Back to Blog

Why Does Independence In Your Information Security Officer Matter?

By Finosec

May 19, 2022

Get notified on new insights from Finosec now!

Be the first to know about new Finosec blogs to grow your knowledge of the cybersecurity governance industry today!

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.

The FFIEC Information Security Handbook states: “Information security officers should report directly to the board or senior management and have sufficient authority, stature within the organization, knowledge, background, training, and independence to perform their assigned tasks. To ensure appropriate segregation of duties, the information security officers should be independent of the IT operations staff and should not report to IT operations management.” Obviously, the ISO should have knowledge and experience in these areas, but their authority and operations should be independent of the IT operations staff and management. This ensures that there is never any conflict of interest, and that the “responsibility for making changes and granting exceptions to policy [is] segregated from the enforcement of the controls.” However, in a smaller financial institution where staff wear multiple hats, this can be easier said than done.

Two Strategies

We often see two strategies when it comes to ensuring ISO independence at an institution.

  1. A team member who is intrinsically independent from IT staff is assigned the role of ISO. Therefore, it is often the case that this team member doesn’t have technology or cybersecurity expertise, resulting in a gap when it comes to implementing best practices. Also, this responsibility may very well fall to a senior level manager whose highest value activities for the institution as a whole are strategy and management, with time constraints naturally causing less emphasis to be placed on cybersecurity and information security practices.
  2. We also see the institution put processes in place to support and uphold the independence of the ISO with reporting and documentation, ensuring that independence is maintained and protected.

Tools and Support

Multiple FINOSEC team members were previously ISOs, and have felt the tension of maintaining that independence. Out of that tension and difficulty, they have created the Governance Automation Platform. This platform can help the ISO grow and simplify the steps for those who are still learning the ropes. Alternatively, even if the ISO is more seasoned and familiar with the difficulties, this platform can come alongside your institution and help you provide oversight reporting and documentation that empower you to master ISO independence as well as increase and validate your exam readiness.

Key Questions

Whether you are just getting started on this path or are reevaluating your effectiveness down the road, here are some key questions to ask:

  1. Is my ISO independent? Why or why not? How can we address this requirement?
  2. Do I have senior level staff members managing tasks in information security that are manual and time consuming? What tools or support do they need to address this?
  3. What reporting do we have to validate independence?

If you would like learn more about how FINOSEC can come alongside your institution to help increase and protect ISO independence, schedule a call by clicking the link below:

Schedule a Call

More from Finosec

The Best Defense Against Ransomware

The Best Defense Against Ransomware

Beth Sumner, our VP of Customer Success, recently had the opportunity to discuss ransomware attacks and the importance of community bankers staying vigilant against these crimes in Independent Banker.  While the number of ransomware attacks continues to increase, so do the sums demanded by the attackers.

Succession Planning: Essential for Sustaining Information Security

Succession Planning: Essential for Sustaining Information Security

In today’s world where cyber threats evolve rapidly, the challenge of replacing an Information Security Officer (ISO) underscores a critical issue: the cybersecurity job market is scorching, yet talent is scarce. This gap has turned recruitment into a high-stakes game for financial institutions, where the departure of an ISO exposes vulnerabilities and regulatory risks. With remote work expanding the competition for skilled professionals, the importance of strategic succession planning has never been more acute, ensuring that institutions remain fortified even in the face of staffing changes.

Partnering for Peace of Mind and Effective Oversight

Partnering for Peace of Mind and Effective Oversight

Pendleton Community Bank, a $700 Million Dollar Bank with 133 Employees in Franklin, WV, led by CEO Bill Loving, faced a critical challenge when their Information Security Officer departed, leaving a significant void in their oversight capabilities. Their goal was clear: establish an effective process for information security governance and cybersecurity oversight to ensure compliance and peace of mind.

Talk To An Expert Now
Talk To An Expert Now 770.268.2765