With the rise in cyber threats and the increasing complexity of regulatory requirements, Information Security Officers (ISOs) face unprecedented challenges. This blog focuses on the importance of governance and effective communication as a key strategy for enhancing operational resiliency.
The Gramm-Leach-Bliley Act (GLBA) first brought to the forefront the importance of establishing the role of an ISO for financial institutions (FIs). However, the significance of this role has only magnified as information technology has become essential to every department and business function within an FI. The exposure of customer non-public information (NPI) has exponentially increased with the widespread adoption of online transactions, mobile banking, and third-party relationships.
Managing information security risks effectively requires collaboration. Each stakeholder group, including end-users, IT management, IT Steering Committee, Executive Management, Risk/Audit Committees, and the Board of Directors, plays a crucial role in supporting and executing information security standards. Segregating duties between IT management and the ISO is one of the biggest challenges for many FIs. For those that lack a formal infrastructure, the FFIEC provides “visibility” and “accountability” guidelines showing how an ISO can and should collaborate with IT management.
In addition, ISOs must break down silos and communicate clearly with all the various stakeholders. This effort requires access to relevant, actionable, and up-to-date information that aligns with each group’s distinct reporting needs, engagement level, and technical understanding.
ISOs may also need to broaden the scope and frequency of their communications. For instance, it is a good best practice to meet with the Board more frequently than once a year. Board members will benefit from periodic discussions with the ISO and IT management to accurately and quickly identify potential issues related to risk such as inconsistent server backups, software patches, and systems nearing EOL. A comprehensive understanding of Human Resources standards and their impact on information security is also important to ensure that policies and procedures are consistent across the organization.
To facilitate and ensure these meetings and conversations are effective, ISOs should rely on industry-standard frameworks that can be customized for audience-based agendas and repeatable tasks. Essentially, ISOs should be transparent in communicating changes that could result in increased risk to NPI.
Overall, this can be a challenging effort, especially for smaller banks and credit unions who may not have the expertise or the time to ensure a consistent approach to governance and communication. For this reason, many FIs choose to partner with a reliable Virtual Information Security Officer (VISO) service. These third-party services provide strategic guidance and the necessary oversight to ensure comprehensive information security management.
Safe Systems ISOversight® is a VISO service that includes a suite of applications, real-time reporting, and knowledgeable FFIEC risk-management professionals who assist with policy implementation, third-party relationship management, BCP, cybersecurity risk assessments, incident response and BCP testing, and other required tasks that are customized for each FI. They also provide ongoing coaching and accurate reporting to help with communication tailored to each stakeholder group. These collaborative efforts will go a long way to ensure operational resiliency and reduce reputation risk.
For a deeper understanding of governance and communication within the ISO role and to gain more insights into enhancing operational resiliency, refer to the complete white paper, Operational Resiliency: Elevating the Role of the ISO.
