Information Security Program
Your Information Security Program. Living, not laminated.
GLBA requires it. Examiners test it. Most institutions inherit one that no longer matches how they actually operate. We build board-approved policies and the program around them, aligned to NIST CSF 2.0 and written for the people expected to follow them.
Delivered by a US-based cyberteam serving financial institutions exclusively.
The Problem
Most policies are written for the auditor. Yours should work for both.
Walk into most institutions and the information security program is a binder: templates bought years ago, edited by whoever held the role at the time, approved annually by a board that has never been shown what changed. It satisfies the checkbox until an examiner reads it next to how the institution actually operates. Then the gaps become findings.
We write policies people can follow and a program the board can genuinely oversee. Every document is right-sized to your institution, mapped to NIST CSF 2.0 and GLBA requirements, and kept on a review cycle so it adapts as your technology, vendors, and risks change instead of sitting frozen on a shelf.
The Program
More than documents. A program your board can stand behind.
GLBA asks for more than a policy binder. These four elements make the program real, and we deliver all of them.
Foundation
Right-sized policy library
A complete set of information security policies written for your size, complexity, and technology stack, not a 400-page template with your logo on it.
Oversight
Board reporting & approval
Annual board packages that show what changed, why it changed, and where the risks are, so approval is informed oversight rather than a rubber stamp.
Adoption
Training & awareness
Policies only work if people know them. We translate the library into role-based training and acknowledgment tracking your HR team can run.
Maintenance
Annual review cycle
Every policy carries an owner and a review date. We manage the cycle, propose updates as regulations and technology shift, and keep the register current.
The Policy Library
Twenty-plus policies. Right-sized to your institution.
The library covers the full scope examiners expect, anchored by the capstone Information Security Policy and extending through access, data, vendors, and emerging technology. Each policy is mapped to the NIST CSF 2.0 functions and GLBA safeguards it satisfies, so coverage is demonstrable, not assumed.
Incident response and business continuity policies are delivered through our dedicated Incident Response & Testing and BCP Risk & Control programs, where they belong next to the plans and exercises that keep them honest.
How it Works
From inherited binder to living program.
A structured engagement with a clear finish line, then a maintenance rhythm that keeps you there.
Program Build
Sequential
Step 01
Review
Weeks 1-2
We inventory your current library, ownership, approval history, and how policies map to what your institution actually does.
Step 02
Gap assessment
Weeks 2-4
Each policy is measured against NIST CSF 2.0, GLBA safeguards, and examiner expectations. Gaps become a prioritized build list.
Outcomes
What done looks like.
Examiner-ready
Demonstrable coverage
Every policy maps to the NIST CSF 2.0 functions and GLBA safeguards it satisfies, with approval history and review dates on record. Coverage is shown, not claimed.
Actually usable
Policies people follow
Written in plain language, right-sized to your operations, and backed by training and acknowledgment tracking, so the program lives in daily work rather than a shared drive.
Living
A maintained register
Owners, review cycles, and update proposals keep every document current as technology, vendors, and regulations shift. Nothing sits frozen on a shelf.
