How can Enterprise Risk interact with the CISO?
Simon said he would summarise how ERM could interact with CISO. Get in touch if you want to hear more.
Incorporating 20 questions for the CISO into an enterprise-wide risk assessment involves aligning these questions with the firm's overall risk management framework. This alignment should ensure that cybersecurity risks are appropriately identified, assessed, prioritised, and managed within the broader context of the firm's risk profile.
1. Integration into Risk Identification Process
Question Alignment: Ensure each question relates to specific cybersecurity risks (e.g., data breaches, compliance risks, technology based vulnerabilities).
Risk Cataloguing: Use responses to categorise risks and identify new ones not previously considered. Work with the CISO and use some of the external regulatory sources to support this activity.
2. Risk Assessment and Analysis
Qualitative and Quantitative Measures: Use answers to evaluate the severity and likelihood of cybersecurity risks. This can involve scoring risks based on potential impact and probability. These heat maps can attract some criticism, unless supported by data, but put your best foot forward.
Risk Dependencies: Analyse how cybersecurity risks relate to other business risks, such as conduct / staff behaviour and technical debt.
3. Risk Prioritisation
Impact on Risk Profile: Use the CISO's insights to adjust the firm's risk profile, prioritising risks that could significantly impact the firms financial stability, regulatory compliance, and customer trust. What harm can be done to firm, customers and potential markets?
Resource Allocation: Direct resources (budget: people and technology) towards mitigating high-priority cybersecurity risks.
4. Risk Mitigation and Strategy Development
Mitigation Plans: Develop strategies based on the CISO's responses to address identified risks, including preventive, detective, and responsive and recovery measures.
Policy and Procedure Updates: Update internal policies and procedures to incorporate cybersecurity risk management practices. Do this in the round having a stand alone information security policy is not enough. How is security embedded in the business thinking, take a look at change management and new business approval policies too.
5. Monitoring and Reporting
Continuous Monitoring: Establish metrics and KPIs based on the CISO's feedback to monitor risk levels over time. Build these into your business-as usual reporting. Use them in your ICARA, ICAAP and/or Recovery Plans.
Reporting Structure: Integrate cybersecurity risk event / incident reporting into the broader risk management reporting process, ensuring regular updates to the board and relevant committees. Integrate cybersecurity risk reporting with your ICARA, ICAAP and/or Recovery Plans.
6. Compliance and Regulatory Considerations
Regulatory Alignment: Ensure questions and subsequent actions comply with relevant financial industry regulations and standards (e.g., GDPR, PCI-DSS) There are so many. Have I mentioned DORA, EBA Guidelines for ICT Security Risk Management, or Operational Resilience ?
Audit and Review: Include cybersecurity risk management practices in internal and external audits. Don’t be lulled into a false sense of security by your shiny new ISO 27001 certification.
7. Stakeholder Engagement
Board Education: Use the dialogue with the CISO to educate board members and other stakeholders on cybersecurity issues, trends, and best practices. Ask the CISO to do it.
Cross-Functional Collaboration: Foster collaboration between the CISO and other departments (e.g., IT, HR, Legal) to ensure a unified approach to managing cybersecurity risks. Use credible external resources like Cyber Griffin (it’s free)
8. Incorporation into Strategic Planning
Strategic Objectives: Align cybersecurity risk management with the firm's strategic objectives, ensuring that efforts to mitigate these risks also support overall business goals. Customers want to know they are safe when they use your platforms and share their data with you. It’s a business differentiator.
Innovation and Growth: Consider how cybersecurity strategies can enable innovation and growth, not just protect against threats. Customers want to know they are safe when they use your platforms and share their data with you. It’s a business differentiator.
By thoughtfully incorporating these questions into the risk assessment process, a financial services firm can ensure a comprehensive approach to managing cybersecurity risks, safeguarding assets, and maintaining trust with clients and regulators.
