University Of The Cumberlands 833 Information Governance

University Of The Cumberlandsits 833 Information Governancespring

Develop a comprehensive Information Governance Policy/Program for Merchant Bank of America (MBA) related to its merchant customers who allow their clients to purchase on credit using credit cards linked to checking accounts at MBA. The policy must protect sensitive information, comply with legal regulations, including PCI DSS, and specify roles, responsibilities, policies, procedures, third-party management, disaster recovery, and auditing processes tailored to MBA’s operations.

Paper For Above instruction

The rapidly evolving financial industry demands robust Information Governance (IG) policies, particularly for institutions like Merchant Bank of America (MBA) that handle sensitive credit card transaction data. The goal of this paper is to develop a comprehensive IG policy tailored explicitly for MBA, focusing on its merchant customers' credit card transactions. The policy will delineate roles and responsibilities, applicable policies, operational procedures, third-party management, incident response, compliance requirements, and continuous monitoring to ensure data security, legal compliance, and operational efficiency.

Introduction

Information Governance (IG) encompasses the management of information throughout its lifecycle, ensuring that data is accurate, secure, accessible, and compliant with applicable laws. For MBA, a financial institution that processes credit card transactions for merchant clients, establishing a tailored IG policy is critical to protect data, support legal and regulatory compliance, and maintain customer trust. The nature of the data—credit card details, transaction records, bank account information—necessitates strict adherence to PCI DSS standards, legal privacy requirements, and internal controls.

Scope of the Information Governance Program

The scope of MBA's IG framework covers all staff involved in creating, sharing, storing, and disposing of transaction-related data within the organization. It includes all electronic and paper-based information systems, whether stored internally or with external third-party vendors. It also addresses data relevant to legal and regulatory obligations, such as PCI DSS compliance and data privacy laws. Specifically, the data involved in credit card transactions, merchant deposit details, and associated customer information fall within the scope.

Roles and Responsibilities

An effective IG program requires clearly defined roles and responsibilities. The role of the Information Governance Committee involves overseeing policy compliance, periodic reviews, and strategic direction. Committee members include senior executives from compliance, IT, legal, and operations departments. The Information Governance Team handles day-to-day implementation, policy enforcement, and incident management. The Information Risk Management unit assesses vulnerabilities and ensures risk mitigation strategies are in place. The Records Manager oversees documentation lifecycle management, including retention and secure disposal. Line-of-Business Managers are responsible for departmental compliance and reporting issues. Employees must adhere to policies, undergo training, and report suspicious activities.

Information Policies

The IG framework integrates several key policies, customized for MBA’s specific context:

  • Information Security Policy: Sets standards for securing transaction data, including encryption, access controls, and incident response procedures.
  • Records Management Policy: Provides guidance on storing, archiving, and disposing of transaction records following legal requirements.
  • Retention and Disposal Schedule: Outlines the duration for retaining different data types, ensuring data is discarded once no longer legally or operationally needed.
  • Data Privacy Policy: Ensures sensitive customer and merchant data are protected according to privacy laws like GDPR and GLBA.
  • Information Sharing Policy: Defines conditions under which data can be shared with third parties, such as PCI DSS compliance vendors.

Information Procedures

The operational procedures define how information is created, stored, accessed, and disposed of, while ensuring compliance with regulations:

  • Legal and Regulatory Compliance: Procedures for aligning practices with PCI DSS, GLBA, and other relevant laws, including periodic audits.
  • Creating and Receiving Information: Controls on how transaction data is entered into systems and validated.
  • Managing Volume of Information: Techniques to handle large datasets efficiently, involving data archiving and deletion policies.
  • Managing Personal Information: Ensuring personal identifiable information (PII) is handled with confidentiality.
  • Storing and Archiving: Secure storage solutions with controlled access, including encrypted databases and secure backups.
  • Sharing and Collaboration: Secure channels for data transfer to third parties, with audit logs to track data exchanges.
  • Disposal of Data: Secure deletion processes ensuring data is irrecoverable after retention period expiration.

Working with Third Parties

Many operations involve external vendors, especially regarding PCI compliance and data processing. The policy must:

  • Define policies for secure data sharing with third-party vendors, ensuring contractual obligations align with internal policies.
  • Establish how third parties handle confidential and PII data, with compliance monitoring and audit rights.
  • Incorporate Data Processing Agreements (DPAs) to enforce data security measures.
  • Measure third-party compliance with established policies via regular audits and reporting mechanisms.

Disaster Recovery, Contingency, and Business Continuity

Maintaining data integrity and availability is critical. The policy should include:

  • Procedures for reporting data breaches, data loss incidents, and security breaches.
  • Incident management protocols with escalation procedures involving relevant departments.
  • Back-up processes, including secure off-site backups, with periodic testing of recovery procedures.
  • Business continuity plans prioritizing data availability during disruptions, ensuring minimal service downtime.

Auditing, Monitoring, and Review

Ongoing oversight is essential for effective IG. The policy enforces:

  • Regular monitoring of user access and activity logs to detect irregularities.
  • Assessment of compliance with PCI DSS and internal policies through periodic audits.
  • Continuous review of data security measures for effectiveness and relevance.
  • Performance metrics and reporting to ensure transparency and accountability.
  • Updating policies and procedures based on audit findings, technological advancements, and regulatory changes.

Conclusion

Implementing a tailored, comprehensive IG policy at MBA ensures robust protection of sensitive transaction data, regulatory compliance, and operational resilience. By clearly defining roles, policies, procedures, third-party engagements, and monitoring mechanisms, MBA can safeguard its customer data, meet legal obligations, and foster trust with its merchant clients. This policy must be living, adaptable to technological and legislative changes, and embedded within the organizational culture to be effective long-term.

References

  • Altman, S. (2020). Data Security Standards in Financial Institutions. Journal of Information Security, 12(3), 45-60.
  • Cheung, K., & Lee, M. (2019). Implementing Effective Data Governance Frameworks. International Journal of Data Management, 15(2), 89-102.
  • Freeman, J. (2018). PCI DSS Compliance Best Practices. PCI Security Standards Council.
  • Gonzalez, R. (2021). Risk Management in Financial Data Processing. Financial Technology Journal, 7(4), 30-45.
  • ISO/IEC 27001 & 27002 Standards. (2013). Information Security Management Systems.
  • National Institute of Standards and Technology (NIST). (2022). Framework for Improving Critical Infrastructure Cybersecurity.
  • Scholtz, S. (2019). Data Retention and Disposal Policies in Banking. Banking Security Review, 10(1), 54-68.
  • Smith, A., & Johnson, T. (2022). Third-Party Risk Management in Financial Services. Financial Services Review, 14(4), 200-215.
  • Thompson, P. (2020). Business Continuity Planning for Financial Institutions. Business Continuity Journal, 3(2), 77-89.
  • United States Federal Trade Commission (FTC). (2018). Data Security and Privacy Complaint Guidelines.

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