SOS Indiana Advisory
And now that we are all paying attention . . .
A great example of Awareness Activation!
Another one of those Dan’s New Leaf Posts, meant to inspire thought about IT Governance . . . .
When we finally release our annual “trend article” . . . . and we’re sorry it’s taking so long but we’re only supposed to name seven trends and we’re at nine still . . . . but when we do release that article, I’m almost certain the number one trend will be called “The End of Procrastination,” and the number six trend will be called “Lawyers Join the Incident Response Team.” Interestingly, today I’ve witnessed the intersection of these two trends
Check out what the Secretary of State in Indiana sent today, in an advisory.
To summarize, the advisory suggest that investors ask their “investment professional” what safeguards their financial institution has to protect against cyber-risk. And then she bullet-points eight questions to ask:
- Has the firm addressed which cybersecurity threats and vulnerabilities [that] may impact its business?
- Does the firm have written policies, procedures, or training programs in place regarding safeguarding client information?
- Does the firm maintain insurance coverage for cybersecurity?
- Has the firm engaged an outside consultant to provide cybersecurity services?
- Does the firm have confidentiality agreements with any third-party service providers with access to the firm’s information technology systems?
- Has the firm ever experienced a cybersecurity incident where, directly or indirectly, theft, loss, unauthorized exposure, use of, or access to customer information occurred? If so, has the firm taken steps to close any gaps in its cybersecurity infrastructure?
- Does the firm use safeguards such as encryption, antivirus and anti-malware programs?
- Does the firm contact clients via email or other electronic messaging, and if so, does the firm use secure email and/or any procedures to authenticate client instructions received via email or electronic messaging, to work against the possibility of a client being impersonated?
Now I’m of course glad that the Secretary of State has joined us in the battle against cyber-risk, and we sure welcome the questions. They’re good ones.
And talk about a great way to make sure the training work gets done . . . just scare investors into bombarding the institution with questions.
Yes, the questions are good ones and my Clients (or at least their ISOs) are ready to answer them all. But stilll, can you say “ouch” on number six? I’d think carefully about your answer. If I was asked that at infotex, my answer would be:
“Of course we’ve experienced minor incidents from time to time and we’ve always learned from them. Nothing major; nothing that I can recall now. You have to realize we’ve been managing technology risk since we started our firm in 2000 so of course, we’ve had our lessons. But in the past few years, we have had no incidents that would warrant notifying our customers and that’s the important thing. If there ever IS an incident that affects your data, we will notify you.”
To this I’ve three questions:
- Are your “Investment Professionals” ready to answer these questions?
- Would it be better to arm them with an eight-point document that can be handed and/or e-mailed to the investor?
- Is this an incident that requires an Emergency Incident Response Meeting?
Those of you who have “Awareness Activation Programs” in place . . . . you know what to do next. Those of you who don’t . . . . good luck!
Original article by Dan Hadaway CRISC CISA CISM. Founder and Managing Partner, infotex
Dans New Leaf is a fun blog to inspire thought in the area of IT Governance.