How to Comply With NCUA 72 Hours Cyber Incident Reporting Timeline?

The National Credit Union Administration (NCUA) has passed advanced cyber incident reporting stipulation for credit unions. Under the latest rule, federally obligated credit unions must inform the NCUA of a "reportable cyber incident"; within 72 hours of such an event. The final rule keeps on the inclination of regulators increasing their focus on requiring faster notifications when incidents occur and, in particular, of the cybersecurity safeguards among financial institutions. On September 1, 2023, the final rule will go into effect.

To comply with NCUA 72 Hours cyber incident reporting timeline, credit unions need intact data inventory to report. Having a complete and accurate inventory of data is important for many reasons, such as regulatory compliance, data security, data privacy and effective data management. It allows credit unions to know your data, where it is located, how it is being used, and who has access to it. This information can be used to make informed decisions about data protection, data retention, and data deletion. Without a complete inventory, it can be difficult or impossible to accurately report on these metrics. Therefore, it is recommended that credit unions maintain an up-to-date and accurate data inventory to ensure proper data governance and compliance with regulations.

Having an intact data inventory can be very important for reporting purposes. A data inventory is essentially a list of all the data assets that a credit union possesses, including information on the data's location, ownership, and usage. If you have an intact data inventory, it can help you to better understand the data assets that your financial institution has and how they are being used. This, in turn, can help you to make more informed decisions and to report on the state of your data assets with greater accuracy.

About Reportable Cyber Incident

The regulation requires credit unions to inform the NCUA within 72 hours after it fairly accepts a reportable cyber incident has arised. A reportable cyber incident is described as any fundamental cyber incident that leads to:

A considerable loss of integrity, confidentiality or member information system or availability of a network that results from the forbidden access to or exposure of sensitive data, disrupts vital member services, or has a significant impact on the resiliency of operative systems, security and processes;
A disturbance of business operations, a member information system resulting from a cyberattack, or vital member services, or exploitation of vulnerabilities; and/or
A forbidden access to sensitive data is abetted through, or caused by, an understanding of a credit union service organization, managed and cloud service provider, or other third-party data hosting provider or a supply chain compromise .

Instance of Reportable Incidents

The NCUA's final rule contained some instances of what may constitute a reportable cyber incident, including, without limitation:

If a member information system has been illicitly updated and/or sensitive data has been left exposed to an illegitimate person, process, or device;
A failed system change or upgrade that results in impromptu widespread user outages for employees and credit union members ; or
A distributed denial of service (DDoS) strike that disrupts member account access.

The regulation does state that eventuality such as failed malware attacks or unsuccessful endeavors to gain ingress to systems do not have to be reported. Moreover , third-party incidents that are undetermined to a credit union and hold data about individuals who happen to be credit union members or employees do not inflict a notification requirement.

How Should Incidents Be Reported?

In accordance with the final rule, incidents may be outlined to the NCUA "via telephone or email, or other identical methods that the NCUA may stipulate." The reporting procedures are intended to give credit unions affability based upon the effect of a potential cyber incident. The NCUA has also emphasized that an initial report does not have to include a full assessment of the incident.

Upcoming Steps for Credit Unions

The NCUA will be providing further guidance, together with examples of non-reportable and reportable incidents, before the final rule becomes effective in September. In the meantime, credit unions must be updating and reviewing their incident response plans and vendor management programs to make sure that they are prepared to comply with these enhanced necessities.

Ardent Privacy's solution helps credit unions in discovering, identifying, and mapping data from Personal Identifiable Information (PII) to sensitive data assets.It also reduces their unwanted or excess data footprint to become compliant and resilient in case of a “reportable cyber incident”. It also provides discovery capabilities essential to meet privacy requirements for compliance (CCPA/CPRA, Virginia CDPA, Colorado Privacy act, Utah Consumer Privacy Act, Connecticut Data Privacy Act), such as data inventory, identification, data subject access requests (DSAR) and data minimization. Credit unions collect and retain vast amounts of personal data which represents a substantial liability for privacy compliance. By utilizing the Ardent Privacy solution, credit unions can reduce risk and liability by limiting excess storage of personal data. Data minimization reduces the costs associated with securing data and storage. It is vital for financial institutes to know what data they have and only keep what they need to do business.

To learn more about how Ardent Privacy can help you comply with the NCUA’s final rule on Cyber Incident Reporting in a 72 hours timeframe, reach out to schedule a demo with one of our technical experts.

About Ardent Privacy

Ardent Privacy is an "Enterprise Data Privacy Technology" solutions provider based in the Maryland/DC region of the United States and Pune, India. Ardent harnesses the power of AI to enable companies with data discovery and automated compliance with various global regulations by taking a data-driven approach. Ardent Privacy's solution utilizes machine learning and artificial intelligence to identify, inventory, map, minimize, and securely delete data in enterprises to reduce legal and financial liability.