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Run: GLBA Information Security Program Annual Review

Use this GLBA Information Security Program Annual Review template to verify your written security program, risk assessment, and safeguards are current, docum...

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Inspection Scope and Program Governance

Document the date range reviewed and the business units, systems, and locations included in scope.
Verify the program document is current, version-controlled, and formally approved by management or the governing body.
Confirm a qualified individual is assigned responsibility for overseeing, implementing, and reporting on the information security program.
Verify the written information security program has been reviewed at least annually and after material changes to operations or risks.
Confirm periodic reporting to the board, committee, or senior management includes program status, risk findings, and remediation progress.

Risk Assessment and Information Inventory

Verify a written risk assessment exists, is dated, and reflects current systems, vendors, and business processes.
Confirm the organization maintains an inventory of customer information, systems, repositories, and data flows in scope.
Verify the assessment evaluates reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information.
Confirm the assessment addresses vendors, cloud providers, processors, and other service providers that store, process, or transmit customer information.
Verify each material risk has a documented treatment decision, owner, due date, and status.

Administrative Safeguards

Confirm access to customer information is granted based on job role and reviewed periodically for appropriateness.
Verify employees and relevant contractors receive periodic security awareness training and completion is documented.
Confirm the organization has documented procedures for identifying, escalating, containing, and reporting security incidents.
Verify security-related changes, exceptions, and compensating controls are approved, tracked, and time-bound.
Confirm prior audit findings, deficiencies, and non-conformances have assigned owners, due dates, and closure evidence.

Technical Safeguards

Verify MFA is required for remote access, privileged access, and other access paths where customer information is exposed.
Confirm user provisioning, deprovisioning, privileged access review, and periodic recertification are operating effectively.
Verify encryption or equivalent compensating controls are used for customer information stored on systems and transmitted across networks.
Confirm security logs are collected, protected from tampering, and reviewed for suspicious activity and critical events.
Verify vulnerabilities are identified, prioritized, remediated within defined service levels, and exceptions are approved.

Physical Safeguards and Facility Controls

Confirm access to records rooms, server rooms, and other sensitive areas is limited to authorized personnel.
Verify customer information in paper or portable form is stored in locked cabinets, secure rooms, or equivalent protections.
Confirm visitors are logged and escorted where required, and sensitive information is not left exposed in public or shared areas.

Findings, Corrective Actions, and Approval

List all findings observed during the review, including the affected control, severity, and evidence.
Document the responsible owner, remediation plan, and target completion date for each open finding.
Inspector confirms the review was completed accurately and evidence supports the recorded results.

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