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 members. It lays out the obligations of “accountable plan fiduciaries” to mitigate cybersecurity dangers to retirement plan belongings and participant information. Relating to finest 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 finest practices

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

The DOL’s 3-Pronged Cybersecurity Plan

Given at this time’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 enhance the worth you present them.

How will you assist defend the belongings and participant information of your retirement plan shoppers? 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 may assist shoppers make the proper resolution for his or her plans by guaranteeing 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 examine this information with business 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 consumer the proper to assessment audit outcomes, demonstrating compliance with the usual.

• Consider the service supplier’s business monitor report. Crimson flags may embrace 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. If that’s the 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 id theft breaches?

• Be certain that the service supplier contract requires ongoing compliance with cybersecurity and data 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 members, 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 data 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 danger. Remember to educate your plan sponsor shoppers on the next pillars of 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 info. This system ought to:

  • Pinpoint dangers

  • Present obligatory 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 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 tasks.

• Develop sturdy information entry management procedures.

• Be certain that any belongings or information saved in a cloud or managed by a third-party service supplier are topic to acceptable safety evaluations and unbiased safety assessments.

• Implement and handle a safe techniques improvement life cycle (SDLC) program (i.e., a proper approach of guaranteeing that sufficient safety controls are applied).

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

• Be certain that delicate information is encrypted whereas saved and in transit.

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

• Appropriately reply to previous cybersecurity incidents.

3) On-line safety ideas for plan fiduciaries and members. Though the next ideas is perhaps acquainted, maintaining them high of thoughts will assist your shoppers and their plan members 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.

• Hold 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 maintain 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 members. If you happen to’re an advisor who helps or acts as a plan fiduciary, you will have an obligation to do your half in educating your shoppers relating to cybersecurity. It’s additionally enterprise follow—and a very good solution 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 advocate visiting the Cybersecurity Consciousness Month web site.