How Identity and Access Management Supports the FTC Safeguards Rule

Access controls

(1) Implementing and periodically reviewing access controls, including technical and, as appropriate, physical controls to: (i) Authenticate and permit access only to authorized users to protect against the unauthorized acquisition of customer information; and (ii) Limit authorized users' access only to customer information that they need to perform their duties and functions, or, in the case of customers, to access their own information;

In practice: Access to systems holding customer information follows job role, requests need a recorded approval, and managers review each team's access on a regular cycle, removing what is no longer required.

Multi-factor authentication

(5) Implement multi-factor authentication for any individual accessing any information system, unless your Qualified Individual has approved in writing the use of reasonably equivalent or more secure access controls;

In practice: Staff and administrators complete a second sign-in factor, often a phishing-resistant method, and any equivalent control the Qualified Individual approves in writing is recorded with its reason.

Risk assessment

(b) Base your information security program on a risk assessment that identifies reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assesses the sufficiency of any safeguards in place to control these risks. (1) The risk assessment shall be written and shall include: (i) Criteria for the evaluation and categorization of identified security risks or threats you face; (ii) Criteria for the assessment of the confidentiality, integrity, and availability of your information systems and customer information, including the adequacy of the existing controls in the context of the identified risks or threats you face; and (iii) Requirements describing how identified risks will be mitigated or accepted based on the risk assessment and how the information security program will address the risks. (2) You shall periodically perform additional risk assessments that reexamine the reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and reassess the sufficiency of any safeguards in place to control these risks.

In practice: The security team's risk assessment includes access facts that identity supplies, such as the number of privileged accounts and the results of the latest access reviews.

Data, personnel, devices, systems and facilities inventory

(2) Identify and manage the data, personnel, devices, systems, and facilities that enable you to achieve business purposes in accordance with their relative importance to business objectives and your risk strategy;

In practice: The asset owners keep the inventory; identity contributes the authoritative list of workers, registered devices and service accounts that the inventory can point to.

Monitoring and logging of authorized user activity

(8) Implement policies, procedures, and controls designed to monitor and log the activity of authorized users and detect unauthorized access or use of, or tampering with, customer information by such users.

In practice: The security operations team does the monitoring; identity sends sign-in, elevation and entitlement-change events and privileged session recordings so unusual use of customer information can be spotted.

Testing and monitoring

(d)(1) Regularly test or otherwise monitor the effectiveness of the safeguards' key controls, systems, and procedures, including those to detect actual and attempted attacks on, or intrusions into, information systems. (2) For information systems, the monitoring and testing shall include continuous monitoring or periodic penetration testing and vulnerability assessments.

In practice: The security team owns testing and monitoring; identity adds recurring checks of access configuration and access review outcomes as inputs to that work.

Service provider oversight

(f) Oversee service providers, by: (1) Taking reasonable steps to select and retain service providers that are capable of maintaining appropriate safeguards for the customer information at issue; (2) Requiring your service providers by contract to implement and maintain such safeguards; and (3) Periodically assessing your service providers based on the risk they present and the continued adequacy of their safeguards.

In practice: Vendor staff who touch customer information get sponsored, time-limited accounts, and the vendor-oversight owner can review those accounts and integrations as part of provider assessments.

Qualified Individual

(a) Designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program (for purposes of this part, “Qualified Individual”). The Qualified Individual may be employed by you, an affiliate, or a service provider. To the extent the requirement in this paragraph (a) is met using a service provider or an affiliate, you shall: (1) Retain responsibility for compliance with this part; (2) Designate a senior member of your personnel responsible for direction and oversight of the Qualified Individual; and (3) Require the service provider or affiliate to maintain an information security program that protects you in accordance with the requirements of this part.

Encryption

(3) Protect by encryption all customer information held or transmitted by you both in transit over external networks and at rest. To the extent you determine that encryption of customer information, either in transit over external networks or at rest, is infeasible, you may instead secure such customer information using effective alternative compensating controls reviewed and approved by your Qualified Individual;

Secure development

(4) Adopt secure development practices for in-house developed applications utilized by you for transmitting, accessing, or storing customer information and procedures for evaluating, assessing, or testing the security of externally developed applications you utilize to transmit, access, or store customer information;

Secure disposal

(6)(i) Develop, implement, and maintain procedures for the secure disposal of customer information in any format no later than two years after the last date the information is used in connection with the provision of a product or service to the customer to which it relates, unless such information is necessary for business operations or for other legitimate business purposes, is otherwise required to be retained by law or regulation, or where targeted disposal is not reasonably feasible due to the manner in which the information is maintained; and (ii) Periodically review your data retention policy to minimize the unnecessary retention of data;

Change management

(7) Adopt procedures for change management; and

Personnel

(e) Implement policies and procedures to ensure that personnel are able to enact your information security program by: (1) Providing your personnel with security awareness training that is updated as necessary to reflect risks identified by the risk assessment; (2) Utilizing qualified information security personnel employed by you or an affiliate or service provider sufficient to manage your information security risks and to perform or oversee the information security program; (3) Providing information security personnel with security updates and training sufficient to address relevant security risks; and (4) Verifying that key information security personnel take steps to maintain current knowledge of changing information security threats and countermeasures.

Evaluate and adjust the program

(g) Evaluate and adjust your information security program in light of the results of the testing and monitoring required by paragraph (d) of this section; any material changes to your operations or business arrangements; the results of risk assessments performed under paragraph (b)(2) of this section; or any other circumstances that you know or have reason to know may have a material impact on your information security program.

Incident response plan

(h) Establish a written incident response plan designed to promptly respond to, and recover from, any security event materially affecting the confidentiality, integrity, or availability of customer information in your control. Such incident response plan shall address the following areas: (1) The goals of the incident response plan; (2) The internal processes for responding to a security event; (3) The definition of clear roles, responsibilities, and levels of decision-making authority; (4) External and internal communications and information sharing; (5) Identification of requirements for the remediation of any identified weaknesses in information systems and associated controls; (6) Documentation and reporting regarding security events and related incident response activities; and (7) The evaluation and revision as necessary of the incident response plan following a security event.

Reporting to the board

(i) Require your Qualified Individual to report in writing, regularly and at least annually, to your board of directors or equivalent governing body. If no such board of directors or equivalent governing body exists, such report shall be timely presented to a senior officer responsible for your information security program. The report shall include the following information: (1) The overall status of the information security program and your compliance with this part; and (2) Material matters related to the information security program, addressing issues such as risk assessment, risk management and control decisions, service provider arrangements, results of testing, security events or violations and management's responses thereto, and recommendations for changes in the information security program.

Notification to the Federal Trade Commission

(j) Notify the Federal Trade Commission about notification events in accordance with paragraphs (j)(1) and (2) of this section. [Paragraphs (j)(1) and (j)(2), which set the 500-consumer threshold, the 30-day deadline and the content of the notice, are not reproduced here.]