Introduction
The security of member information is paramount for all credit unions. Regulatory frameworks, such as 12 CFR Part 748, provide a structured approach to safeguarding this sensitive data. This article delves into the specific requirements that credit unions must adhere to, regarding the protection of member information and cybersecurity, which are primarily discussed in Appendix A of the Part 748 Guidelines.
Security Program Requirements
Each federally Insured credit unions must establish a written security program within 90 days of the effective date of insurance. This program is the foundation of a credit union’s commitment to securing member information and should be comprehensive, addressing all facets of security. Part 748 requires the written security program to address physical security as well as information security, this article will focus on the information security aspects of it that are discussed in Appendix A.
Detailed Guidelines
Here is a detailed list of the guidelines from 12 CFR Part 748 for information security requirements for credit unions:
1. Develop a Written Security Program: A formal program must be in place within 90 days of the effective date of insurance, outlining the security measures to protect member information. This plan should be detailed in size and complexity that is appropriate to the nature and scope of the Credit Union’s activities.
2. Involve the Board of Directors – The board of directors must approve the written security policy and programs and they must also oversee its development, implementation, and maintenance.
2. Conduct Regular Risk Assessments: Identify potential risks to member information systems from internal and external sources. These assessments must assess the likelihood and potential damage of these threats and determine efficacy of the safeguards in place.
3. Manage and Control Identified Risks – Controls must be designed, developed, and implemented to control the risks identified above.
4. Establish Security Policies and Procedures: Maintain written policies and procedures to protect member information against unauthorized access or use.
5. Implement Access Controls: Control access to member information systems to prevent unauthorized entry and data breaches. This should include policies and procedures that limit employees access only to what they need. Controls should be established to properly authenticate users before access is granted.
6. Encrypt Sensitive Member Information: Use encryption to protect sensitive data from unauthorized disclosure while in transit or at rest.
7. Develop an Incident Response Program: Prepare for potential security breaches with a response program that addresses unauthorized access to member information.
8. Train Employees: Ensure that all employees are aware of information security protocols and procedures. Credit unions should track and document the progress of employees training.
9. Monitor and Test Security Programs: Regularly test the effectiveness of security measures and adjust as necessary. This should include system monitoring as well as internal and external vulnerability scanning and remediation.
10. Provide Member Notice: Inform members about the credit union’s practices regarding information security.
13. Respond to Catastrophic Acts and Cyber Incidents: Have procedures in place to address catastrophic events and cyber incidents.
14. Properly Dispose of Records: Ensure the proper disposal of records containing nonpublic personal information to maintain member privacy.
Conclusion
The guidelines outlined in 12 CFR Part 748 are not merely regulatory requirements; they are essential practices for the protection of member information. Credit unions must remain vigilant and proactive in their approach to information security, continually adapting to new threats and maintaining the trust of their members.
This information was gathered from the CFR 12 Part 748 found here. There are many more details to review there. If you would like to discuss your situation and how you can be sure you are compliant, please contact us here or by calling our office at 484-443-4000.
