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FTC Extends Safeguards Rule Compliance Deadline for Financial Institutions

Financial institutions covered by the Safeguards RuleNovember 15, 2022Federal Trade Commission

Summary

The FTC extended the compliance deadline for certain provisions of the Safeguards Rule by six months to June 9, 2023, due to challenges like shortage of qualified personnel and supply chain issues exacerbated by the COVID-19 pandemic. The rule requires non-banking financial institutions to implement enhanced data security measures, and the extension aims to facilitate compliance, especially for small entities.

Contract Impact

In-house legal teams should review vendor agreements, customer contracts, and employee data handling policies to ensure they incorporate requirements from the Safeguards Rule under the Gramm-Leach-Bliley Act. Specifically, clauses related to data security programs, risk assessments, access controls, encryption, incident response, and vendor management must be updated to mandate compliance with the Rule. Contracts should include audit rights to verify security practices, breach notification obligations aligned with the Rule, and requirements for regular security training. For small entities, consider including provisions for phased implementation or deadline extensions to align with the June 2023 compliance date, and ensure indemnification clauses cover data security failures.

Contract Search Terms

Safeguards Ruledata security programcomprehensive security programrisk assessmentaccess controlsencryptionincident response planvendor managementaudit rightssecurity standards

Laws Cited

Gramm-Leach-Bliley Act

Violation Types

Entity Details

Entity

Financial institutions covered by the Safeguards Rule

Also known as: Financial Institutions

Industry

Financial Services

Official Sources

Source Evidence

Entity Name
"Financial institutions covered by the Safeguards Rule"
Laws Cited
"Gramm-Leach-Bliley Act"

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