcement
    ISO 27701
    Voluntary international certification standard

    Testing

    GLBA
    Risk assessments, penetration testing, board reports
    ISO 27701
    Internal audits, management reviews, certification audits

    Penalties

    GLBA
    Up to $100k per violation, criminal penalties
    ISO 27701
    Loss of certification, no direct legal penalties

    Frequently Asked Questions

    Common questions about GLBA and ISO 27701

    GLBA FAQ

    ISO 27701 FAQ

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