Update: 11/9/22 The FTC has changed the FTC Safeguards Rule compliance date to June 9th, 2023.


The following information still holds true, just with a changed date.


The FTC Safeguards Rule December 2022 update brought significant changes to the way financial institutions handle customer information. To ensure compliance with the latest requirements, it’s essential for businesses to understand the key provisions and implement the necessary measures.

  1. Comprehensive Information Security Program: Financial institutions must establish and maintain a written security program that identifies and assesses the risks to customer information. This program should be tailored to the institution’s size, complexity, and the nature of its activities.
  2. Designated Coordinator: Organizations are required to appoint a qualified individual to coordinate the information security program. This person is responsible for overseeing and implementing the program, ensuring that it effectively addresses the unique risks of the institution.
  3. Risk Assessment: Financial institutions must regularly assess risks to customer information, taking into account the sensitivity of the data and potential threats. The assessment should cover areas such as employee training, information systems, and the prevention, detection, and response to potential security events.
  4. Access Controls: The updated FTC Safeguards Rule December 2022 mandates that organizations implement access controls to limit access to customer information. This includes strong authentication procedures, such as multi-factor authentication, and the regular review of access privileges.
  5. Encryption: Financial institutions must encrypt customer information during transmission and storage, using widely accepted cryptographic standards. This helps protect sensitive data from unauthorized access, even if the security measures are bypassed.
  6. Incident Response Plan: Organizations must develop and implement a written incident response plan to address security events. The plan should outline procedures for detecting, reporting, and responding to potential incidents, as well as notifying affected customers and relevant regulatory bodies.
  7. Vendor Management: The FTC Safeguards Rule December 2022 update places a greater emphasis on vendor management. Financial institutions must conduct due diligence on third-party service providers and ensure they maintain appropriate security measures to protect customer information.
  8. Regular Testing and Monitoring: Organizations must periodically test and monitor the effectiveness of their information security program. This includes reviewing the program’s ability to prevent, detect, and respond to security events and adjusting it as needed.
  9. Employee Training: Financial institutions must provide ongoing training to employees, ensuring they understand their role in maintaining the security of customer information. Training should cover topics such as data privacy, phishing, and password management.
  10. Periodic Program Evaluation: The updated FTC Safeguards Rule from December 2022 requires financial institutions to perform regular evaluations of their information security program. This includes adjusting the program as necessary to account for changes in technology, business practices, or potential threats. Periodic evaluations ensure the program remains effective and up-to-date, protecting customer information from evolving risks.
  11. Record Retention and Disposal: Organizations must establish policies and procedures for securely retaining and disposing of customer information. This includes maintaining records for a specified retention period and securely destroying records when they are no longer needed. Proper record management helps to minimize the risk of unauthorized access and data breaches.
  12. Physical Security Measures: Financial institutions must implement physical security measures to protect customer information. This includes restricting access to areas where customer data is stored, securing servers and storage devices, and implementing appropriate security measures for both on-site and off-site data storage locations.
  13. Network Security: The FTC Safeguards Rule December 2022 update emphasizes the importance of network security in protecting customer information. Financial institutions must implement network security measures such as firewalls, intrusion detection systems, and secure remote access to minimize the risk of unauthorized access and data breaches.
  14. Secure Software Development: Organizations must follow secure software development practices to ensure customer information is protected during the development and implementation of new software systems. This includes conducting security assessments and integrating security controls into the software development lifecycle.
  15. Patch Management: Financial institutions must establish a formal patch management process to address security vulnerabilities in a timely manner. This includes regularly monitoring for security updates, testing patches, and deploying them to vulnerable systems. Effective patch management helps to minimize the risk of data breaches resulting from known vulnerabilities.
  16. Mobile Device Security: With the increasing use of mobile devices for accessing customer information, organizations must implement robust mobile device security measures. This includes configuring devices with strong security settings, requiring user authentication, and implementing measures to remotely wipe lost or stolen devices.
  17. Cybersecurity Insurance: The updated FTC Safeguards Rule encourages financial institutions to consider obtaining cybersecurity insurance to mitigate the financial impact of a data breach. Cybersecurity insurance can cover costs associated with breach response, customer notification, and legal expenses.
  18. Reporting Requirements: In the event of a security incident, financial institutions must comply with relevant reporting requirements. This includes notifying affected customers, regulatory bodies, and law enforcement agencies as appropriate. Timely reporting can help mitigate the impact of a security incident and assist in the investigation of the event.
  19. Compliance Audits: Financial institutions should conduct regular audits to assess their compliance with the FTC Safeguards Rule December 2022 update. Audits can identify potential gaps in the information security program and help organizations address them to ensure ongoing compliance.
  20. Continuous Improvement: Organizations must adopt a culture of continuous improvement to ensure their information security program remains effective in the face of evolving threats. This includes regularly reviewing and updating policies, procedures, and controls to address new risks and maintain the security of customer information.

The FTC Safeguards Rule December 2022 update provides a comprehensive framework for financial institutions to protect customer information. By implementing the required measures, organizations can significantly reduce the risk of data breaches, protect the privacy and security of their customers, and maintain regulatory compliance. It is essential for financial institutions to stay informed about updates to the FTC Safeguards Rule and adjust their information security program accordingly to address evolving risks and maintain a robust security posture.


To get the full guide of FTC Safeguards Rule Checklist go to the full guide.


Or download the full compliance checklist to use in your firm



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