GLBA
U.S. law for financial privacy notices and safeguards
NERC CIP
Mandatory standards for Bulk Electric System cybersecurity.
Quick Verdict
GLBA mandates privacy notices and safeguards for financial firms protecting NPI, while NERC CIP enforces cybersecurity standards for electric utilities ensuring grid reliability. Organizations adopt GLBA for consumer trust and FTC compliance; NERC CIP for mandatory BES protection and FERC enforcement.
GLBA
Gramm-Leach-Bliley Act (GLBA)
NERC CIP
NERC Critical Infrastructure Protection Standards
Key Features
- Risk-based BES Cyber System impact tiering (High/Medium/Low)
- Mandatory FERC-enforced annual audits and penalties
- 35-day patch evaluation and 90-day log retention cadences
- Electronic/Physical Security Perimeters with access controls
- Incident response, recovery, and supply chain risk management
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 for financial institutions handling nonpublic personal information (NPI). It establishes Privacy Rule, Safeguards Rule, and Pretexting Provisions using a risk-based approach to ensure transparency, security, and protection against fraud.
Key Components
- **Privacy Rule (16 C.F.R. Part 313)Initial/annual notices, opt-out for nonaffiliated sharing.
- **Safeguards Rule (16 C.F.R. Part 314)Written security program with 9+ elements including risk assessment, Qualified Individual, testing, vendor oversight.
- **Pretexting protectionsAnti-social engineering measures. Enforced by FTC for non-banks; compliance via ongoing programs, no formal certification.
Why Organizations Use It
Mandated for financial entities to avoid $100K+ penalties, enhance customer trust, mitigate breach risks, and meet multi-agency enforcement. Builds resilience, differentiates in fintech, supports vendor ecosystems.
Implementation Overview
Phased: scoping, risk assessment, policy development, technical controls (encryption, MFA), training, testing. Applies to banks/non-banks (tax firms, auto dealers); suits all sizes with small-entity exemptions. Requires audits, board reporting, continuous monitoring.
NERC CIP Details
What It Is
NERC Critical Infrastructure Protection (CIP) standards are mandatory U.S. reliability regulations enforced by FERC. They protect the Bulk Electric System (BES) from cyber and physical threats causing misoperation or instability. Adopting a risk-based, tiered approach, entities categorize BES Cyber Systems as High, Medium, or Low impact.
Key Components
- Core standards: CIP-002 (scoping) to CIP-014 (supply chain/physical security).
- Pillars: governance (CIP-003), personnel/training (CIP-004), perimeters (CIP-005/006), system security (CIP-007), incident response/recovery (CIP-008/009), configuration management (CIP-010).
- Recurring cycles: 15/35-day reviews, annual audits.
- Compliance via evidence retention (3 years), penalties for violations.
Why Organizations Use It
- Legal mandate for BES owners/operators; fines up to $1M+ per violation.
- Mitigates grid instability risks, enhances resilience.
- Builds stakeholder trust, lowers insurance costs, enables market access.
Implementation Overview
Phased: scoping, gap analysis, controls deployment, audits. Applies to utilities/transmission entities in North America. Requires CIP Senior Manager oversight, automation for cadences.
Key Differences
| Aspect | GLBA | NERC CIP |
|---|---|---|
| Scope | Consumer financial privacy and data security | Bulk Electric System cybersecurity and reliability |
| Industry | Financial institutions (broad non-banks) | Electric utilities and grid operators |
| Nature | Mandatory FTC rules for privacy/safeguards | Mandatory FERC-enforced reliability standards |
| Testing | Risk assessments, penetration testing annually | Vulnerability assessments every 15/36 months |
| Penalties | Up to $100k per violation, criminal exposure | Millions in fines, operating restrictions |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about GLBA and NERC CIP
GLBA FAQ
NERC CIP FAQ
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