Rapid Regulatory Assessment

ENGAGEMENT

The Security organization for a large financial institution was concerned about its readiness for the forthcoming updated FTC Safeguards regulations. DayBlink Consulting led and managed an FTC Safeguards assessment to help the client evaluate its compliance against the Rule elements and controls. DayBlink Consulting was responsible for gathering information via stakeholder interviews and systems analysis, identifying gap areas, and synthesizing results into a roadmap, formal documentation, and PowerBI data visualizations. Additionally, DayBlink Consulting assisted with remediating the gaps.

PROBLEM

The Security organization was informed that, in roughly 18 months, newly updated Safeguards with greater regulatory rigidity would be enforced by the FTC. These updated controls enhanced and extended what was currently required. In addition to an updated control set, the client requested interpretation of several control requirements to ensure agreed-upon definitions. The control set was vague and lacked specific markers for the organization to follow. 

As a result, DayBlink Consulting was the support system to ensure comprehensive coverage. The client also required a third-party to fairly evaluate the people, processes, and technologies under the scope of coverage, identify the gaps, and develop a remediation roadmap prior to the enforcement of the regulation. This included not only DayBlink Consulting’s view on the coverage and gaps but also third-party legal counsel, which was facilitated by DayBlink Consulting.

SOLUTION

DayBlink Consulting was engaged to conduct a comprehensive controls assessment. This multi-faceted approach began with stakeholder engagement, involving interviews with over 50 stakeholders across various levels and departments. Each interview was meticulously planned to cover the stakeholder’s area of expertise related to the FTC Safeguards, encompassing documentation, personnel, key processes, existing identified gaps, and more. This thorough engagement ensured that DayBlink Consulting had a deep understanding of the organization’s current state and potential vulnerabilities. In parallel, DayBlink Consulting reviewed over 60 policy &  standard documents. This review provided a detailed view of the existing framework and highlighted areas needing improvement. The policy review was critical in identifying inconsistencies and gaps in the current documentation, which could pose compliance risks under new regulations.

DayBlink Consulting also inspected key systems and data connections to understand the technical landscape. This step was crucial as it provided insights into how data flowed through the organization and where vulnerabilities might exist. Mapping these connections and identifying potential weak points were instrumental in developing a robust remediation plan. From the discovery and analysis phase, DayBlink Consulting articulated and prioritized the identified gaps. These findings were synthesized into a clear and actionable roadmap, which was then presented to security and company leadership, as well as the security review board. This presentation ensured that the necessary buy-in was achieved from all levels of the organization. Collaboration with outside legal counsel was an essential step to ensure that the interpretations and implementations of the controls were legally sound and defensible.

DayBlink Consulting developed an 18-month remediation roadmap, outlining specific actions and timelines for addressing each identified gap. This roadmap was supported by a set of PowerBI dashboards and tracking documents, which provided a transparent and dynamic way to monitor progress, assign responsibilities, and ensure accountability. These tools were critical in keeping the remediation efforts on track and ensuring that all stakeholders were aligned and informed throughout the process.

Additionally, DayBlink Consulting supported the development of a budget to align on the cost of remediating each of the activities. This budget ranged from must-be-completed-for-compliance actions to nice-to-have enhancements for improving the overall security posture. By providing a clear financial framework, DayBlink Consulting helped the client prioritize remediation activities based on their criticality and available resources.

As the assessment and planning phase concluded, the value of DayBlink Consulting’s  expertise and methodology became evident. Recognizing this, the client requested DayBlink Consulting to continue the engagement to manage the remediation program across the technology organization. This extended engagement included assisting with closing and remediating the gaps, ensuring that the timeline and budget across all 15 workstreams of remediation remained on track. DayBlink Consulting’s ongoing involvement provided the continuity and expertise necessary to drive the remediation efforts to completion.

RESULT

Over the course of the assessment, DayBlink Consulting identified 108 remediation opportunities across a range of priorities, encompassing both technology and process issues. These remediation opportunities were categorized and prioritized to provide a clear path forward for the client.

DayBlink Consulting worked closely with leaders across the organization to ensure their understanding of the relevant remediation findings and their responsibilities. DayBlink Consulting’s team managed the completion of the activities for over a year beyond the initial assessment, providing continuous support and guidance to the client.

The results of the assessment and the tracking of gap completion were reported monthly by DayBlink Consulting across the organization. These regular updates ensured transparency and kept the entire organization aligned with the compliance objectives. 

Through meticulous planning, thorough execution, and continuous engagement, DayBlink Consulting delivered a solution that not only met regulatory requirements but also strengthened the client’s overall cybersecurity posture. The sustained support and proactive management established a robust framework for continued success and adaptability in an ever-evolving regulatory landscape. This engagement not only addressed immediate compliance needs but also laid the foundation for a more resilient and secure organizational framework.