DOL Steerage for Retirement Plan Cybersecurity

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

1. Ideas for hiring a retirement plan service supplier

2. Retirement plan cybersecurity finest practices

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

The DOL’s 3-Pronged Cybersecurity Plan

Given as we speak’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 property and participant knowledge of your retirement plan shoppers? Let’s assessment the specifics of the DOL steerage 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 may assist shoppers make the appropriate choice for his or her plans by making certain that they deal with the next finest 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 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 focus ought to be on contract provisions that give the shopper the appropriate to assessment audit outcomes, demonstrating compliance with the usual.

• Consider the service supplier’s business monitor document. Crimson flags may embrace info 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. 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 duty for info safety breaches, whereas different phrases improve cybersecurity safety for the plan and its contributors, together with:

  • Info 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 based mostly on finest practices will allow plan fiduciaries to behave prudently and mitigate cybersecurity danger. Remember to educate your plan sponsor shoppers on the next pillars of a great 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 providers

• Set up sturdy safety insurance policies, tips, and requirements.

• Conduct annual danger 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 knowledge entry management procedures.

• Be sure that any property 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 programs growth life cycle (SDLC) program (i.e., a proper means 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.

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

• Implement sturdy 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 suggestions for plan fiduciaries and contributors. Though the next suggestions may be acquainted, retaining them prime of thoughts will assist your shoppers and their plan contributors scale back the chance 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 concerning indicators of phishing assaults.

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

Cybersecurity Consciousness Mindset

In accordance with the DOL steerage for retirement plan cybersecurity, the insurance policies described above are designed to assist shield an estimated $9.3 trillion in plan property. This huge sum highlights the cyberthreats confronted by your plan sponsor shoppers and their plan contributors. Should you’re an advisor who helps or acts as a plan fiduciary, you’ve gotten an obligation to do your half in educating your shoppers concerning cybersecurity. It’s additionally a great enterprise observe—and a very good solution to construct relationships with retirement plan sponsors.

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