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. Concerning greatest practices, the DOL steering for retirement plan cybersecurity recommends a three-pronged method:

1. Suggestions for hiring a retirement plan service supplier

2. Retirement plan cybersecurity greatest practices

3. On-line safety ideas 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 purchasers 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 shield the belongings and participant knowledge of your retirement plan purchasers? Let’s assessment the specifics of the DOL steering for retirement plan cybersecurity.

1) Suggestions 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 purchasers make the best determination for his or her plans by making certain that they give attention to the next greatest practices when vetting third-party distributors:

• Ask concerning the service supplier’s data safety requirements, practices, insurance policies, and audit outcomes. Your plan sponsor purchasers 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 carried out. Right here, the main focus must be on contract provisions that give the shopper the best to assessment audit outcomes, demonstrating compliance with the usual.

• Consider the service supplier’s trade monitor document. Crimson flags would possibly embrace 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. 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 id theft breaches?

• Be sure that the service supplier contract requires ongoing compliance with cybersecurity and data safety requirements. Some contract provisions could restrict the service supplier’s duty for data 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 knowledge and confidentiality

  • Notification of cybersecurity breaches

  • Compliance with data retention and destruction, privateness, and data 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. Make sure you educate your plan sponsor purchasers on the next pillars of an excellent coverage:

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

  • Pinpoint dangers

  • Present needed safety

  • Determine cybersecurity occasions and reply to them

  • Work to revive operations and providers

• 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 data safety roles and duties.

• 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 unbiased safety assessments.

• Implement and handle a safe methods improvement life cycle (SDLC) program (i.e., a proper approach of making certain that ample 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 robust technical safety options and safety greatest practices (e.g., often 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 may be acquainted, conserving them high of thoughts will assist your purchasers 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.

• Preserve private contact data 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 keeping 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 purchasers and their plan contributors. When you’re an advisor who helps or acts as a plan fiduciary, you’ve gotten an obligation to do your half in educating your purchasers concerning cybersecurity. It’s additionally an excellent enterprise observe—and a very good solution to construct relationships with retirement plan sponsors.

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