Managing Information Security Requirements and Expectations: Accountability vs. Responsibility

Of the many roles within a financial institution, the information security officer (ISO) is the most critical for the protection of confidential and nonpublic personal information and maintaining compliance with federal regulations. In fact, the Federal Financial Institution Examination Council (FFIEC) goes so far as to mandate that all financial institutions have one or more individuals dedicated to the position of ISO.

Safe Systems held a webinar last week outlining the most common challenges for ISOs and some helpful ways that they can better identify, perform, and document their regulatory responsibilities. In this blog post, we’ll highlight two of the most important elements of the ISO role and outline 8 key regulatory responsibilities all ISOs should focus on to meet examiner expectations.

Key Elements

For ISOs, everything ultimately hinges on responsibility (specific tasks the ISO must perform) and accountability (specific documentation ISOs must provide to key internal and external stakeholders). In fact, these terms are referenced multiple times within the FFIEC guidance:

“The ISO is responsible for overseeing and reporting on the management and mitigation of information security risks across the institution and should be held accountable for the results of this oversight and reporting. – FFIEC Management Handbook

“Management should designate at least one information security officer responsible and accountable for implementing and monitoring the information security program.” – FFIEC Information Security Handbook

Individuals in the ISO role must effectively demonstrate both elements to adequately meet regulatory expectations.

Maintaining Compliance

The ISO must not only be able to perform key responsibilities of the role, but he or she must also provide proper documentation to specific stakeholders to satisfy the accountability requirements. The FFIEC’s Management Handbook outlines 8 key responsibilities of the ISO role including:

1. Implementing the information security strategy and objectives, as approved by the board of directors, including strategies to monitor and address current and emerging risks
2. Engaging with management in the lines of business to understand new initiatives, providing information on the inherent information security risk of these activities, and outlining ways to mitigate the risks
3. Working with management in the lines of business to understand the flows of information, the risks to that information, and the best ways to protect the information
4. Monitoring emerging risks and implementing mitigations
5. Informing the board, management and cybersecurity risks and the role of staff in protecting information
6. Championing security awareness and training programs
7. Participating in industry collaborative efforts to monitor, share, and discuss emerging security threats
8. Reporting significant security events to the board, steering committee, government agencies, and law enforcement, as appropriate

When performing these key responsibilities, the ISO must reference the institution’s policies (what you say you do); procedures (how you say you’ll do them); and actual practices (what you actually do and are able to document). In our experience, we’ve seen that there is often a gap between procedures and practices, which often results in the majority of audit and exam findings for financial institutions.

To address this issue, many community banks and credit unions are turning to virtual ISO solutions. A virtual ISO platform serves as a risk management solution that addresses the regulatory expectations and important tasks that the ISO must oversee. The solution helps financial institutions augment their internal ISO role, streamline responsibilities, and ensure the institution’s procedures and practices are properly aligned. Most importantly, a virtual ISO can make sure that all stakeholders; Board, committee, auditor, and regulator, have the appropriate reports to document that alignment.

To learn more about the information security officer role, the 3 virtual ISO delivery models, and the benefits of virtual ISO solutions, watch our recorded webinar, “ISO Requirements and Expectations: Accountability vs. Responsibility.”