GLBA Safeguards Rule Compliance
Know where your written information security program stands against the FTC's Safeguards Rule before an examiner, a cyber insurer or a lending partner asks. An advisory readiness assessment delivered by executive-level security leadership, with reporting your board can act on and remediation you can track.
This is an assessment and readiness service. A readiness score is an advisory measure prepared by My CISO Partner; it is not a Regulatory Compliance Determination, which only the FTC or your functional regulator makes.
A structured readiness assessment against the Safeguards Rule's actual requirements.
We take the FTC's Safeguards Rule — 16 CFR Part 314 — express it as an assessable control library across its five core domains, and work through every applicable control with your team: what the requirement asks, what you have in place, what evidences it, where the gaps are, and what closes them.
- Every control keeps its citation to 16 CFR Part 314. Requirement statements are plain-English summaries for audit planning; the rule controls.
- A readiness score that distinguishes compliance status, risk severity, evidence sufficiency and remediation status — with the calculation shown, never a bare percentage.
- Service-provider oversight is scoped as its own domain, not an afterthought — the Rule requires you to select service providers capable of safeguarding information and to contractually require them to do so.
- A free, ten-question scored self-assessment is available today at no cost as a starting point — the full readiness engagement builds on it with evidence and a tracked remediation plan.
Any financial institution the FTC's definition reaches.
Non-bank lenders & mortgage companies
Mortgage lenders, brokers and servicers whose Safeguards Rule obligations sit with the FTC rather than a banking regulator.
Fintechs & finance companies
Consumer and commercial finance companies that qualify as "financial institutions" under the GLBA's broad definition, often without realizing it.
Auto dealers & equipment finance
Dealers who extend or arrange credit and hold customer financial information, a Safeguards Rule-covered activity the FTC actively enforces.
Leadership and counsel
CEOs, boards and general counsel who need the Qualified Individual reporting requirement met with a real program behind it, not a title on an org chart.
The gaps that surface after an incident are the expensive ones.
No designated Qualified Individual, or one in name only
The Rule requires a designated individual accountable for the program, and a written report to the board or governing body at least annually. We help build the report, not just fill the title.
A risk assessment that was never written down
The Rule requires a written risk assessment, in criteria, not a verbal sense of "we're probably fine." Every risk-assessment control here carries what an examiner expects to see.
Missing technical Safeguards
Encryption, MFA, access controls and monitoring are all explicit Rule requirements, not general best practice — each is its own assessable control, not folded into a vague "security" line item.
Service providers with no contractual requirement
The Rule requires you to select capable service providers and bind them contractually. Service-provider oversight is scoped and tracked as its own domain.
No incident response plan
A written incident response plan is a named Rule requirement, along with the reporting obligations that follow a qualifying breach.
Testing and monitoring nobody scheduled
Continuous monitoring or periodic penetration testing and vulnerability assessment — the Rule requires one or the other on a defined cadence, and we track which one you've committed to.
Ten stages, one traceable chain.
From the first conversation to the executive report, every stage leaves a record you can follow back: framework → domain → requirement → control → evidence → assessment → finding → remediation.
- Scope is set from your institution type, customer data footprint and existing program maturity — every one of the five Safeguards Rule domains is assessed, since the Rule doesn't offer a scoped-down path for smaller institutions beyond limited exemptions we confirm with you.
- Each control is recorded as Compliant, Partially Compliant, Non-Compliant, Not Applicable or Not Assessed — the assessor's vocabulary, not a verdict on the institution — with evidence requested, received and rated for sufficiency.
- The readiness score weights each control by its regulatory significance, discounts it by evidence sufficiency, and deducts for unresolved critical and high findings — the weighting is configuration, and every step is shown.
- Issued results are frozen. A final assessment cannot be edited or reopened; a changed position is a new assessment, so history is never rewritten — useful evidence of program maturity if the FTC ever asks.
The five domains 16 CFR Part 314 actually names.
Program Governance
A designated Qualified Individual, a written information security program, and an annual written report to the board or governing body.
Risk Assessment
A written risk assessment covering foreseeable internal and external risks to customer information, in criteria and periodically reassessed.
Technical Safeguards
Encryption of customer information, multi-factor authentication, access controls, and secure development practices.
Incident Response & Service Providers
A written incident response plan, breach notification obligations, and contractual oversight of service providers who access customer information.
Testing & Monitoring
Continuous monitoring, or periodic penetration testing and vulnerability assessment on the Rule's required cadence.
What you receive.
- A scoped, control-by-control assessment record with the Safeguards Rule's citations preserved.
- An evidence register: every request, version, review decision, validity period and expiry, with an access ledger.
- A findings register with rating, priority, owner, due date and a remediation plan per finding.
- The readiness score with its domain breakdown and the full calculation.
- A draft of the annual written report your Qualified Individual delivers to the board — built from the assessment record, not from scratch.
- A client portal showing assessment status, released findings, outstanding evidence and delivered reports.
A ten-question starting point.
Our free GLBA Safeguards Assessment takes about ten minutes and gives you a scored first read across the same five domains before you commit to a full engagement.
Written for the Qualified Individual's board report.
One dashboard for the board, the Qualified Individual and counsel: overall readiness, critical and high findings, overdue remediation and evidence gaps — with drill-down to the control, the finding and the evidence behind every number.
Ownership after the assessment.
Readiness is not a one-time exercise. Our Fractional CISO service can serve as, or support, your designated Qualified Individual — owning the remediation plan and preparing the annual board report.
Questions, answered directly.
No. It is an advisory readiness assessment. The readiness score describes the state of preparation as observed by the assessors; only the FTC or your functional regulator determines compliance. Nothing in the reports states that an institution is, or is not, in compliance with the Safeguards Rule.
Yes, through a Fractional CISO engagement — the Rule allows the Qualified Individual to be an internal employee, an affiliate, or a service provider, provided your organization retains ultimate responsibility. We'll confirm the right structure for your institution before the engagement starts.
No. The free ten-question assessment is a scored starting point across the same five domains. The full readiness engagement adds control-by-control evidence collection, a findings register, tracked remediation, and the board report your Qualified Individual is required to deliver.
Named, senior consultants perform the assessment and make every judgement. Where an AI assistant is enabled for an engagement, everything it produces is labelled AI GENERATED — HUMAN REVIEW REQUIRED and cites only records already in the assessment; it cannot change a status, close a finding, or make any compliance determination.
The written information security program the Rule requires.
Our policy library includes sample policies aligned to the financial institution regulatory set (NCUA, FFIEC and GLBA) among 228 templates spanning governance, risk, privacy, operational and compliance requirements — a starting point for the written program the Safeguards Rule requires.
Start with the free assessment.
Ten questions tell us where your program stands today. A consultant follows up to scope the full readiness engagement.