and Andrew Retrum, Managing Director
Security and Privacy
Global cybersecurity risk has never been higher, especially at financial institutions, which are often targeted for their high-value information. Earlier this year, Protiviti published its 2017 IT Security and Privacy Survey, which found a strong correlation between board engagement and effective information security, along with a general need to improve data classification, policies and vendor risk management.
We sat down with our colleagues Scott Laliberte, Managing Director in our Cybersecurity practice, and Adam Hamm, Managing Director, Risk and Compliance, to discuss how these overall findings compared to those specific to the financial services segment, and why the financial services industry differed from the general population in some aspects. We outlined the comparisons in a recently published white paper. What follows is a sampling of some of the questions we addressed, with a brief summary of the answers. For a more detailed analysis and more data specific to the industry, we recommend downloading the free paper from our website.
Q: What are the top IT security and privacy-related challenges facing financial services firms today?
A: Disruptive technologies, third party risk, shadow IT — systems and solutions built and used inside the organization without explicit organizational approval — and data classification, are top concerns, not only for FSI firms but for survey respondents generally.
Data classification is a particularly challenging and important issue for the financial services industry — both from security and compliance perspective. We often talk about “crown jewels” — data that warrants greater protection due to its higher value. Establishing effective data classification and data governance are multi-year efforts for most institutions, and they must be consistently managed and refreshed. And, the difficulty of these efforts are compounded by the unique complexity of financial systems. Naturally, financial services forms are slightly ahead in the data classification game than their counterparts in other industries, due to their more acute awareness and ongoing and focused efforts, but they still have a long way to go.
Q: Boards of directors of financial firms are more engaged and have a higher understanding of information security risks affecting their business compared to other industries. What does this tell you about the level of board engagement at financial institutions?
A: Financial institutions are being attacked and breached more often than companies in other industries due to the high value of their information. As a result, regulators have been pushing boards at financial services firms to become more aware of and involved in cyber risk management. The Gramm-Leach-Bliley Act (GLBA), as well as guidance from the Federal Financial Institutions Examination Council (FFIEC), both encourage regular cyber risk reporting to the board and management. The New York Department of Financial Services similarly requires that CISOs at insurance companies provide a report to the board on the cyber program and material cyber risks of the company, at least annually. As we noted in the beginning, our survey found a strong correlation between board engagement and cybersecurity maturity in all organizations — so the higher involvement of financial services firms’ boards bodes well for their companies’ cybersecurity, provided directors get actively engaged with management on this topic.
Q: Over half of financial services respondents to the survey said they were “moderately confident” they could prevent a targeted external attack by a well-funded attacker. Is this an accurate assessment of most financial institutions?
A: Given that the probability of a cyber attack on a financial institution has become a matter of “when,” rather than “if,” we would not expect any institution to have a high — or even moderate — degree of confidence. It may be a measure of false confidence that so many organizations think they can prevent an attack. The onus is now on firms to assume that an attack is likely, and be prepared to limit its impact.
Q: Most financial services respondents indicated that they were working with more big data for business intelligence compared to last year. What should firms be concerned about with regard to their growing use of big data?
A: Big data includes both structured and unstructured data, which is more difficult to classify. Firms may also be dealing with new technologies with different security characteristics as well as more data distributed in the cloud. All of these factors complicate data management for financial institutions. As financial institutions rely more on big data, it is critical that they know what data to protect, its location and all of the places it might travel over its lifecycle in the system. Just as important is the need to control access to data and to protect the integrity of that data as more users interact with it for a growing number of reasons.
Q: More and more firms are using third parties to access better services and more advanced technology, but are financial institutions doing enough to counter new risks arising from third parties, such as partnerships with fintech companies?
A: Financial institutions are digital businesses, with more and more capabilities provided via mobile devices and through partnerships with financial technology, or fintech, companies. Many fintechs are small startup organizations that may lack the rigor and discipline of a traditional financial services firm. While innovation is necessary to compete in today’s fast-paced world, organizations need to take appropriate steps to ensure there are appropriate controls in place, and test those controls to minimize risk from third parties.
The full paper goes into significantly more detail on these and other questions than the abstract provided here, and presents the perspective of both security and risk and compliance experts. Let us know if you find it helpful.