Planning allowance: 3–5 working days; 6–12 hours, excluding specialist advice. Collect customer security commitments, the current insurance application and policy, and any regulator or certification scope. Record the legal entity and data involved.
For healthcare, start with HHS's current Security Rule summary. For a potentially covered non-bank financial institution, start with the FTC Safeguards guide. Those are applicability inputs, not interchangeable compliance bundles.
Send a short, concrete question list to counsel or the relevant compliance specialist: which obligations apply, what evidence demonstrates them, which dates matter, and which contract terms must flow to suppliers? Obtain written resolution of disputed scope.
Exit criterion: a reviewed obligation register that distinguishes law, contract, standard and proposed change. Pitfall: buying against a proposed rule as if it were already an enforceable deadline, or assuming a general-purpose provider understands your entity's obligations.