Recording | 3 Part Series on GLBA: Session 3: Areas of Focus to Avoid Unknowingly Misrepresenting the Handling and Security of Consumer Information to Your Consumers and Regulators (Nov. 13)
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In this session, Rocio Baeza will be closing the 3-part series on GLBA. This is valuable information for your GC to have for information security risk management planning for 2025. In this session, attendees will walk away with:
- an analysis of cases where FTC filed a complaint arguing that the organization had misrepresented data handling practices of consumer information
- the foundational elements that Legal Counsel needs to have in place to mitigate risk of misrepresentation
- how the privacy policy can be the entryway for regulators to argue that the protection and privacy of consumer information is being misrepresented (and in some cases, a UDAAP risk)
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Rocio Baeza
CEO & Founder
CyberSecurityBase
Rocio is the CEO and founder of CyberSecurityBase, a data security and privacy consultancy supporting FinTechs. GCs hire CyberSecurityBase to design and implement robust information security programs that expect to be scrutinized by bank partners. Rocio's background includes 16 years in small-dollar lending/FinTech and 11 years in cybersecurity.
Rocio has actively participated in proposed rulemaking/updates activity initiated by the FDIC, OCC, FRB, and CFPB, including the “Interagency Guidance on Third-Party Relationships: Risk Management”.