NYDFS, utility IT & customer privacy

New York utility audit planning

Plan a utility cybersecurity and privacy audit with separate DFS, PSC and personal-information tracks. Define the entity, examine evidence and carry findings through verified closure.

Illustrative water-treatment infrastructure.

Three separate audit tracks

DFS coverage and shared services

Part 500 depends on qualifying financial-services authorization. Review licenses, exemptions, Class A criteria and affiliate boundaries.

Utility IT and customer privacy

Part 1200 and existing PSC PII orders require their own jurisdiction, size, ownership and transition decisions.

Private-information safeguards

Review SHIELD safeguards, breach roles, resident information and state or local notification procedures.

Safe assessment work

Plan evidence, samples, field permissions, findings, corrective actions and verified handover.

Download the planning set

Download the complete set (ZIP)

Use it from scope to handover

  1. Confirm each legal entity, ownership, operating function and review period.
  2. Resolve applicability with current instruments and named compliance reviewers.
  3. Assign tasks, safe methods, populations, samples and evidence owners.
  4. Record results, escalate incidents, correct failures and verify closure.
  5. Transfer open questions and recurring duties with actual technical, compliance and operating approvals.

Current rules and unresolved questions

Planning edition: October 15, 2026. New York adopted utility IT cybersecurity rules in April 2026, effective June 1, with phased requirements. Utility status alone does not establish NYDFS coverage.

Use the final PSC adoption and Appendix A, the State Register adoption notice, the DFS resource center and the current GBL breach statute, safeguards statute and state/local notification provisions.

The review report identifies apparent drafting errors, first-year timing questions and unavailable entity-specific criteria. Obtain current utility orders, tariffs, local policies and written clarification before adopting conclusions. The pack is a planning resource; completed work requires actual evidence and approvals.

Discuss the audit boundary

Bring the entity profile and unresolved questions to a scoped planning discussion. Keep completed worksheets and evidence in controlled records.

Discuss utility assessment scope

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