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 individuals. It lays out the obligations of “accountable plan fiduciaries” to mitigate cybersecurity dangers to retirement plan belongings and participant information. Concerning greatest practices, the DOL steering for retirement plan cybersecurity recommends a three-pronged strategy:

1. Ideas for hiring a retirement plan service supplier

2. Retirement plan cybersecurity greatest practices

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

The DOL’s 3-Pronged Cybersecurity Plan

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

How are you going to assist shield the belongings and participant information 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 possibly can assist shoppers make the best resolution for his or her plans by making certain that they concentrate on the next greatest practices when vetting third-party distributors:

• Ask in regards to the service supplier’s info safety requirements, practices, insurance policies, and audit outcomes. Your plan sponsor shoppers ought to examine this information with trade requirements.

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

• Consider the service supplier’s trade observe file. Purple flags would possibly embody info safety incidents, litigation, or authorized proceedings associated to the seller’s companies.

• Focus on 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 brought on by cybersecurity and identification theft breaches?

• Make 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 knowledge and confidentiality

  • Notification of cybersecurity breaches

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

  • Insurance coverage

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

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

  • Pinpoint dangers

  • Present mandatory safety

  • Establish cybersecurity occasions and reply to them

  • Work to revive operations and companies

• Set up sturdy 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 info safety roles and duties.

• Develop sturdy information entry management procedures.

• Make sure that any belongings or information 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 improvement life cycle (SDLC) program (i.e., a proper manner of making certain that sufficient safety controls are applied).

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

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

• Implement sturdy technical safety options and safety greatest practices (e.g., often replace antivirus software program and again up information).

• Appropriately reply to previous cybersecurity incidents.

3) On-line safety ideas for plan fiduciaries and individuals. Though the next ideas is perhaps acquainted, retaining 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 sturdy and distinctive passwords.

• Use multifactor authentication.

• Maintain private contact info 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 preserve 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 shield an estimated $9.3 trillion in plan belongings. This huge sum highlights the cyberthreats confronted by your plan sponsor shoppers and their plan individuals. In the event you’re an advisor who helps or acts as a plan fiduciary, you have got an obligation to do your half in educating your shoppers relating to cybersecurity. It’s additionally an excellent enterprise apply—and a very good solution to construct relationships with retirement plan sponsors.

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