In a video released to FINOSEC Academy, Co-Founder and CEO, Zach Duke, poses some questions around the processes you currently have in place at your institution. Regardless of which department you think of first, it is likely that some outdated processes are still in place, and your information security and cyber security teams are no exception.
Understanding examiner expectations and knowing how to train your team and board on information security is important. You and your team need to know where the risks are and where regulators are focused based on those risks.
It’s vital for you to fully understand the information security management systems you have in place
But it’s a nuisance to keep track of them all. First, you need to know the status of every component, especially for the systems you outsourced. Then, you must also understand the different kinds of information the systems store, how it’s stored, how data is transmitted, and what kinds of information is transmitted.
ISO Independence
A vital component of your information security program is an information security officer that is independent and adhering to appropriate segregation of duties as outlined by regulatory expectations.
And let’s acknowledge the tests associated with bank examiners definitely fall into the “not fun” category.
Have you addressed the Computer-Security Incident Notification Requirements for Banking Organizations? Full compliance has been extended to May 1, 2022. Five questions to ask:
In a technology driven industry, it is easy to assume that most of the decisions made around your cybersecurity posture are related to tools and software. While that may be the case a majority of the time, FINOSEC President and CEO Zach Duke also raises some questions and awareness around the impact of staffing on your cybersecurity and information security environment. In the video below, Zach poses questions around ISO independence, support infrastructure, and how to navigate staffing limitations. Watch the video and come back after the break for further discussion.
It is understood and expected that auditors and examiners will ask financial institutions about the safeguards, controls, and tools in place that drive and strengthen their cybersecurity governance. But as FINOSEC President and CEO Zach Duke describes in today’s video, they will also be looking for additional components. The industry is seeing expectations to describe the nuances of what questions and processes were present in cyber related strategic decisions, a concept called “credible challenge.” Auditors and examiners are looking for validation that the Board and other executive leadership members are asking solid questions and demonstrate compelling processes in making decisions around cybersecurity. Watch the video from Zach below and come back after the break for further discussion.
The practice of user access reporting within financial institutions has historically been an arduous process that relies on archaic technology and is both time and labor intensive. While generating multiple user access reports per year would be ideal, many financial institutions, through no fault of their own, often find they can only produce the bare minimum amount of reporting required annually. But as cyber risks continue to grow and the regulatory requirements continue to increase, it is vital that financial institutions can quickly and easily produce these reports, and with increased frequency.
