RFG Perspective: While corporate boards grapple with cybersecurity issues and attempt to shore up their defenses, the inclusion of cloud computing models into the equation are increasing the risk exposure levels. Business and IT executives should work together to aggressively establish processes, procedures, and technology that will minimize the risk exposures to levels deemed acceptable. Additionally, senior executives and Boards of Directors need to play a more active roll in the accountability and governance of cybersecurity by discussing and addressing challenges, issues and status at least quarterly.
An article on the front page of the Wall Street Journal on June 30, 2014 discussed corporate boards racing to shore up cybersecurity. It alluded to a number of corporate boards waking up to cyber threats and worrying that hackers would steal company know-how and intellectual property (IP). In the first half of 2014 1,517 NYSE- or NASDAQ-traded companies listed in their securities filings references to some form of cyber attack or data breach – almost a 20 percent increase from the previous year. In all of 2013 1,288 such filing comments were made whereas in 2012 only 879 companies reported cyber statements. This is good and bad news – good that cybersecurity is getting CEO and Board attention and bad news in that executives are belatedly waking up to an endemic problem.
The Board and CEO have a fiduciary responsibility to shareholders to protect the company's assets from undue risks. It is not something that can be assigned and then ignored. Yet that is what has happened at many companies over the years. They must be involved in cybersecurity governance and decision-making on an ongoing basis and not shunt it off to Chief Risk Officers (CROs), Chief Security Officers (CSOs or CISOs) and/or IT executives. CEOs and other senior executives should also ensure privacy and security programs are aligned with each business unit's requirements and that the risk probability and exposures are reasonably known and reduced to an acceptable level. It is important that all parties understand that zero security risks are not possible anymore (nor would the expense be worth it if attainable); what is important is to agree upon what level of risk exposure is acceptable, budget for it, and implement initiatives to make it happen.
At the Board level there should be a risk committee that is responsible for all risk management, including cyber risk. Moreover, best practices suggest Boards should, as a minimum, address the following five areas:
- regularly reviews and approves top-level policies on privacy and IT security risks
- regularly reviews and approves roles and responsibilities of lead personnel responsible for privacy and IT security
- regularly reviews and approves annual budgets for privacy and IT security programs separate from IT budgets
- regularly reviews and approves cyber insurance coverage
- regularly receives and acts upon reports from senior management regarding privacy and IT security risk exposures.
These efforts can be done by the full Board or by a risk committee that reports to the Board. Some Boards may have assigned this role to the audit committee but, while it is good that it is addressed, it is not a perfect fit.
Cloud Multiplier Effect
In June the Ponemon Institute LLC published a report on the cloud multiplier effect. The firm surveyed 613 IT and IT security practitioners in the U.S. that are familiar with their companies' usage of cloud services. The news is not good. Because most respondents believe cloud security is an oxymoron and certain cloud services can result in greater exposures and more costly breaches, the use of cloud services multiplies the breach costs by a factor between 1.38 and 2.25. The top two impacts are from cloud breaches involving high value IP and the backup and storage of sensitive or confidential information, respectively. Most respondents believe corporate IT organizations are not properly vetting cloud platforms for security, are not proactively assessing information to ensure sensitive or confidential information is not in the cloud, and are not vigilant on cloud audits or assessments.
Moreover, disturbingly, almost 75 percent of respondents believe their cloud services providers would not notify them immediately if they had a data breach involving the loss or theft of IP or business confidential information. Almost two-thirds of those surveyed expressed concern that their cloud service providers are not in full compliance with privacy and data protection laws – and this is in the U.S. where the rules are less strict than the EU. Furthermore, respondents feel there is a lack of visibility into the cloud as it relates to applications, data, devices, and usage.
Boards, CEOs and senior non-IT management need to become more aware of their cybersecurity exposures and actively participate in minimizing the risks. IT executives, on the other hand, need to present the challenges, status and trends in a more business, less technical manner, including recommendations, so that the other executives can appreciate the issues and authorize the appropriate actions. As the Ponemon study shows, the challenges go beyond the corporate four walls into clouds they have no control over. IT executives need to become involved in the selection and vetting of cloud services providers. Furthermore, business and IT executives must work together and build strong governance practices to minimize cybersecurity risks.
RFG POV: Cybersecurity risk exposures are increasing and collectively executives are falling short in their fiduciary responsibilities to protect company assets. Boards, CEOs and other senior executives must take their accountability seriously and play a more aggressive role in ensuring the risk exposures to corporate assets are known and within acceptable levels. For most organizations this will be a major cultural change and challenge and will require IT executives to proactively step forward to make it happen. IT executives should collaborate with board members, senior executives, and outside compliance services providers to establish a program that will enable executives to establish a governance methodology that monitors and reports on the risks and provides cost/benefit analyses of alternative corrective actions. Moreover, at a minimum, corporate executives must review the governance materials quarterly, and after critical risk events occur, and take appropriate actions.