By: Mike Detrow, CISSP, Senior Consultant and Manager of IT
At small community banks, the IT Manager role was once, and in some cases still is, one of many hats worn by the President or CFO. However, this role is quickly evolving into a nearly full-time position even at smaller community banks. There are a number of factors that are contributing to this change, including increased use and sophistication of technology, increased regulatory scrutiny for cybersecurity, and the rapidly changing threat landscape.
It was not long ago that the IT Manager only needed to support a few internal servers and workstations. Over time, technology and customer expectations have evolved, leading to increased network complexity through the requirement for additional internal servers to support new services, the use of server virtualization, and connectivity to additional outside networks. In addition, the use of mobile technology has expanded dramatically leading to employees using mobile devices to access internal network resources, and banking services being provided to customers through their mobile devices.
The amount of time required to properly manage and monitor a bank’s information systems has increased dramatically. However, in many cases, community banks have not significantly increased the human resources assigned to the management of their IT environment. We have had numerous discussions with bank IT personnel indicating that they do not believe that they have enough time and resources to properly address the changing IT regulatory requirements and new cyber risks. While some community banks have outsourced the management of their network and other systems to a service provider, this does not relieve the bank of its role in the oversight of these systems. Additionally, outsourcing increases the time that the bank must spend to manage these vendor relationships.
Here are some of the areas where we have seen community banks spending additional time to perform IT and information security functions:
- Vendor Management. As the bank implements new services or engages service providers to manage existing services, additional time is required to monitor these vendors. Significant time is needed to obtain the required documentation from each vendor and to review and analyze this documentation.
- Threat Intelligence. Threat intelligence sources are monitored to identify threat sources and their current activities to identify and implement mitigating controls that will limit the potential impact of these activities on the bank. Significant time can be spent analyzing the data from threat intelligence sources to determine its applicability to the bank and to then implement or modify mitigating controls.
- Risk Assessment and Policy Maintenance. As the bank adds or changes technologies or services, risk assessments and policies must be created or updated to address their risks. In addition, risk assessments need to be updated periodically to ensure that the risks associated with new or changing threats are evaluated and mitigated. A cybersecurity assessment must be completed and reviewed periodically based on changes within the bank’s IT environment.
- Ongoing Employee Information Security Awareness Training. With most banks providing external email access and internet access to all of their employees, each employee has become a critical link in the security chain where the result of one employee clicking on a malicious link in an email can be an organization-wide catastrophe. Annual training is no longer adequate to keep employees apprised of current threats such as ransomware and phishing scenarios. A significant amount of time can be spent developing training materials and distributing them to employees on an ongoing basis.
- Event Management and Monitoring. Network devices, operating systems, and applications must be monitored to identify malicious activity. In the past, many banks were only monitoring perimeter devices such as firewalls and believing that the perimeter devices would stop any threats. However, many current attacks start with the installation of malicious code on an employee’s workstation to bypass the controls imposed by the firewall and then the attacker moves around, potentially undetected on the internal network. Monitoring for malicious activity on all of the bank’s internal network devices can require significant resources. Patch Management. Patch management is more than just patching Microsoft operating systems and applications such as Adobe Acrobat and Java. Patch management includes updating the software running on network devices such as firewalls, routers, switches, DVRs, and printers to address any known vulnerabilities. Additional time must be spent to identify the release of new patches, and in many cases the patches must be installed manually on each network device.
- Disaster Recovery / Business Continuity Planning and Testing. A bank’s increased dependence on technology requires formal documentation for maintaining business continuity and testing the selected plans to ensure that the bank can recover from a disaster within a reasonable time frame to allow for the continued performance of its daily functions. Additional time is required to initially document recovery strategies and then modify the strategies based on system or vendor changes. Time is also required to prepare testing strategies, coordinate testing schedules with vendors, and analyze the test results. Incident Response Planning and Testing. Many experts say that it is not a question of if a business will be hit by some form of breach, but a question of when it will happen. Banks must have a well-documented plan in place to detect and respond to an information security incident. In addition, the plan needs to be tested periodically to ensure that all employees are aware of their roles to effectively and efficiently respond to an incident.
Potential Costs of a Breach
Why should changes to the technology used by the bank, changes to regulatory requirements, and the evolving threat landscape be a significant concern for the board of directors? The board of directors is ultimately responsible for the management of the information security program, and failing to provide the appropriate resources to manage the IT and information security functions at the bank can lead to regulatory enforcement actions, harm to the bank’s reputation, and significant costs associated with a data breach.
According to the Ponemon Institute’s 2017 Cost of Data Breach Study: United States, performed June 2017, the average cost for each lost or stolen record containing sensitive and confidential information is $225. This study also indicated that breaches involving businesses within the financial services industry had a per capita cost of $336.
Another consideration for the board of directors is insurance coverage. While a bank may have a cyber insurance policy, management needs to thoroughly understand the requirements for this policy and ensure that it is meeting all of the minimum security requirements of the policy. Insurance companies may reject a claim or even seek repayment of a settlement if defined controls were not in place at the bank at the time of a breach.
Using the example of a community bank with assets of 100 million and 12,000 customer records, a breach of those 12,000 records could cost the bank 4 million dollars. This would be a substantial loss for the bank if insurance coverage is not appropriate, and even more significant if an insurance claim is denied due to the bank’s failure to maintain the minimum security requirements defined within the policy.
With the rapid changes in technology and the changing threat landscape, continuing education for the bank’s IT staff is also a critical consideration. A bank’s IT Manager must learn how to change the bank’s mitigation strategies to address evolving cyber threats rather than relying solely on the strategies that have been used in the past. There are numerous options for continuing education such as cybersecurity conferences sponsored by state banking associations and webinars.
Cybersecurity Assessment Tool Staffing Requirements
With the regulatory focus on cybersecurity, another illustration of the need to evaluate the human resources required to effectively manage the bank’s information systems can be found in the declarative statements within the staffing section of the FFIEC’s Cybersecurity Assessment Tool as shown below. Attainment of the baseline cybersecurity maturity level is required for all banks as this level identifies the minimum expectations required by law, regulations, or supervisory guidance. The declarative statements within the evolving cybersecurity maturity level will also need to be attained by small community banks as they increase their maturity level over time.
- Information security roles and responsibilities have been identified.
- Processes are in place to identify additional expertise needed to improve information security defenses.
- A formal process is used to identify cybersecurity tools and expertise that may be needed.
- Management with appropriate knowledge and experience leads the institution’s cybersecurity efforts.
- Staff with cybersecurity responsibilities have the requisite qualifications to perform the necessary tasks of the position.
- Employment candidates, contractors, and third parties are subject to background verification proportional to the confidentiality of the data accessed, business requirements, and acceptable risk.
In summary, the board of directors and senior management must carefully consider the resources required to appropriately manage its information systems based on the rapid technological, regulatory, and threat landscape changes. Strategic plans should consider the additional workload that will be created to support changes within the bank’s IT environment to achieve management’s strategic goals, and ensure that appropriate human resources are included within its plans.
For more information on this article or how Young & Associates, Inc. can assist you, contact me at 330.422.3447 or [email protected].