
A Shield of Defensibility Protecting CISOs and Their Companies
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In todays rapidly evolving regulatory landscape, CISOs are facing unprecedented challenges and scrutiny. From the SECs materiality rules to high-profile legal cases, such as SolarWinds and Clorox, CISOs increasingly face personal and professional risks related to perceived cybersecurity failures. Recently, Proofpoint surveyed 1,600 CISOs worldwide to get a pulse on how CISOs are navigating these challenges, finding that 66% are concerned about personal, financial, and legal liability in their role. Additionally, 72% indicated that they wouldnt join an organization that didnt offer them directors and officersinsurance or similar coverage to protect them against financial liability in the event of a successful cyberattack. Given these reasonable concerns, how can CISOs build a shield of defensibility to protect themselves and their organizations?Creating a System of RecordThe first critical step is for CISOs to build and maintain a comprehensive management system of record that meticulously documents key cybersecurity decisions, actions, and assessments.Begin by defining the scope and objectives of the management system, including the types of cybersecurity decisions, actions, and assessments to document, which regulatory requirements and industry standards the organization must adhere to, and the key stakeholders and their roles in the system.Related:CISOs may choose to store this system of record in a governance, risk, and compliance tool, a document management system, or a custom solution tailored to the organizations specific needs. In any case, the solution must document specific actions, decisions, and assessments, and include version control mechanisms to track changes over time, creating an audit trail that shows what changed, when, and why.Fulfilling the Duty of CareCISOs can demonstrate that they have fulfilled their duty of care by implementing a cybersecurity program that aligns with industry frameworks, such as the National Institute of Standards and Technology (NIST) Cybersecurity Framework (CSF) or the International Organization for Standardization (ISO) 27001 to establish a structured approach for identifying and addressing risks. CISOs must also conduct regular risk assessments and vulnerability scans to identify and mitigate security gaps and work to ensure their teams develop, document, and maintain robust security policies, procedures, and controls. These policies, procedures, and controls may be integrated into ongoing cybersecurity awareness training to ensure a broader understanding of business risks, including those related to human errors.Related:In addition to continuously assessing the effectiveness of controls and overall security posture, the CISO and their security team must stay up to date with relevant compliance requirements and meet or exceed them. The recent SEC requirements requiring disclosure of material cybersecurity incidents within four days of determining that the cybersecurity incident is material further highlight the need for CISOs to implement incident response and business continuity plans. As threat actors swiftly shift tactics and techniques, security teams must regularly test and update these plans in order to be able to report quickly and accurately on the materiality of such incidents.Communicating Cyber DecisionsCyber incidents are increasingly disrupting business operations, driving CISOs and other cybersecurity leaders to communicate cyber risks, mitigation strategies, and resource needs with other executives and the board of directors. Instead of focusing on technical details of breach prevention and different threat models, CISOs must now communicate cyber risk in terms of business objectives and impact. Provide clear, regular updates to establish ongoing communication about the cybersecurity program and how it enables the organization as a whole to meet its business goals. Use real-world scenarios to test cyber resilience and communicate those results as a way to make abstract risks more tangible and relatable to stakeholders. This approach facilitates informed decision-making and enables them to discuss pros, cons, and recommended courses of action.Related:By employing these strategies, CISOs can ensure executives and board members have the necessary business context to understand and support cybersecurity decisions, both in day-to-day operations and during critical cybersecurity incidents. By framing cybersecurity initiatives and risks in terms of how they align with and support overall business goals, security leadership can more effectively communicate the reasons for different cyber decisions and ensure that the board understands business risks as they relate to cybersecurity threats.A Three-Layer Shield of DefensibilityIn an era of regulatory upheaval and increasingly sophisticated threat actors, many CISOs are held accountable for cybersecurity incidents that have materially impacted -- or are likely to impact -- their organizations strategy, operations, or financial stability. While the SEC rule applies primarily to public companies, every CISO feels the pressure to protect both their careers and their organizations.Building a strong shield of defensibility, inclusive of the three layers below, collectively protect the CISO and the organization they serve:A system of record that thoroughly documents all cybersecurity effortsA comprehensive cybersecurity program that aligns with industry frameworksA strong communication plan on how cyber risks translate into business objectives and impactsBy fostering a culture of security, responding quickly and accurately during crises, and strategically communicating about cyber risks to the business, this cohesive approach fortifies both CISOs and organizations against cyber threats and regulatory scrutiny.
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