According to Jackie Marshall, Gladiatorâs director of IT regulatory compliance, âOur eSAT program has proven to be a valuable tool that makes it easier for our clients to comply with GLBA guidance, and provides an audit trail to ensure that bank personnel understand and accept their institutionâs related policies and procedures. This new enhancement addresses the extension of the responsibility to protect non-public customer information beyond bank employees to include the board of directors. Because the board is ultimately responsible for the success of an institutionâs Information Security Program and Identity Theft Prevention Program, board members must have the knowledge to fulfill their responsibility to proactively protect customersâ confidential information and ultimately the bankâs reputation.â
Danny Johnston, group president of Gladiator Technology, added, âFinancial institutions should now ensure that their boards â just like front-line and operations employees â are fully and regularly trained to protect non-public information, at least annually. This training should be specialized for its board membersâ roles and help ensure members understand the tangible and intangible risks associated with handling highly sensitive customer information. To that end, we have tailored our eSAT Board of Directors Training to emphasize the vital role board members have in adequately safeguarding non-public information.
Compliance with the Identity Theft Prevention Program mandated by modifications to the FACT Act was required by November 1, 2008. Gladiatorâs eSAT program has also been recently expanded with the content required to train all financial institution employees to comply with these identity theft âred flagâ provisions.