Documents

Financial institutions must adhere to statutory and regulatory requirements by maintaining clearly defined information security and privacy policies, controls and procedures. This includes establishing a robust security program, a comprehensive privacy program, and demonstrating proactive management of audit findings.

Information Security and Privacy Policies
Information Security Program (ISP)
Information Privacy Program (IPP)
Incident Response Plan (IRP)
Information Security Controls and Procedures (NIST SP 800-53r5)
Audit and Examination Findings

These documents are essential for ensuring a secure and compliant environment, protecting information assets, and maintaining the trust of individuals.

Policies

Policies are formal statements that define the principles, rules, and guidelines for how an organization manages various aspects of its operations.

Controls and Procedures

Information Security Controls and Procedures are specific actions and processes implemented to enforce policies and mitigate risks. They ensure that the organization adheres to its policies and maintains a secure and compliant environment.

To ensure proper design and implementation of controls, IRM utilizes NIST SP 800-53r5 Policies, Controls, and Procedures for all applicable controls. NIST is widely regarded as the gold standard in information security. By adhering to NIST standards, auditors and examiners can focus on verifying the implementation of controls rather than evaluating their design or necessity. This approach streamlines the audit process and ensures that institutions remain compliant and secure.

There are 1,008 controls and 195 control enhancements in the NIST SP 800-53 R5 specification, which will not be enumerated in this document. These controls are broken down into 20 NIST control families aligned with policies. Examples include but are not limited to:

Access Control (AC)
Awareness and Training (AT)
Audit and Accountability (AU)
Configuration Management (CM)
Incident Response (IR)
Risk Assessment (RA)
System and Communications Protection (SC)

Security Program

A Security Program is a comprehensive framework that includes all policies, controls, and procedures related to information security. Its primary goal is to protect the organization's information assets from threats and vulnerabilities.

To ensure that the information security program meets the standards of auditors and regulators in terms of efficacy and completeness, IRM bases each program on the NIST Cybersecurity Framework. This approach guarantees that the program is well-designed, lightweight, complete, and effective. As a result, auditors and regulators can focus on verifying the implementation of the program rather than questioning its design.

Key components the security program include:

Risk Exposure: Failure to identify and assess risks leads to security blind spots.
Access Management Challenges: Weak controls allow unauthorized access to critical systems.
Incident Response Gaps: Delayed detection and response increase security breach impacts.
Security Training Deficiencies: Employees unaware of threats contribute to security lapses.
Ineffective Audit Trails: Poor logging hinders compliance verification and issue tracking.
Unmanaged System Changes: Lack of configuration oversight leads to security loopholes.
Business Continuity Risks: Absence of contingency planning disrupts critical operations.
Physical Security Weaknesses: Insufficient controls increase unauthorized access risks.
Data Protection Issues: Inadequate media safeguards result in data exposure.
Supply Chain Vulnerabilities: Third-party security gaps introduce organizational risks.

By incorporating these key components, organizations can establish a robust security program that effectively protects their information assets and meets regulatory requirements.

Privacy Program

A Privacy Program focuses specifically on protecting individuals' personal information and ensuring compliance with data protection laws and regulations.

To ensure that the information privacy program meets the standards of auditors and regulators in terms of efficacy and completeness, IRM bases each program on the NIST Privacy Framework. This approach guarantees that the program is well-designed, lightweight, complete, and effective. As a result, auditors and regulators can focus on verifying the implementation of the program rather than questioning its design.

Key elements of a privacy program include:

Data Inventory and Mapping:Identifying and documenting personal data collected, stored, and processed by the organization.
Privacy Risk Assessments:Evaluating privacy risks associated with data processing activities.
Privacy Policies and Procedures:Establishing and maintaining policies and procedures to ensure compliance with data protection laws and regulations.
Data Subject Rights Management:Implementing processes to manage and respond to data subject requests, such as access, rectification, and deletion.
Data Minimization and Retention:Ensuring that personal data is only collected and retained for as long as necessary for the intended purpose.
Security Measures:Implementing appropriate technical and organizational measures to protect personal data from unauthorized access, disclosure, alteration, or destruction.
Training and Awareness:Educating employees about privacy policies, procedures, and best practices.
Third-Party Management:Ensuring that third-party service providers comply with privacy requirements through contracts and regular assessments.
Incident Response:Establishing procedures to detect, report, and respond to data breaches and other privacy incidents.
Monitoring and Auditing:Regularly monitoring and auditing privacy practices to ensure compliance and identify areas for improvement.

By incorporating these key elements, organizations can establish a robust privacy program that effectively protects personal information and meets regulatory requirements.

Audit/Examination Findings

Audit/Examination Findings are the results of internal or external reviews of the organization's information security and privacy practices. These findings identify areas of non-compliance, weaknesses in controls, and opportunities for improvement. Key actions related to audit findings include:

Remediation Plans: Developing and implementing plans to address identified weaknesses and non-compliance issues.
Continuous Improvement: Regularly reviewing and updating security and privacy practices based on audit findings and changing threats.
Reporting: Documenting and communicating audit findings and remediation efforts to relevant stakeholders.

By having well-defined policies, controls, and procedures, a robust security program, a comprehensive privacy program, and proactive management of audit findings, organizations can ensure a secure and compliant environment that protects their information assets and maintains individuals' trust.