The terms 23 NYCRR Part 500 actually turns on, defined in plain language by practitioners. For the full walkthrough, see the NYDFS cybersecurity compliance guide.
The New York Department of Financial Services Cybersecurity Regulation. It requires Covered Entities to maintain a risk-based cybersecurity program, specific controls, regulatory reporting, and an annual filing. An amended version expanded the obligations, including tighter requirements for larger entities, broader incident reporting, and the certification-or-acknowledgment filing.
The New York State Department of Financial Services, the regulator that licenses and supervises banking, insurance, and financial-services businesses operating in New York and administers Part 500.
Any person or business operating under, or required to operate under, a license, registration, charter, certificate, permit, accreditation, or similar authorization under New York's Banking Law, Insurance Law, or Financial Services Law. The obligation follows the New York authorization, not the location of the company.
The head of the New York Department of Financial Services. The 72-hour notice and other Part 500 filings are made to the Superintendent.
The data Part 500 protects: defined categories of sensitive business information, certain personal financial and identifying information, and health information whose unauthorized disclosure or use would cause harm to the business or to an individual.
The discrete set of electronic resources used to collect, process, store, or transmit electronic information, together with the supporting infrastructure for those resources.
The risk-based set of controls and processes a Covered Entity maintains to protect the confidentiality, integrity, and availability of its information systems. It performs six core functions: identify, protect, detect, respond, recover, and fulfill regulatory reporting.
The written governance document, approved by a senior officer or the board, that sets out how the Covered Entity protects its information systems across the areas the regulation names, from data classification to vendor management to incident response.
The qualified individual a Covered Entity designates to oversee, implement, and enforce the cybersecurity program and policy. The role can be filled internally, by an affiliate, or by a third party, but the entity keeps responsibility, and the CISO reports to the governing body at least annually.
The periodic, documented evaluation of cybersecurity risks that the program, policy, and controls have to be based on. It produces criteria for evaluating risks, for assessing existing controls, and for deciding how to mitigate or accept what remains. The spine of a Part 500 program.
Authentication that requires two or more verification factors. Part 500 requires MFA for individuals accessing the Covered Entity's information systems, subject to a written CISO-approved compensating control that is reasonably equivalent or more secure under narrow conditions.
Encoding nonpublic information so it cannot be read without a key. Part 500 requires encryption of nonpublic information in transit over external networks and at rest, or effective CISO-approved alternative controls where encryption is infeasible.
A test that simulates a real attacker to find exploitable weaknesses in information systems. Part 500 requires penetration testing based on the risk assessment, at the cadence the rule sets, by qualified testers.
Automated scanning and manual review designed to detect new security vulnerabilities, run on a regular basis and after material system changes, with timely remediation of what it finds.
Any act or attempt, successful or not, to gain unauthorized access to, disrupt, or misuse an information system or the information stored on it. A defined subset of these events triggers the 72-hour notice.
The requirement to notify the Superintendent as promptly as possible and no later than 72 hours after determining that a qualifying cybersecurity event has occurred. The clock runs from the determination, and an entity cannot delay the determination to delay the clock.
A non-affiliate that provides services to the Covered Entity and maintains, processes, or otherwise accesses nonpublic information through that work. Part 500 requires written policies, due diligence, and contract terms governing these providers.
The written plan to respond to and recover from a cybersecurity event that materially affects the entity's systems or business. The amended rule pairs it with a business continuity and disaster recovery plan and requires periodic testing.
The annual written statement to the Department covering the prior calendar year. The entity either certifies material compliance or submits an acknowledgment of noncompliance with the gaps and a remediation timeline, signed by the highest-ranking executive and the CISO.
A reduction in the obligations a Covered Entity owes, most commonly tied to size thresholds for employee count, New York revenue, and total assets. It reduces requirements but never removes the core ones, and claiming it requires a filed notice of exemption.
Systems and records that can reconstruct material financial transactions and detect and respond to cybersecurity events, retained for the periods the regulation sets.
An account with elevated rights that can change configurations, reach broad data, or manage other accounts. Part 500 calls for tighter control of these accounts, and unauthorized access to one can trigger the 72-hour notice.
Compliance Command Center turns these concepts into a defensible, examiner-ready 23 NYCRR Part 500 program, run by practitioners and leveraged by software.
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