Standards Comparison

    ISO 37301

    Voluntary
    2021

    International standard for compliance management systems

    VS

    GLBA

    Mandatory
    1999

    U.S. law for financial privacy notices and data safeguards

    Quick Verdict

    ISO 37301 provides certifiable CMS frameworks for global organizations seeking compliance excellence, while GLBA mandates privacy notices and security programs for US financial institutions protecting NPI. Companies adopt ISO 37301 for integration and prestige; GLBA to avoid hefty fines.

    Compliance Management

    ISO 37301

    ISO 37301:2021 Compliance management systems – Requirements

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

    Key Features

    • Certifiable requirements standard replacing guidance-only ISO 19600
    • High-Level Structure enables integration with ISO 9001, 14001, 27001
    • Risk-based approach identifies obligations, risks, and controls
    • Leadership commitment fosters compliance culture and whistleblower protections
    • PDCA cycle drives performance evaluation and continual improvement
    Financial Privacy

    GLBA

    Gramm-Leach-Bliley Act

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

    Key Features

    • Privacy notices and opt-out rights for NPI sharing
    • Comprehensive safeguards program with risk assessments
    • Qualified Individual designation and board reporting
    • Service provider oversight and contractual safeguards
    • 30-day breach notification for 500+ consumers

    Detailed Analysis

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

    ISO 37301 Details

    What It Is

    ISO 37301:2021 – Compliance management systems – Requirements with guidance for use is a certifiable international standard for establishing, implementing, maintaining, and improving effective compliance management systems (CMS). Applicable to all organization sizes and sectors, it uses a risk-based PDCA (Plan-Do-Check-Act) approach and follows the ISO High-Level Structure (HLS) for integration with other standards like ISO 9001 and 27001.

    Key Components

    • Core clauses: context, leadership, planning, support, operation, performance evaluation, improvement.
    • Emphasizes leadership commitment, compliance culture, risk assessment, whistleblowing protections, and continual improvement.
    • Built on HLS with explicit 'shall' requirements; companion standards (ISO 37302, 37303) for measurement and competence.
    • Third-party certification via accredited bodies like ANAB.

    Why Organizations Use It

    Drives regulatory compliance, reduces risks/fines, enhances reputation, and meets ESG/investor demands. Provides external assurance, integrates with IMS, and supports UN SDGs.

    Implementation Overview

    Phased approach: gap analysis, obligation register, controls, training, audits. Scalable for SMEs/enterprises; 3-year certification cycle with surveillance audits. 2024 Amendment adds climate action changes.

    GLBA Details

    What It Is

    The 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). GLBA employs a risk-based approach through its Privacy Rule and Safeguards Rule, focusing on transparency, consumer choice, and data protection.

    Key Components

    • **Privacy Rule (16 C.F.R. Part 313)Mandates initial/annual notices and opt-out rights for nonaffiliated third-party sharing.
    • **Safeguards Rule (16 C.F.R. Part 314)Requires a written information security program with administrative, technical, and physical safeguards; includes nine core elements like risk assessments and vendor oversight.
    • **Pretexting provisionsProhibits obtaining NPI under false pretenses. Built on consumer protection principles; compliance via self-attestation, no formal certification.

    Why Organizations Use It

    • Legal mandate for covered entities (banks, non-banks like tax firms).
    • Mitigates enforcement risks (fines up to $100K/violation).
    • Enhances trust, reduces breach impacts, supports vendor management.

    Implementation Overview

    Phased: scoping, risk assessment, policy development, technical controls, testing. Applies to activity-based financial institutions (U.S.-focused); audited by FTC/banking regulators.

    Key Differences

    Scope

    ISO 37301
    Compliance management systems across all obligations
    GLBA
    Privacy and security of consumer financial information

    Industry

    ISO 37301
    All sectors, all sizes, global applicability
    GLBA
    Financial institutions (broad definition), US-focused

    Nature

    ISO 37301
    Voluntary certifiable international standard
    GLBA
    Mandatory US federal regulation with enforcement

    Testing

    ISO 37301
    Internal audits, management reviews, certification audits
    GLBA
    Risk assessments, penetration testing, vulnerability scans

    Penalties

    ISO 37301
    Loss of certification, no legal penalties
    GLBA
    Fines up to $100K/violation, criminal penalties

    Frequently Asked Questions

    Common questions about ISO 37301 and GLBA

    ISO 37301 FAQ

    GLBA FAQ

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