DOL Steerage for Retirement Plan Cybersecurity

Earlier this yr, the DOL’s Worker Advantages Safety Administration issued cybersecurity steerage for retirement plan sponsors, fiduciaries, recordkeepers, and individuals. 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 steerage for retirement plan cybersecurity recommends a three-pronged strategy:

1. Ideas for hiring a retirement plan service supplier

2. Retirement plan cybersecurity finest practices

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

The DOL’s 3-Pronged Cybersecurity Plan

Given in the present day’s heightened cybersecurity dangers, adopting a security-first mindset is important for advisors within the retirement plan area. By educating your shoppers in regards to the DOL’s cybersecurity expectations, you’ll construct relationships with retirement plan sponsors and enhance the worth you present them.

How are you going to assist defend the belongings and participant information of your retirement plan shoppers? Let’s evaluate the specifics of the DOL steerage for retirement plan cybersecurity.

1) Ideas 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 determination for his or her plans by guaranteeing that they concentrate on 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 trade requirements.

• Find out how the service supplier validates its practices and which ranges of safety requirements it has met and carried out. Right here, the main target needs to be on contract provisions that give the shopper the proper to evaluate audit outcomes, demonstrating compliance with the usual.

• Consider the service supplier’s trade monitor file. Purple flags would possibly embody data safety incidents, litigation, or authorized proceedings associated to the seller’s companies.

• 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?

• Make 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 individuals, 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 primarily based on finest practices will allow plan fiduciaries to behave prudently and mitigate cybersecurity danger. 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 obligatory safety

  • Establish cybersecurity occasions and reply to them

  • Work to revive operations and companies

• Set up sturdy safety insurance policies, tips, 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 data safety roles and obligations.

• Develop sturdy information entry management procedures.

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

• Implement and handle a safe methods growth life cycle (SDLC) program (i.e., a proper method of guaranteeing that enough safety controls are carried out).

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

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

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

• Appropriately reply to previous cybersecurity incidents.

3) On-line safety ideas for plan fiduciaries and individuals. Though the next ideas is likely to be acquainted, preserving them high of thoughts will assist your shoppers and their plan individuals scale back the danger 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 data 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 preserve apps and software program present.

Cybersecurity Consciousness Mindset

In response to the DOL steerage 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 individuals. In the event you’re an advisor who helps or acts as a plan fiduciary, you have got an obligation to do your half in educating your shoppers relating to cybersecurity. It’s additionally a great enterprise follow—and a very good solution to construct relationships with retirement plan sponsors.

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