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Protection Beyond Compliance:
Effective Cyber Security Risk Management
Speaking with you today
Vikas Bhatia – CEO & ERA
Vikas is the founder, CEO and Executive Risk Adviser at Kalki. He has 18+ years’ experience,
obtained serving local, regional & global clients in the outsourcing, consulting, and regulatory
domains, enabling him to enhance any organizations Information Security Management
System (ISMS).
He is a Certified Chief Information Security Officer (C|CISO), Certified Information Systems
Security Professional (CISSP), and Certified Information Privacy Professional (CIPP).
Risk = Likelihood x Impact
How is everything connected?
Where are we least prepared?
Finding 1: It took the Target breach to get the board’s
attention.
What brings your attention to cybersecurity? What
influences the way you feel about cybersecurity?
Target Attack Timeline
Finding 2: Board members may be overly confident about
the effectiveness of their cybersecurity governance
practices and often rate the effectiveness of these
programs much higher than IT security professionals do.
Lets talk about how you feel about this finding and how
this relates to you and your role within VFCU.
Perceived Effectiveness of Cybersecurity Governance Practices
Finding 3: Board members admit their knowledge about
cybersecurity is limited.
How can we work to improve your understanding of
cybersecurity issues and risk levels?
Perceived Knowledge about Cybersecurity
Incident Classification Patterns
Finding 4: Board members may not be receiving
information and briefings about cyber attacks and data
breaches affecting their organization.
Do you feel you are receiving enough information on
data security and data breaches to help grow your
knowledge and understanding of cyber threats?
Board Knowledge of Breaches
Breach Discovery Methods
Finding 5: IT security professionals are skeptical of their
board’s understanding about cybersecurity risks.
Technology and strategic management often have trouble
seeing eye-to-eye on cybersecurity readiness and needs.
How can we get everyone speaking the same language?
Board vs. IT Perceptions
Survey
Who from your organization is responsible for handling technology outages? CEO or IT Team
How confident are you in that person’s ability to respond to those outages? Somewhat - Very Confident
How confident are you in your company’s ability to recover from such an
incident?
Somewhat - Very Confident
Who from your organization is responsible for handling and responding to
unauthorized disclosure of information or a breach?
CEO
How confident are you in that person’s ability to respond to such an
unauthorized disclosure?
Somewhat - Very Confident
How confident are you in your company’s ability to recover from such an
incident?
Somewhat - Very Confident
Technology Outages
Handling a Breach
What’s important to Credit Unions?
Serving the member
Reputation Service Stability Trust
Innovation Engagement Dedication
Value Growth
Strategic Drivers
A Credit Union’s revenue is
driven by the trust of its
members.
The loss of even a small
percentage of membership
due to loss of trust would
result in significant financial
loss.
Revenue
The day-to-day operations of
branches is vital. Members
expect 24x7 access to funds
and rely on branches to be
operational.
Operational downtime incurs
significant costs including
productivity costs, costs of
restoration of service or
funds and costs due to lost
membership.
Operations
Credit Unions pride
themselves on their
reputation among members
and rely on that reputation
to retain and grow their
membership.
The impact of a breach on
that reputation would be
detrimental. A focus on
SecurITy will provides a key
differentiator to improve
member trust and build
reputation.
Reputation
The NCUA compliance
framework was designed in
2006, provides very little
guidance and represents a
minimum standard.
Outdated compliance
standards do not keep pace
with current threats and are
not sufficient to protect
member data.
Compliance
Mission: to best serve members.
What’s important to your
Credit Union?
Do we walk the walk?
Ranking
Area 1 2 3 4
Reputation 6 2 3 1
Revenue 1 1 2 8
Operations 2 5 4 1
Compliance 4 4 3 1
Sample priority ranking by a previous Credit Union client. Does this look familiar?
An over-focus on compliance may not support the objective of serving the member community.
What are we protecting? … Our Members!
Technical SecurITy
Physical SecurITy
Protection is not:
SecurITy Direction
Incident Management Business Continuity Technical SecurITy Compliance
Access Control Physical SecurITy Operations SecurITy 3rd Party SecurITy
Organization of SecurITy Human SecurITy Asset Management
How do we protect it?
How are we measuring what we’re doing?
The Capability Maturity Model Integration (CMMI) will be used to measure our journey.
Maturity Level Name Definition
0 Non-existent
Complete lack of any recognizable processes. The enterprise has not even recognized that there is an
issue to be addressed.
1 Initial / Ad Hoc
There is evidence that the enterprise has recognized that the issues exist and need to be addressed.
There are, however, no standardized processes; instead, there are ad hoc approaches that tend to be
applied on an individual or case-by-case basis. The overall approach to management is disorganized.
2
Repeatable
but Intuitive
Processes have developed to the stage where similar procedures are followed by different people
undertaking the same task. There is no formal training or communication of standard procedures, and
responsibility is left to the individual. There is a high degree of reliance on the knowledge of individuals
and, therefore, errors are likely.
3
Defined
Process
Procedures have been standardized and documented, and communicated through training. It is mandated
that these processes should be followed; however, it is unlikely that deviations will be detected. The
procedures themselves are not sophisticated but are the formalization of existing practices.
4
Managed and
Measurable
Management monitors and measures compliance with procedures and takes action where processes
appear not to be working effectively. Processes are under constant improvement and provide good
practice. Automation and tools are used in a limited or fragmented way.
5 Optimized
Processes have been refined to a level of good practice, based on the results of continuous improvement
and maturity modelling with other enterprises. IT is used in an integrated way to automate the workflow,
providing tools to improve quality and effectiveness, making the enterprise quick to adapt.
Incident Management Business Continuity Technical SecurITy Compliance
Access Control Physical SecurITy
SecurITy Direction Human SecurITy
Sample Client: What are they doing now?
Operations SecurITy
Incident Management
(2)
Business Continuity
(3)
Technical SecurITy
(1)
Compliance
(3)
Access Control
(3)
Physical SecurITy
(3)
SecurITy Policies
(1)
Human SecurITy
(2)
Sample Client: How are well are they doing the things they are doing?
Operations SecurITy
(1)
Incident Management Business Continuity Technical SecurITy Compliance
Access Control Physical SecurITy
SecurITy Direction Human SecurITy
Sample Client: What’s the bigger picture?
Operations SecurITy
So What…
Scenario A: Breach
Remediation Costs
Total Number of records
X
$154 per record*
Additional Impact
• Reputational impact
• Additional
productivity impacts
• Cost of remediation
*Ponemon institute: average cost of breach remediation is $145 per record
Example:
15,000 members
X
$154 per record*
=
$2,310,000
Cyber Insurance: Incident Response Responsibilities
Do you know which stages of the incident
response process your company is responsible for
handling vs. your insurance company?
Do you have a written, tested and
functional incident response process in place?
Cyber Insurance: Internal Security Controls
Did you know that your insurance provider can
refuse to pay out if you aren’t taking preventative
measures?
Do you know all the cyber security program
elements you are expected to have in place?
Cyber Insurance: Payout and Expectations
What are your policy’s max and average payouts?
Does either one of those numbers cover the cost
of the breach estimated earlier?
Do you know what you are expected to provide
and when to provide it when notifying your cyber
insurance of a problem? Do you have these
expectations built in to your company's internal
processes?
$$$
Scenario B: Downtime due to system outage
Productivity Costs
$ amount per day
in Salary costs
Additional Impact
• Reputational impact
• Additional
productivity impacts
• Cost of remediation
Scenario C: Malware outbreak
Numbers and costs based on actual malware incidents at 150 employee financial firm in NY.
Incident 1: Pre-SecurITy (June 2014)
100% of firm’s users
affected
Lost productivity totaled
approx. 3,600 hours
Approx. 145 hours
combined (internal IT
team and vendors) spent
on clean-up
Total outbreak cost:
Approx. $325,000
Incident 2: Mid-SecurITy Implementation (June 2015)
5% of firm’s users
affected
Lost productivity totaled
approx. 255 hours
Approx. 96 hours
combined (internal IT
team and vendors) spent
on clean-up
Total outbreak cost:
Approx. $25,000
Difference
95% 3,345 hours 49 hours $300,000
Opportunities
Where should we start?
Education: Target your weakest links ASAP!
TEST
Regularly test your
employees to see how they
behave! Run regular 3rd party
Phishing & Social Engineering
Testing to practice the real
thing and see how they
respond. Conduct a recurring
Security Awareness Survey to
measure the culture around
security and gauge the level
of employee knowledge.
TEACH
Provide interactive training
on security that’s geared
toward educating even the
non-technical employees at
your company. Use a variety
of instructor-led and digital
methods. Make sure your
trainers are ready to teach
employees WHY they should
care and how to protect both
themselves and the
company.
TRACK
Measure your success and
adjust accordingly. Track key
metrics including
participation. Use the
methods in the TEST section
to regularly benchmark
where your employees fall
and measure improvements
in the results. Make
adjustments and
improvements over time to
mature your education
program.
DIY Resources
Beginner’s Guide to Data
Classification
SecurITy Checklist for
Executives
Project Initiation Form
Template
Risk Register Template
Questions?
protected@kalkiconsulting.com
www.kalkiconsulting.com
1.855.GO.KALKI

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Credit Union Cyber Security

  • 1. Protection Beyond Compliance: Effective Cyber Security Risk Management
  • 2. Speaking with you today Vikas Bhatia – CEO & ERA Vikas is the founder, CEO and Executive Risk Adviser at Kalki. He has 18+ years’ experience, obtained serving local, regional & global clients in the outsourcing, consulting, and regulatory domains, enabling him to enhance any organizations Information Security Management System (ISMS). He is a Certified Chief Information Security Officer (C|CISO), Certified Information Systems Security Professional (CISSP), and Certified Information Privacy Professional (CIPP).
  • 3. Risk = Likelihood x Impact
  • 4. How is everything connected?
  • 5. Where are we least prepared?
  • 6. Finding 1: It took the Target breach to get the board’s attention. What brings your attention to cybersecurity? What influences the way you feel about cybersecurity?
  • 8. Finding 2: Board members may be overly confident about the effectiveness of their cybersecurity governance practices and often rate the effectiveness of these programs much higher than IT security professionals do. Lets talk about how you feel about this finding and how this relates to you and your role within VFCU.
  • 9. Perceived Effectiveness of Cybersecurity Governance Practices
  • 10. Finding 3: Board members admit their knowledge about cybersecurity is limited. How can we work to improve your understanding of cybersecurity issues and risk levels?
  • 11. Perceived Knowledge about Cybersecurity
  • 13. Finding 4: Board members may not be receiving information and briefings about cyber attacks and data breaches affecting their organization. Do you feel you are receiving enough information on data security and data breaches to help grow your knowledge and understanding of cyber threats?
  • 14. Board Knowledge of Breaches
  • 16. Finding 5: IT security professionals are skeptical of their board’s understanding about cybersecurity risks. Technology and strategic management often have trouble seeing eye-to-eye on cybersecurity readiness and needs. How can we get everyone speaking the same language?
  • 17. Board vs. IT Perceptions
  • 18. Survey Who from your organization is responsible for handling technology outages? CEO or IT Team How confident are you in that person’s ability to respond to those outages? Somewhat - Very Confident How confident are you in your company’s ability to recover from such an incident? Somewhat - Very Confident Who from your organization is responsible for handling and responding to unauthorized disclosure of information or a breach? CEO How confident are you in that person’s ability to respond to such an unauthorized disclosure? Somewhat - Very Confident How confident are you in your company’s ability to recover from such an incident? Somewhat - Very Confident Technology Outages Handling a Breach
  • 19. What’s important to Credit Unions? Serving the member Reputation Service Stability Trust Innovation Engagement Dedication Value Growth
  • 20. Strategic Drivers A Credit Union’s revenue is driven by the trust of its members. The loss of even a small percentage of membership due to loss of trust would result in significant financial loss. Revenue The day-to-day operations of branches is vital. Members expect 24x7 access to funds and rely on branches to be operational. Operational downtime incurs significant costs including productivity costs, costs of restoration of service or funds and costs due to lost membership. Operations Credit Unions pride themselves on their reputation among members and rely on that reputation to retain and grow their membership. The impact of a breach on that reputation would be detrimental. A focus on SecurITy will provides a key differentiator to improve member trust and build reputation. Reputation The NCUA compliance framework was designed in 2006, provides very little guidance and represents a minimum standard. Outdated compliance standards do not keep pace with current threats and are not sufficient to protect member data. Compliance Mission: to best serve members.
  • 21. What’s important to your Credit Union?
  • 22. Do we walk the walk? Ranking Area 1 2 3 4 Reputation 6 2 3 1 Revenue 1 1 2 8 Operations 2 5 4 1 Compliance 4 4 3 1 Sample priority ranking by a previous Credit Union client. Does this look familiar? An over-focus on compliance may not support the objective of serving the member community.
  • 23. What are we protecting? … Our Members!
  • 25. SecurITy Direction Incident Management Business Continuity Technical SecurITy Compliance Access Control Physical SecurITy Operations SecurITy 3rd Party SecurITy Organization of SecurITy Human SecurITy Asset Management How do we protect it?
  • 26. How are we measuring what we’re doing? The Capability Maturity Model Integration (CMMI) will be used to measure our journey. Maturity Level Name Definition 0 Non-existent Complete lack of any recognizable processes. The enterprise has not even recognized that there is an issue to be addressed. 1 Initial / Ad Hoc There is evidence that the enterprise has recognized that the issues exist and need to be addressed. There are, however, no standardized processes; instead, there are ad hoc approaches that tend to be applied on an individual or case-by-case basis. The overall approach to management is disorganized. 2 Repeatable but Intuitive Processes have developed to the stage where similar procedures are followed by different people undertaking the same task. There is no formal training or communication of standard procedures, and responsibility is left to the individual. There is a high degree of reliance on the knowledge of individuals and, therefore, errors are likely. 3 Defined Process Procedures have been standardized and documented, and communicated through training. It is mandated that these processes should be followed; however, it is unlikely that deviations will be detected. The procedures themselves are not sophisticated but are the formalization of existing practices. 4 Managed and Measurable Management monitors and measures compliance with procedures and takes action where processes appear not to be working effectively. Processes are under constant improvement and provide good practice. Automation and tools are used in a limited or fragmented way. 5 Optimized Processes have been refined to a level of good practice, based on the results of continuous improvement and maturity modelling with other enterprises. IT is used in an integrated way to automate the workflow, providing tools to improve quality and effectiveness, making the enterprise quick to adapt.
  • 27. Incident Management Business Continuity Technical SecurITy Compliance Access Control Physical SecurITy SecurITy Direction Human SecurITy Sample Client: What are they doing now? Operations SecurITy
  • 28. Incident Management (2) Business Continuity (3) Technical SecurITy (1) Compliance (3) Access Control (3) Physical SecurITy (3) SecurITy Policies (1) Human SecurITy (2) Sample Client: How are well are they doing the things they are doing? Operations SecurITy (1)
  • 29. Incident Management Business Continuity Technical SecurITy Compliance Access Control Physical SecurITy SecurITy Direction Human SecurITy Sample Client: What’s the bigger picture? Operations SecurITy
  • 31. Scenario A: Breach Remediation Costs Total Number of records X $154 per record* Additional Impact • Reputational impact • Additional productivity impacts • Cost of remediation *Ponemon institute: average cost of breach remediation is $145 per record Example: 15,000 members X $154 per record* = $2,310,000
  • 32. Cyber Insurance: Incident Response Responsibilities Do you know which stages of the incident response process your company is responsible for handling vs. your insurance company? Do you have a written, tested and functional incident response process in place?
  • 33. Cyber Insurance: Internal Security Controls Did you know that your insurance provider can refuse to pay out if you aren’t taking preventative measures? Do you know all the cyber security program elements you are expected to have in place?
  • 34. Cyber Insurance: Payout and Expectations What are your policy’s max and average payouts? Does either one of those numbers cover the cost of the breach estimated earlier? Do you know what you are expected to provide and when to provide it when notifying your cyber insurance of a problem? Do you have these expectations built in to your company's internal processes? $$$
  • 35. Scenario B: Downtime due to system outage Productivity Costs $ amount per day in Salary costs Additional Impact • Reputational impact • Additional productivity impacts • Cost of remediation
  • 36. Scenario C: Malware outbreak Numbers and costs based on actual malware incidents at 150 employee financial firm in NY. Incident 1: Pre-SecurITy (June 2014) 100% of firm’s users affected Lost productivity totaled approx. 3,600 hours Approx. 145 hours combined (internal IT team and vendors) spent on clean-up Total outbreak cost: Approx. $325,000 Incident 2: Mid-SecurITy Implementation (June 2015) 5% of firm’s users affected Lost productivity totaled approx. 255 hours Approx. 96 hours combined (internal IT team and vendors) spent on clean-up Total outbreak cost: Approx. $25,000 Difference 95% 3,345 hours 49 hours $300,000
  • 38. Where should we start?
  • 39. Education: Target your weakest links ASAP! TEST Regularly test your employees to see how they behave! Run regular 3rd party Phishing & Social Engineering Testing to practice the real thing and see how they respond. Conduct a recurring Security Awareness Survey to measure the culture around security and gauge the level of employee knowledge. TEACH Provide interactive training on security that’s geared toward educating even the non-technical employees at your company. Use a variety of instructor-led and digital methods. Make sure your trainers are ready to teach employees WHY they should care and how to protect both themselves and the company. TRACK Measure your success and adjust accordingly. Track key metrics including participation. Use the methods in the TEST section to regularly benchmark where your employees fall and measure improvements in the results. Make adjustments and improvements over time to mature your education program.
  • 40. DIY Resources Beginner’s Guide to Data Classification SecurITy Checklist for Executives Project Initiation Form Template Risk Register Template