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Maintaining Data Privacy Through Your Financial Institution’s Digital Journey


One of financial institutions’ biggest concerns when considering digital tools such as artificial intelligence, automation, or data platforms is verifying your institution and customer data remain secure. The trust needed with your vendors and platforms require much more diligence, awareness, and monitoring than when you favored an on-premises infrastructure where your team managed the controls, patching, user access, provisioning, and configuration.

February 24, 2025 / By Tim Dively

One of financial institutions’ biggest concerns when considering digital tools such as artificial intelligence, automation, or data platforms is verifying your institution and customer data remain secure. The trust needed with your vendors and platforms require much more diligence, awareness, and monitoring than when you favored an on-premises infrastructure where your team managed the controls, patching, user access, provisioning, and configuration.

Understanding your digital tools

If you don't fully understand automation, AI, data flow, and processes, can you effectively monitor and provide safety, or are you blindly trusting your third and fourth-party vendors to do it? It’s crucial to have a clear understanding of how these technologies work and where your data is being processed, stored, and accessed.

Learning from incidents

Often when we hear about an incident at a financial institution there are lessons to learn. These incidents can serve as a call to action to verify your institution wouldn't have been impacted by the same attack or identify a gap to address.

While human error will always be high root cause risk, you can control how high that risk is by enhancing your controls and tools. Essential measures include:

  • Complex passwords

  • Multi-factor authentication

  • Data segregation

  • Network segmentation

  • Regular backups

  • Endpoint protection

  • Email security

  • Intrusion detection and prevention systems

  • Patch management, and

  • User training

Assessing your IT team's skills

Inventory your IT team’s skills and measure them against your infrastructure, cybersecurity, and risk management needs. If you have a managed service provider, assess their skills and how they stay ahead of ever-increasing effectiveness of cyber threats. The harsh reality in today's financial services ecosystem is the skills required to maintain your hardware and software are different from those needed to effectively stay ahead of cyber threats for your institution and your customers.

Actionable steps

Here are some steps you can take now to enhance your data privacy:

  • Update your vendor management program — Ask your vendors if they are leveraging AI or automation as part of your vendor review process. Start with critical and high-risk vendors first.

  • Identify fourth-party vendors — These are vendors your third-party vendors use. Understanding this extended network is crucial for comprehensive security.

  • Update your infrastructure topology map — Include on-premises devices, remote connection configurations (outside of WAN), data flow, data classification, user access control, vendor connections, internet connectivity, redundancy/backup, and network/cybersecurity management tools.

  • Create an AI and automation policy — Whether you are ready to integrate AI, automation, or other digital tools at your institution or not, starting with an AI and automation policy will help regulators know you have identified the risks presented through your vendors and through the availability of publicly facing AI and digital tools available to your employees.

By taking these steps, you can better manage the complexities of data privacy in a digital world and verify your institution and customer data remain secure throughout your digital journey and maturity.

For more information on cybersecurity, contact Tim Dively at tim.dively@CLAconnect.com or 704-816-575, or contact Randall Romes at randy.romes@CLAconnect.com or 612-397-3114.

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The information contained herein is general in nature and is not intended, and should not be construed, as legal, accounting, investment, or tax advice or opinion provided by CliftonLarsonAllen LLP (CLA) to the reader. For more information, visit CLAconnect.com.

CLA exists to create opportunities for our clients, our people, and our communities through our industry-focused wealth advisory, digital, audit, tax, consulting, and outsourcing services. CLA (CliftonLarsonAllen LLP) is an independent network member of CLA Global. See CLAglobal.com/disclaimer. Investment advisory services are offered through CliftonLarsonAllen Wealth Advisors, LLC, an SEC-registered investment advisor.

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