DOL Steering for Retirement Plan Cybersecurity

Earlier this yr, the DOL’s Worker Advantages Safety Administration issued cybersecurity steering for retirement plan sponsors, fiduciaries, recordkeepers, and individuals. It lays out the obligations of “accountable plan fiduciaries” to mitigate cybersecurity dangers to retirement plan belongings and participant knowledge. Concerning 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 suggestions for plan fiduciaries and individuals

The DOL’s 3-Pronged Cybersecurity Plan

Given right this moment’s heightened cybersecurity dangers, adopting a security-first mindset is important for advisors within the retirement plan house. 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 evaluation 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’ll be able to assist shoppers make the proper resolution for his or her plans by making certain that they concentrate on the next finest practices when vetting third-party distributors:

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

• Learn the way the service supplier validates its practices and which ranges of safety requirements it has met and applied. Right here, the main focus needs to be on contract provisions that give the shopper the proper to evaluation audit outcomes, demonstrating compliance with the usual.

• Consider the service supplier’s trade monitor document. Purple flags may embody info safety incidents, litigation, or authorized proceedings associated to the seller’s companies.

• Talk about whether or not the service supplier has skilled previous safety breaches. In that 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 attributable to cybersecurity and identification theft breaches?

• Be sure that the service supplier contract requires ongoing compliance with cybersecurity and knowledge safety requirements. Some contract provisions might restrict the service supplier’s accountability for info safety breaches, whereas different phrases improve cybersecurity safety for the plan and its individuals, together with:

  • Data safety reporting

  • Provisions on the use and sharing of data and confidentiality

  • Notification of cybersecurity breaches

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

  • Insurance coverage

2) Retirement plan cybersecurity finest practices. Creating a coverage primarily based on finest practices will allow plan fiduciaries to behave prudently and mitigate cybersecurity threat. Be sure you educate your plan sponsor shoppers on the next pillars of a very good 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 info. This system ought to:

  • Pinpoint dangers

  • Present needed safety

  • Determine cybersecurity occasions and reply to them

  • Work to revive operations and companies

• Set up robust safety insurance policies, tips, 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 info safety roles and obligations.

• Develop robust knowledge entry management procedures.

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

• Implement and handle a safe techniques growth life cycle (SDLC) program (i.e., a proper means of making certain that ample safety controls are applied).

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

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

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

• Appropriately reply to previous cybersecurity incidents.

3) On-line safety suggestions for plan fiduciaries and individuals. Though the next suggestions is likely to be acquainted, preserving them high of thoughts will assist your shoppers and their plan individuals cut 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.

• Preserve private contact info present.

• Shut or delete unused accounts.

• Be cautious of free Wi-Fi.

• Be within the know concerning indicators of phishing assaults.

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

Cybersecurity Consciousness Mindset

In line with 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 individuals. If you happen to’re an advisor who helps or acts as a plan fiduciary, you may have an obligation to do your half in educating your shoppers concerning cybersecurity. It’s additionally a very good enterprise apply—and a very good technique to construct relationships with retirement plan sponsors.

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