If you want to stay out of DOL trouble, here\u2019s what I\u2019d tell you over a drink,no legalese, just practical advice.<\/p>\n
1. Cybersecurity is a fiduciary issue.<\/strong> The DOL is digging deep into cybersecurity practices, going well past HIPAA compliance. Having an \u201cIT policy\u201d on the shelf won\u2019t cut it. Auditors will want to see meeting minutes, risk assessments, device policies, and even how you handle portable devices and payroll data.<\/p>\n 2. Vet and tighten your vendor contracts now.<\/strong> Review your agreements with vendors and recordkeepers (especially those handling participant data or payroll info). Make sure the contracts require strong data security standards, reporting on cyber incidents, encryption, and notifications. And yes\u2014make sure the vendors can\u2019t wiggle out of liability when things go sideways.<\/p>\n 3. Look for documentation, not just policies.<\/strong> It\u2019s easy to write a cybersecurity plan, less easy to prove you executed it. The DOL will ask for audit reports, risk assessments, training logs, breach investigations, and communications about security protocols. If you don\u2019t have documented follow-through, you\u2019re vulnerable.<\/p>\n 4. Train your people, and document that training.<\/strong> Cybersecurity training isn\u2019t just a \u201cnice to have.\u201d It\u2019s expected. Keep records: who was trained, when, by whom, and what materials were used. The DOL is looking for that chain of evidence.<\/p>\n 5. Check your insurance, and insist on cyber coverage.<\/strong> Cyber-insurance isn\u2019t just for tech companies. Review your policies now\u2014what do they cover? Do they address social engineering, phishing, identity theft, or data breaches? What are the limits? Have you made claims before? The DOL might ask.<\/p>\n 6. Bring cybersecurity into your plan oversight meetings.<\/strong> Just like you review investment performance or vendor contracts periodically, cybersecurity should be a recurring agenda item for your plan committee. If you treat it as an afterthought, you\u2019ll have trouble explaining your oversight in a DOL audit.<\/p>\n Final Word:<\/strong> Cybersecurity isn\u2019t just an IT problem, it\u2019s an ERISA oversight issue. If you don\u2019t treat participant data protections, vendor security, and breach preparedness as fiduciary responsibilities, don\u2019t be surprised when a DOL audit rips your plan apart. Better to prepare before the audit letters hit.<\/p>\n <\/span><\/p>","protected":false},"excerpt":{"rendered":" If you want to stay out of DOL trouble, here\u2019s what I\u2019d tell you over a drink,no legalese, just practical advice. 1. Cybersecurity is a fiduciary issue. The DOL is digging deep into cybersecurity practices, going well past HIPAA compliance. … Continue reading