Information Security Officer Archives

05 Aug 2022

Banks, Compliance, Credit Unions The Safe Systems Compliance Team 0 comment

The Importance of Succession Planning to IT and Information Security Resiliency

The Importance of Succession Planning

Change can be challenging—especially when it involves the transition of IT management and other key personnel. That’s why it’s imperative for banks and credit unions to be proactive about succession planning.

While regulators expect institutions to have a formal succession plan for key leadership roles, having a strategy for filling critical positions is a matter of practicality. If an IT administrator or information security officer (ISO) is not in place, or not available to complete the tasks, reports, and other responsibilities of these roles, then it could lead to cyberattacks and other security issues. This, in turn, can have dire consequences on a financial institution’s operations, risk-profile compliance, and reputation.

Succession Planning Strategies

Institutions can ensure IT and information security resiliency by having an effective plan for managing the absence of key security-related personnel. Depending on their size, type, and goals, they can adopt any of these approaches to succession planning:

Proactively assess internal talent and then orient the most suitable individual to serve as an alternate or backup for various IT admin or ISO responsibilities. The ISO alternate, for instance, should train with the existing ISO, attend ISO oversight meetings, and present appropriate information to executive management and the board. If the ISO leaves, the backup individual should be equipped to assume the role temporarily or even for the long term if necessary. Training a staff member to perform IT or information security duties is not only pragmatic, but it complies with regulatory guidance.
Implement an internal committee or team approach to managing IT and information security during a temporary or permanent personnel change. The committee can facilitate the IT and information security program in several ways. It can maintain processes until an outside replacement is installed or support an internal successor who is transitioning into the position. The committee can also provide coaching to keep the replacement from becoming overwhelmed by the complexity and assortment of tasks required.
Partner with a trusted third party to obtain the additional expertise needed to meet IT and information security benchmarks. This approach provides an accountability partnership role and a regular framework that clearly defines key responsibilities and streamlines processes. This strategy can ensure institutions have suitable resources to ease the transition of key personnel to enhance IT and information security resiliency.

Leveraging a Virtual ISO

A virtual ISO can be an ideal solution for institutions seeking to enhance IT and information security resiliency. This third-party service can not only support succession planning, but it can also serve as an extension of the internal ISO providing an external layer of oversight and an objective point of view — which allows institutions to approach risk more strategically and proactively.

ISOversight from Safe Systems, for instance, is a complete solution that makes it easier for community banks and credit unions to master information security and compliance online. This virtual ISO solution—which is especially for financial institutions—offers valuable access to applications and resources, cyber risk reporting, and compliance experts. With ISOversight, banks and credit unions can be confident that all their ISO-related requirements are completed on time, documented properly, and reported to the appropriate parties. Learn more about how to enhance your institution’s security posture during tough times. Read our white paper on “Building IT and Information Security Resiliency in Chaotic Times.”

16 Jun 2022

Banks, Compliance, Credit Unions The Safe Systems Compliance Team 0 comment

Choosing a Virtual ISO (VISO)

The ISO’s role is becoming increasingly more complex and challenging due to growing cyber security threats, the ever-changing technology environment, and expanding regulatory expectations. It can be difficult for banks and credit unions to stay on top of information security issues. That’s why today even the smallest institutions often engage a trusted third party for help. A virtual information security officer (VISO) service can help institutions effectively manage information security so that nothing gets missed or falls through the cracks.

Common Types of VISO

The most common types of virtual ISO solutions available to institutions are the “do-it-yourself” (DIY), “hybrid,” and “offload” models. The DIY option is designed for institutions that have a solid grasp of the ISO’s job functions and just need some basic tools and limited consultation to enhance their efforts. This model is the least expensive but also requires more of a time commitment from your internal resources. The hybrid model may typically include an assortment of apps, templates, pre-configured reports, and other tools, along with a broader and deeper level of consultation. Resource requirements from the institution side are greatly reduced compared to DIY, but typically greater than offload. Accordingly, costs for a hybrid approach are somewhere between the two other models. The hybrid model also tends to be the most flexible and is designed to evolve with the changing needs of the institution. Finally, the offload approach attempts to provide a “turn-key” solution wherein the virtual ISO partner effectively assumes most or all the responsibilities of your internal ISO. This approach requires the least involvement from your institution (which could introduce other challenges…see the “Examiner Support” section below), but it is usually also the most expensive. As this model is the most inclusive, the knowledge and experience of the third-party provider are your most important consideration. The offload approach typically includes unlimited consultation, on-demand reporting, participation in committee meetings, etc.

Key Factors to Consider

When choosing a virtual ISO, there are some important aspects to consider to ensure your institution selects the best option. Keep in mind that each virtual ISO model comes with a certain level of flexibility and engagement for a specific price. The key is to carefully balance the service and costs against your specific internal resource gaps to determine the best solution for your situation. Ideally, whatever solution you choose should have the flexibility to dial up or down the level of service, depending on how your situation may change in the future.

Whatever virtual ISO solution you opt for, it should provide documentation and reporting in a form that the various stakeholders can understand. Each one of the many ISO responsibilities has one or more reports or documents that support the requirement to hold the ISO accountable for its responsibilities. The board of directors, the steering committee, the IT auditors, and examiners, all have different perspectives and comprehension levels and may require different degrees of detail for the same information. For instance, boards and examiners might require higher-level data, whereas steering committees and IT auditors might require more detailed documentation for their purposes. You should have access to on-demand reporting with relevant, actionable, up-to-date information that matches the level of engagement for the various stakeholder groups.

The regulatory guidance on ISO responsibilities includes terms such as “engaging with” and “working with” management in the individual lines of business to understand the risks of various initiatives. They also expect the ISO to “implement” the information security strategy as defined by the board, and to periodically “inform” the board and senior management on the status of the program. In the case of a virtual ISO, your hybrid or offload third-party partner needs to have an excellent understanding of enterprise-wide strategic objectives, and a good working relationship with management in all lines of business and within the different departments within your organization.

Remember, as with all outsourced activities, even though you can delegate some (or even most) of the heavy lifting to a virtual ISO, you cannot outsource responsibility. Your institution still must maintain a strong oversight effort to ensure that all ISO duties are completed, documented, and reported appropriately. Higher levels of third-party reliance require correspondingly higher levels of oversight. According to the Federal Financial Institutions Examination Council’s Outsourcing Technology Services booklet you are obligated to oversee all activities, whether you perform them, or a third-party performs them on your behalf.

Examiner Support

The examiner feedback we have seen to date strongly supports the idea of financial institutions implementing a virtual ISO solution “…as long as it’s done correctly.” That means focusing on all the responsibilities and accountabilities of the role and making sure sufficient documentation and appropriate oversight and reporting are built-in. Doing it correctly also means making sure the in-house ISO is not so detached from the processes and procedures that they cannot authoritatively explain them to a stakeholder, which can be the primary downside of the “offload” model. The decision-making process is the most important concern for regulators. Your solution should allow you to offload enough to make the ISO’s job easier and more organized, but not so much that they become disconnected and lose operational awareness of their current threat and control environment.

In conclusion, choosing the right type of virtual ISO service allows institutions to provide the appropriate level of insight and oversight for their in-house ISO. This can help them to be better equipped to manage information security activities, meet evolving industry standards, and adjust to tightening regulatory requirements, all in an increasing cyber threat environment.

At Safe Systems, we offer a virtual ISO service based on the above-described hybrid model. ISOversight™, is a VISO service that is flexible to accommodate the changing needs of community banks and credit unions. The ISOversight service includes a full suite of applications to manage everything from vendors to business continuity, along with all associated information security policies and risk assessments. This is a cost-effective, comprehensive, and flexible solution that makes information security management much more efficient. For more insight about the most common virtual ISO models and how to determine which one may be right for you, view our webinar on “Is a Virtual ISO Right for You?”

09 Jun 2022

Banks, Compliance, Credit Unions The Safe Systems Compliance Team 0 comment

Planning for Safety, Soundness, and Resiliency

With the rise in cybercrimes and increased regulatory scrutiny, having a board-approved IT Strategic Plan is often not enough to ensure cyber resiliency. It’s essential for financial institutions to develop a robust IT management and information security infrastructure. The following excerpts from our recent white paper on “Building IT and Information Security Resiliency in Chaotic Times,” show how institutions can strengthen and support these key management roles to make better technology and security decisions, improve visibility, and reduce vulnerability. In addition, institutions can use strategic partners and risk management solutions to bolster resources they already have in place and enhance their overall cyber resilience.

1. Separating ISO Duties

Examiners have a strong interest in the IT administrator and ISO roles, which are interconnected and integral to an institution’s safety and soundness. However, many community banks and credit units still struggle with meeting the FFIEC requirements for segregating these positions. The importance of separating ISO duties relates to creating additional oversight to verify activities and maintain accountability to management and the board. Separating these functions also helps to build a clear audit trail to ensure risk is being accurately assessed and reported to senior management. While the ISO functions in an oversight capacity of the IT administrator, the ISO also relies heavily on the administrator to share data that can be used to recommend steps to improve the institution’s security posture. Therefore, the IT admin-ISO relationship must also be cooperative to ensure their daily activities support the organization’s policies and procedures.

2. Being Proactive about Succession Planning

Regulators expect financial institutions to have a formal succession plan for the ISO, IT administrator, and other key leadership roles, as indicated by the uptick in exam findings related to this issue. Depending on their size, type, and goals, institutions may employ different approaches for succession planning. They can identify and train someone to serve as an alternate or “backup” for various IT or ISO responsibilities, incorporate an internal committee or team approach for managing IT and information security, or use the support of a trusted third party to maintain IT and information security standards.

3. Partnering with a Trusted Third Party

An outside expert can provide an objective perspective that can help institutions think beyond the day-to-day issues and consider risk more proactively and strategically. Bringing in a technology partner on the front end—when things are going well—can also position institutions to be stronger and more successful in the future. For instance, a virtual information security officer (VISO) can expand an internal ISO’s capabilities and increase the likelihood that all ISO-related tasks are completed in a timely and efficient manner. A VISO can also provide an external layer of oversight to enable the required separation of duties.

ISOversight^®, our virtual ISO service, makes it easier for financial institutions to master information security and manage compliance online. ISOversight is a comprehensive solution with a full suite of applications and resources, cyber risk reporting, and dedicated compliance specialists. It’s uniquely designed to help banking institutions enhance their strategies to improve IT management, information security, and compliance. With ISOversight, community banks and credit unions can ensure that no information security issues fall through the cracks—especially during challenging times.

For more information about how to enhance your institution’s security posture, read the full white paper on “Building IT and Information Security Resiliency in Chaotic Times.”

30 Dec 2021

Banks, Compliance, Credit Unions, Security, Technology Christine Ray 0 comment

Our Top Blog Posts of 2021

With a new year approaching, it’s a good time to review some of the key discussions from the past year. Read these highlights from our top blog posts of 2021, to help your financial institution refine key operational strategies for 2022 and beyond:

1. 2021 Hot Topics in Compliance: Mid-Year Update

Although the COVID-19 pandemic isn’t over, financial institutions have learned valuable lessons so far. Key impacts have been primarily operational, involving risks related to temporary measures taken to weather the crisis. In addition, there are important compliance trends and new regulatory guidance institutions should anticipate going forward. Ransomware cybersecurity has been a key area of focus for regulators, and given the recent high-profile cyber events affecting the industry, their scrutiny will likely increase in the future. This will be reflected, in part, by the number of (and types of) assessments that regulators might expect institutions to perform annually. These assessments from various state and federal entities include the Cybersecurity Assessment Tool (CAT), the optional Ransomware Self-Assessment Tool (R-SAT), the Cybersecurity Evaluation Tool, and the modified Information Technology Risk Examination for Credit Unions (InTREx-CU). In addition, there have been major shifts with cyber insurance, and the FFIEC released a new Architecture, Infrastructure, and Operations booklet in its Information Technology Examination Handbook series. Read more.

2. The 4 “R’s” of Disaster Recovery

Maintaining an effective approach to disaster recovery can help financial institutions satisfy regulatory requirements, better protect themselves from the effects of negative events, and improve their ability to continue operating after a disaster. There are four important “R’s” that institutions should concentrate on for disaster recovery: recovery time objective ( RTO ), recovery point objective ( RPO ), replication , and recurring testing .

RTO is the longest acceptable length of time a computer, system, network, or application can be down after a disaster happens. When establishing RTOs, prioritizations must be made based on the significance of the business function and budgetary constraints. The RPO is the amount of time between a disaster occurring and a financial institution’s most recent backup. Essentially, the RPO will be determined by the institution’s technology solution and risk tolerance. DR replication entails having an exact copy of an institution’s data available and remotely accessible when an adverse event transpires. The best practice is to keep one backup copy onsite and another offsite in a different geographic location that’s not impacted by the disaster. Recurring testing allows institutions to identify key aspects of their DR strategy and adjust as needed to accomplish their objectives. Regular testing can expose potential problems in their DR plan so they can address these issues immediately. Read more.

3. Segregation of ISO Duties Critical to Network Security and Regulatory Compliance for FIs

It’s crucial for financial institutions to maintain distinct duties between their information security officer (ISO) and network administrator to ensure network security, regulatory compliance, and the health of their operations. There should be at least one designated ISO who is responsible for implementing and monitoring the information security program and who reports directly to the board or senior management—not to IT operations management. The significance of segregating the ISO’s duties comes down to oversight: Separating ISO and network administrator tasks helps to create a clear audit trail and ensures risk is being accurately assessed and reported to senior management . It also allows the ISO to provide another “set of eyes” that help to maintain a level of accountability to management, the board, and other stakeholders. The ISO’s independent role primarily serves to ensure the integrity of an institution’s information security program . Financial institutions can also use a virtual ISO to create an additional layer of oversight on top of what they have in place internally. Read more.

Discover these and other key topics about banking compliance, security, and technology on the Safe Systems blog.

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14 Jul 2020

Banks, Compliance, Credit Unions Tom Hinkel 0 comment

The ISO in a Crisis: Key Responsibilities of the Information Security Officer During a Pandemic

According to the Federal Financial Institution Examination Council’s (FFIEC) Information Technology Examination Handbook, “ISOs are responsible for responding to security events by coordinating actions to protect the institution and its customers from imminent loss of information, managing the negative effects on the confidentiality, integrity, availability, or value of information, and minimizing the disruption or degradation of critical services.”

When faced with an operational crisis such as the current Covid-19 Pandemic, potential disruption of critical services is the primary concern. Since the information security officer (ISO) acts as the “quarterback” over the many different departments and functions within the institution, they must make sure all routine tasks are still being completed, in addition to ensuring that the institution has adapted to the unique circumstances of the crisis.

The FFIEC Management Handbook lists 8 broad categories of responsibilities for ISO’s. We’ve identified a few of those areas that should be of particular focus during a crisis:

Working With The IT Steering Committee

During any crisis, the ISO must work closely with the IT Steering Committee to ensure that the institution minimizes the risks to the security and confidentiality of non-public information and financial transactions. As difficult as this is during normal operations, it may be even more of a challenge during a crisis. Key considerations include:

The IT Steering Committee should still perform their normal duties and maintain a normal schedule. Phone /video conferences can suffice if in-person meetings are not an option.

Attention to on-going and planned IT project road map/initiatives. Timelines and all supporting activities must still be tracked, project plans updated, and all stakeholders informed.

Review the Remote Access Policy and the Remote User / Acceptable Use Acknowledgement with IT and HR as your current situation may include unique risks that have not been previously addressed. For example, some employees may have to use their personal devices to access the FI’s network to do their job. Take particular note of the Remote Access and Use of Remote Devices sections of the FFIEC Information Security Handbook and any other related best practices and/or guidance initiatives. Trusted third parties can also be an important resource for this effort.

Document all actions taken and lessons learned during the crisis so far. Then, incorporate them into your next round of policy updates.

Continue to report the status of all IT and information security activities to the Board.

Managing Incident Response, BCP/IRP, and Cyber Responsibilities during an Adverse Event

The ISO is typically the Incident Response Team Coordinator and may determine whether or not to activate the formal Incident Response Plan (IRP). The declaration of a pandemic or other adverse operational event does not in itself require the IRP to be invoked, however, any disruption of normal business services may create vulnerabilities that a cyber attacker could take advantage of.

The ISO will also likely be involved with general business continuity planning and recovery efforts. The criteria for activating the Business Continuity Plan will vary by institution, but the ISO is typically one of the few key individuals tasked with evaluating whether the event is likely to negatively impact the institution’s ability to provide business products and services to customers beyond recovery time objectives (RTOs).

In adverse situations, cyber awareness should be heightened. For example:

The institution could have key personnel out, and alternate personnel may not be adequately trained or have the same level of cyber awareness as the primary staff members.

The institution may be implementing workarounds for new software or devices when trying to accommodate customers affected by the event. In the interest of expediency for customers, the institution may take shortcuts that it normally wouldn’t or otherwise fail to follow normal procedures.

The institution could run into issues with the critical vendors that perform or support its perimeter security, compromising real-time alerting for the organization. This is known as “cascading impact”, where a product or service provided by a third-party is degraded, which in turn affects you.

The institution could experience secondary disruptions where hackers may attempt a cyber-attack against perceived weakened defenses.

The ISO must anticipate all of these risks and should communicate with critical third parties to ensure they have a plan in place to keep the NPI and financial transactions secure and provide critical operational services at acceptable levels of risk.

Addressing Auditor and Examiner Expectations

Although a pandemic, as a crisis event, was de-emphasized in the 2019 BCM Handbook, financial institutions should expect regulators to issue additional joint statements in the post-pandemic phase due to the shear impact and duration of this event. ISOs should expect examiners to ask about the specific actions the institution has taken in response to COVID-19, including:

Succession plans – ISOs should be prepared to share the institution’s succession plans, how these plans were implemented during the pandemic, and any key updates to the plan post-pandemic.

Cross-training efforts – the ISO (if also the BCP Coordinator) should explain the institution’s plans for cross-training and how these plans were implemented during the pandemic.

Remote access controls – the ISO should address all of FFIEC requirements for remote access and document any updates or changes that occur.

Third-party/supply chain issues – the ISO should communicate with all critical vendors to ensure there are no interruptions to critical services, and he or she should have contingency plans in place if a third-party provider can no longer provide adequate service.

Information security officers ultimately must be able to show auditors and examiners exactly how the institution withstood the pandemic, maintained compliance, kept all non-public information secure, and kept all stakeholders informed, all of which is no small task during normal operations!

For more information on responding to crisis events, view our pandemic resources.

09 Apr 2020

Banks, Compliance, Credit Unions Christine Ray 0 comment

American Pride Bank Tackles Information Security Responsibilities with Safe Systems’ ISOversight Virtual ISO Solution

With ongoing cybersecurity threats; increased use of third-party providers; and constantly evolving regulatory and reporting requirements, the role of the information security officer (ISO) is even more important in today’s complex banking environment than ever before. However, community bank and credit union ISOs often struggle to keep up with the growing number of responsibilities this role requires – often forced to manage critical tasks with limited resources and a lack of segregation of duties.

The Challenge

Nicole Rinehart, Chief Operations Officer at American Pride Bank, ran into this very issue as the sole IT admin at American Pride Bank. Managing all of the ISO responsibilities, including critical activities such as Board reporting and the production of comprehensive reports for examiners, was difficult to manage due to the many manual processes required.

During a regulatory examination, an examiner recommended the bank focus on having more independence within its ISO duties. The Federal Financial Institution Examination Council (FFIEC) states that all financial institutions must have separation of duties for the ISO role. To accomplish this, the bank began evaluating solutions to help streamline processes and ensure complete oversight of all information security activities.

The Solution

After consideration, American Pride Bank decided to partner with Safe Systems and implement its ISOversight virtual ISO solution. The service includes a suite of applications and programs to help institutions streamline management of key compliance duties including the CAT, BCP, Vendor Management and Information Security.

In this case, the bank was already leveraging individual components of ISOversight. By converting to the virtual ISO service, they gained additional tools, reports, and expert compliance support. An important part of the solution includes monthly meetings with the Safe Systems compliance team to assess the bank’s information security activities and provide guidance.

The Results

With ISOversight, American Pride Bank has improved its overall preparation and communication of the information security program. All key stakeholders in the bank have access to ISO-related items in real-time, and the information security program is more organized and streamlined, enabling the bank to save time on monitoring and reporting.

“The ISOversight solution has been a game-changer for our bank because now we have a robust process in place working with Safe Systems and a full committee of our team members to ensure all tasks are completed accurately and nothing slips through the cracks,” said Rinehart. “It’s so important to have a process like this, especially when you have limited resources. Safe Systems has truly become an extension of our internal team, helping us to stay on track with ISO responsibilities and ensuring we comply with all regulatory requirements.”

To learn more, read the full case study, “American Pride Bank Streamlines Processes and Improves Compliance Reporting with Safe Systems’ ISOversight Virtual ISO Solution.”