In an unrelated matter, the CFPB (Consumer Financial Protection Bureau) issued its first Consent Order against an online payment platform – questioning reasonable and appropriate data security practices not in place i.e. not meeting at least industry security standards. Citing mishap in employee data security training, lack of encryption, no periodic internal risk assessment and missing policies, procedures, etc.
Hence, CFPB issued order without prior report of a breach and is proactively representing consumers (which is adding to the growing awareness) and actions taken by authorities such as SEC and FTC (Securities and Exchange Commission and Federal Trade Commission). CFPB included the following recommendation:
- Annual/bi-annual security risk assessment
- 3-rd party to perform audit
- Maintaining reasonable procedures
- Encrypting data
- Regular employee training
- Appropriate customer identity authentication
- Update security patches for web and mobile applications
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