If your organization is a bank, insurance provider, mortgage broker, university or
other business entity that deals with private financial data, it’s subject to rules of the Gramm-Leach-Bliley Act (GLBA). The GLBA controls how confidential financial information is collected, shared and used; protects consumers from privacy breaches and prohibits fraudulent business practices.
Learn more about the protections the GLBA offers and how document management supports companies in meeting the regulatory requirements outlined by this law.
Table of Contents
- Understanding GLBA compliance requirements
- Key data protection obligations for organizations
- The role of software in GLBA compliance
- Essential document management features for GLBA compliance
- How DocuWare supports GLBA compliance
- Closing thoughts: Building a resilient compliance foundation
- Resources and further reading
- GLBA compliance software FAQ
Understanding GLBA compliance requirements
The GLBA mandates that companies offering loans, insurance, or investments keep private data protected and inform customers about how they share information. This law covers a wide range of businesses involved in financial activities, including some that aren't your typical banks or lenders.
Companies regulated by the GLBA have to keep customers updated on how their non-public personal information (NPI), which includes any personally identifiable information, is shared and allow people to opt out of sharing their data with non-affiliated businesses. In addition, whoever receives this information faces restrictions on how they can reuse or disclose it.
To comply with the GLBA, companies are also required to build solid data protection plans, communicate privacy updates clearly to clients, and tightly manage who can access sensitive information. Ignoring these rules can result in major fines or legal action.
The Gramm-Leach-Bliley Act (GLBA), passed in 1999, was created to help the financial industry evolve with the times. It’s most recognized for rolling back the Glass-Steagall Act, which, since 1933, had stopped commercial banks from offering investment and insurance products as part of their core services. This rule was put in place after the stock market crash in 1929, when lawmakers wanted to limit the risk customers faced by keeping banks from mixing traditional banking with the sale of riskier financial products.
For decades, this meant commercial banks couldn’t legally operate as brokers. However, as new regulations cropped up to protect depositors over the years, the financial industry gained stronger guardrails. The GLBA opened the door for banks and similar institutions to expand their offerings and provide additional services.
As business practices change and new security concerns like the prevalence of cyberattacks are introduced, updates to GLBA are made.
Who is covered?
The term “financial institution” applies to any company that conducts financial operations — this includes lending, buying, facilitating or servicing loans. For example, because colleges and universities handle financial matters like distributing federal Perkins Loans, the Federal Trade Commission (FTC) classifies them as financial institutions under the GLBA guidelines.
Auto dealerships are also covered by GLBA because they regularly handle financial deals like offering credit, arranging loans, or setting up leases In the course of doing business, dealerships gather a lot of sensitive information from customers — things like social security numbers, income details, bank account information and credit reports.
Key data protection obligations for organizations
Companies covered by the GLBA have to follow three main guidelines:
- The Financial Privacy Rule controls how businesses gather, use, and share financial details.
- The Safeguards Rule makes it mandatory for organizations to put solid security measures in place to keep customer information safe.
- The Pretexting Rule bans using fraudulent means to access clients' data. For example, someone might use a fake identity to access credit reports or get information about customer accounts.
Financial institutions and other covered entities must:
- Provide a privacy notice that covers what kind of personal information is collected, who it’s disclosed to, and how it's secured at the start of a customer relationship.
- Let customers know they can opt out before sharing their confidential information with unaffiliated companies — unless it's an allowed exception.
- Follow GLBA rules on how shared information can be used — anyone it’s shared with can only use it for its original purpose.
- Make sure there are contracts in place that protect customer data if their company partners with third parties for services or joint marketing.
- Never share account numbers with outside companies for marketing via phone, mail or email.
Recent GLBA violations
Failure to comply with the Safeguards Rule
In 2025, the FTC filed a suit against Ascension, LLC. The company sent 60,000 customer mortgage files — including Social Security numbers, driver’s licenses, names, loan details, and bank information — to a document processing vendor. The complaint says Ascension didn’t thoroughly check the vendor’s security, which meant sensitive data was left open for unauthorized access for about a year. This violated the GLBA Safeguard Rule, which protects consumers' private financial information.
As part of the settlement, Ascension is required to implement a robust data security program, designate employees to oversee it, obtain annual compliance certification from an executive, and undergo a security audit every two years.
Non-compliance with the Pretexting Rule
In January 2025, the Federal Trade Commission (FTC) filed a lawsuit against Greystar, a manager of multifamily properties, alleging that the company was not upfront with renters because it did not disclose additional fees that bumped up rental prices beyond what was initially advertised.
The suit, which was filed in the U.S. District Court for the District of Colorado, also includes the State of Colorado as a co-plaintiff. The FTC claims that Greystar’s actions potentially break the rules in the Federal Trade Commission Act, Gramm-Leach-Bliley Act, and the Colorado Consumer Protection Act. Greystar agreed to pay $23 million to the FTC and $1 million to the state of Colorado to settle the suit. Under the proposed agreement, Greystar must now plainly show all monthly leasing amounts and any required fees upfront.
The role of software in GLBA compliance
GRC platforms: managing policies and risk
Gartner describes governance, risk and compliance (GRC) tools as solutions that help companies manage risks as a whole —from finding and analyzing potential issues to addressing, tracking, and reporting on them. These tools give risk management teams a clear, connected view of the main risks facing the organization, allowing different teams — like compliance and internal audit — to work together effectively.
GRC software addresses:
- Governance: Refers to the systems and policies that help make sure an organization’s day-to-day operations and larger goals are in sync. Good governance guides executives in recognizing what’s working to move the company forward and what could be slowing things down.
- Risk management: Focuses on finding, checking, and addressing anything that could threaten the organization, from hacking threats to possible legal consequences.
- Compliance management: Ensures what a business does is in line with all applicable laws and regulations that affect it.
How a document management system works seamlessly alongside GRC software
A document management system (DMS) handles everything related to document flow—like classifying, securely storing, version control and document-intensive workflows. A DMS takes care of how you organize, store and safeguard, and access information, while GRC solutions help keep company actions on track and reduce exposure to risks.
Document management is the backbone for making sure essential files — like policies, proof of compliance, audit files, contracts and process guides — are always available, protected, and handled according to business rules and federal requirements.
A document management system can be configured to enable compliance, reduce risks, and support internal controls with version management and maintain a single source of truth. Everyone can easily search for the information they need and be confident that they are working with the latest version of the documents.
It’s easy to integrate DocuWare with your current GRC solution to facilitate effortless sharing of documents and data, boosting the overall productivity and effectiveness of GRC software.
Essential document management features for GLBA compliance
Secure storage and access controls
- Strong access controls, multi-factor authentication and single sign-on for staff, suppliers and system administrators.
- Data protection through encryption both during transfer and when stored.
- Apps that are built securely using best practices, version control and code checks.
- Granular data security permissions to control data access.
- Well-defined plans, round-the-clock monitoring, and practice drills based on GLBA requirements.
Audit trails and compliance readiness
- Detailed lists of all the personal information they collect, store and share, making sure it’s handled properly according to legal standards.
- Tracking of compliance activities and the ability to monitor data management practices to prove they’re following GLBA rules.
Automated retention and deletion policies
- Robust management of requests from customers as a result of powerful search and immediate access to information for authorized users.
- Proof they’re committed to upholding the consumer protections set out by GLBA.
Integration with other risk management and compliance tools
- A wide range of integration options through capabilities that include APIs, iPaaS and native connectors.
- Access to documents directly from GRC software.
How DocuWare supports GLBA compliance
While GRC tools manage compliance processes and documentation requirements; DocuWare manages the records themselves. DocuWare keeps your business on the right side of privacy regulations by using secure, permission-based access, workflow automation and advanced security.
You can keep an eye on document edits and updates, assign who is allowed to view or change files, and limit access to the right people. Detailed tracking and audit logs make sure you always know what’s happening with your sensitive data.
Here’s what DocuWare brings to the table:
Secure storage for your customers’ private data
DocuWare takes security seriously, using strong user authentication, secure HTTPS transfers, 256-bit encryption, layered access controls, and protection against cyber threats. This technology keeps your data safe from unauthorized access and digital risks.
Retrieving the latest or archived documents is quick and simple, which also helps with GLBA compliance checks. With automatic backups in the cloud, your files are protected even if something goes wrong locally.
Customizable access management
DocuWare’s advanced permissions let you control exactly who has access to your documents. You can set permissions for individual employees, roles, or whole departments, letting you decide who can read, edit, upload, or delete confidential data. Everything is locked down with unique logins and can include multi-factor authentication and single sign-on for an extra layer of safety.
Audit trails and compliance monitoring
DocuWare automatically creates time-stamped activity logs for all changes and user actions. These tamper-proof records make it easy to show auditors and regulators the strict controls you have in place for sensitive information. They also provide a reliable history you can reference whenever needed.
Automated workflows for regulatory compliance
With DocuWare’s workflow automation, every document goes through a pre-set, step-by-step process to guarantee compliance. You can automate security checks, set deadlines, define responsibilities, and ensure everyone knows their role. Whether your operations are straightforward or complex, DocuWare streamlines your compliance workflows.
Centralized repository for customer information
DocuWare provides a single source of truth because everyone in your organization works with the same documents. Your team will also be able to pull up related documents from one system. DocuWare integrates seamlessly with GRC systems, ensuring that data flows smoothly in and between departments.
Automated workflows for security and audit
DocuWare Workflow Manager brings greater accuracy to how you run your processes. Every document moves through a structured, multi-step workflow—from the moment it’s created or received until the workflow is complete—so accuracy and compliance are maintained consistently.
With Workflow Manager, you can automate controls, create tasks that happen one after another or at the same time, add custom rules, set due dates, assign responsibilities to different team members, and manage permissions for each step of the process.
With DocuWare’s automation and task management features, you can make the most of your data, regardless of whether your workflow is simple or complex.
Closing thoughts: Building a resilient compliance foundation
DocuWare streamlines recordkeeping, tightens access controls, and makes it simpler to manage customer privacy preferences and consent. With features for safeguarding data and enabling the security of private information, automating compliance checks, and supporting quick responses to customer requests, these systems help organizations reduce risk and respond quickly to regulatory changes. DocuWare is a valuable compliance tool that helps companies create a more resilient and future-proof business operation.
Resources and further reading
- FTC Safeguards Rule: What Your Business Needs to Know
- How To Comply with the Privacy of Consumer Financial Information Rule of the Gramm-Leach-Bliley Act
- Consumer Compliance Examination Manual
- International Association of Privacy Professionals (IAPP) Guide to the Gramm-Leach-Bliley Act
GLBA compliance software FAQ
How does document management software help with GLBA compliance?
Document management systems cover everything from categorizing and securely saving files to monitoring updates and managing complex, document-intensive workflows. DocuWare organizes, archives and protects your critical information.
What types of documents does GLBA require to be securely stored?
Any document containing non-public private information. This includes information that has been shared with third parties. It’s important to review and monitor their security policies along with your own.
Does DocuWare provide audit trails for GLBA compliance?
DocuWare keeps a secure, time-stamped record of every change and user action. These audit logs are locked down, so you can easily prove to auditors and regulators that you’re handling sensitive data with tight controls. Plus, you’ll always have a trustworthy record to look back on if you ever need to check something.
The information in this blog post is intended for educational purposes only. If you have specific questions, consult your compliance officer, legal department or outside counsel.
