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DOL Steerage for Retirement Plan Cybersecurity

Earlier this yr, the DOL’s Worker Advantages Safety Administration issued cybersecurity steering for retirement plan sponsors, fiduciaries, recordkeepers, and contributors. It lays out the obligations of “accountable plan fiduciaries” to mitigate cybersecurity dangers to retirement plan belongings and participant knowledge. Relating to finest practices, the DOL steering for retirement plan cybersecurity recommends a three-pronged method:

  1. Ideas for hiring a retirement plan service supplier

  2. Retirement plan cybersecurity finest practices

  3. On-line safety ideas for plan fiduciaries and contributors

The DOL’s 3-Pronged Cybersecurity Plan

Given at this time’s heightened cybersecurity dangers, adopting a security-first mindset is important for advisors within the retirement plan area. By educating your shoppers concerning the DOL’s cybersecurity expectations, you’ll construct relationships with retirement plan sponsors and improve the worth you present them.

How will you assist defend the belongings and participant knowledge of your retirement plan shoppers? Let’s assessment the specifics of the DOL steering for retirement plan cybersecurity.

1) Ideas for hiring a retirement plan service supplier. Many (if not most) plan sponsors depend on third-party service suppliers for help with plan administration and recordkeeping. You possibly can assist shoppers make the correct choice for his or her plans by making certain that they deal with the next finest practices when vetting third-party distributors:

  • Ask concerning the service supplier’s data safety requirements, practices, insurance policies, and audit outcomes. Your plan sponsor shoppers ought to examine this knowledge with business requirements.

  • Learn the way the service supplier validates its practices and which ranges of safety requirements it has met and carried out. Right here, the main target must be on contract provisions that give the consumer the correct to assessment audit outcomes, demonstrating compliance with the usual.

  • Consider the service supplier’s business observe report. Purple flags may embody data safety incidents, litigation, or authorized proceedings associated to the seller’s providers.

  • Focus on whether or not the service supplier has skilled previous safety breaches. If that’s the case, what occurred? How did the service supplier reply?

  • Discover out whether or not the service supplier has any insurance coverage insurance policies. Would such insurance policies cowl losses brought on by cybersecurity and id theft breaches?

  • Make sure that the service supplier contract requires ongoing compliance with cybersecurity and data safety requirements. Some contract provisions could restrict the service supplier’s accountability for data safety breaches, whereas different phrases improve cybersecurity safety for the plan and its contributors, together with:

    • Data safety reporting

    • Provisions on the use and sharing of knowledge and confidentiality

    • Notification of cybersecurity breaches

    • Compliance with information retention and destruction, privateness, and data safety legal guidelines

    • Insurance coverage

2) Retirement plan cybersecurity finest practicesCreating a coverage based mostly on finest practices will allow plan fiduciaries to behave prudently and mitigate cybersecurity threat. Remember to educate your plan sponsor shoppers on the next pillars of a superb coverage:

  • Create a proper, well-documented cybersecurity program to establish and assess inside and exterior cybersecurity dangers that threaten the confidentiality, integrity, or availability of saved, nonpublic data. This system ought to:

    • Pinpoint dangers

    • Present mandatory safety

    • Establish cybersecurity occasions and reply to them

    • Work to revive operations and providers

  • Set up robust safety insurance policies, pointers, and requirements.

  • Conduct annual threat assessments, in addition to periodic cybersecurity consciousness coaching.

  • Carry out an annual third-party audit of safety controls.

  • Outline and assign data safety roles and duties.

  • Develop robust knowledge entry management procedures.

  • Make sure that any belongings or knowledge saved in a cloud or managed by a third-party service supplier are topic to acceptable safety opinions and unbiased safety assessments.

  • Implement and handle a safe programs improvement life cycle (SDLC) program (i.e., a proper manner of making certain that sufficient safety controls are carried out).

  • Have an efficient enterprise resiliency program that addresses enterprise continuity, catastrophe restoration, and incident response.

  • Make sure that delicate knowledge is encrypted whereas saved and in transit.

  • Implement robust technical safety options and safety finest practices (e.g., frequently replace antivirus software program and again up knowledge).

  • Appropriately reply to previous cybersecurity incidents.

3) On-line safety ideas for plan fiduciaries and contributors. Though the next ideas is likely to be acquainted, conserving them high of thoughts will assist your shoppers and their plan contributors scale back the danger of fraud and loss to their retirement accounts:

  • Register, arrange, and routinely monitor any on-line retirement account.

  • Create robust and distinctive passwords.

  • Use multifactor authentication.

  • Maintain private contact data present.

  • Shut or delete unused accounts.

  • Be cautious of free Wi-Fi.

  • Be within the know relating to indicators of phishing assaults.

  • Use antivirus software program and maintain apps and software program present.

Cybersecurity Consciousness Mindset

In response to the DOL steering for retirement plan cybersecurity, the insurance policies described above are designed to assist defend an estimated $9.3 trillion in plan belongings. This huge sum highlights the cyberthreats confronted by your plan sponsor shoppers and their plan contributors. For those who’re an advisor who helps or acts as a plan fiduciary, you will have an obligation to do your half in educating your shoppers relating to cybersecurity. It’s additionally a superb enterprise apply—and a very good method to construct relationships with retirement plan sponsors.

For extra data on cybersecurity, learn our current submit on the significance of cyber legal responsibility insurance coverage. We additionally suggest visiting the Cybersecurity Consciousness Month web site.



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