DOL Steering for Retirement Plan Cybersecurity

Earlier this 12 months, 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 information. Relating to finest practices, the DOL steerage 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 contributors

The DOL’s 3-Pronged Cybersecurity Plan

Given at this time’s heightened cybersecurity dangers, adopting a security-first mindset is crucial 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 will you assist shield the property and participant information of your retirement plan shoppers? Let’s evaluation the specifics of the DOL steerage 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 shoppers make the fitting determination for his or her plans by guaranteeing that they deal with the next finest practices when vetting third-party distributors:

• Ask in regards to the service supplier’s data safety requirements, practices, insurance policies, and audit outcomes. Your plan sponsor shoppers ought to evaluate 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 must be on contract provisions that give the consumer the fitting to evaluation audit outcomes, demonstrating compliance with the usual.

• Consider the service supplier’s business observe report. Purple flags may embody 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 identification 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 accountability 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 finest practices. Creating a coverage based mostly on finest practices will allow plan fiduciaries to behave prudently and mitigate cybersecurity threat. Make sure 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 data. This system ought to:

  • Pinpoint dangers

  • Present vital safety

  • Establish 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 tasks.

• Develop robust information entry management procedures.

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

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

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

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

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

• Appropriately reply to previous cybersecurity incidents.

3) On-line safety ideas for plan fiduciaries and contributors. Though the next ideas is likely to be acquainted, preserving them high of thoughts will assist your shoppers and their plan contributors cut 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.

• Hold 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 preserve apps and software program present.

Cybersecurity Consciousness Mindset

In keeping 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. In the event you’re an advisor who helps or acts as a plan fiduciary, you may have an obligation to do your half in educating your shoppers concerning cybersecurity. It’s additionally a great enterprise observe—and a very good strategy 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 advocate visiting the Cybersecurity Consciousness Month web site.