Cyber and Privacy is an area that is constantly changing. Technology evolves, threats become more sophisticated, and regulation is always developing. While that can make this area daunting to deal with, it doesn't have to lead to paralysis. Like with any dynamic area of regulation, having a structured strategy is key. At AB we like to break this area down into three stages: Preparation, Incident Response, and Maintenance.
Preparation and Prevention
Much like with your health, when it comes to your cyber security and management of personal data, prevention is always preferable to treatment.
There are a host of actions that companies can take before they ever have a problem. Every company has a cyber infrastructure (whether they know it or not), and small changes can make a big difference. This can range from standard reviews of your policies, cyber security controls and data arrangements, through to comprehensive Privacy Impact Assessments and incident response plans.
For a comprehensive approach, consider arranging a Cyber Health Check, or just reach out for a chat.
Incident Response
Cyber incidents can take many forms, ranging from the sensational to the mundane - but they tend to have one feature in common - when they happen, time is of the essence.
While cyber attacks are becoming more prevalent, from a regulatory perspective, privacy breaches can be just as problematic. While a ransomware attack can clearly be costly (and often preventable), accidental privacy breaches can show weaknesses in systems and processes that are often of more interest to a regulator.
No matter what the incident, outcomes will always be better if there is an established incident response plan already in place. Either way, however, the initial steps for any incident will be broadly similar:
- Establish initial containment;
- Determine the source and extent of the breach
- Ensure the system is secure;
- Determine if/what data was affected;
- Consider if the breach has regulatory implications;
- Prepare communications to clients;
- Prepare communications to regulators;
- Remediate.
There are two skill sets that are essential to managing incidents effectively: forensic and regulatory - and at AB we have both.
The overarching message is this: cyber incidents must be responded to quickly and by multi-disciplinary teams with experience in managing cyber incidents.
Maintenance and regulatory management
In an area where change is constant, ensuring your cyber infrastructure remains up to date is an ongoing challenge. As technology continues to evolve quickly, the regulatory environment is in a constant state of flux, and the market demands increasingly digitised products, services, and business practices.
From a business perspective, this means a constant stream of regulatory queries, client enquiries, and change projects - the 'day to day' of cyber and privacy.
This can be managed through a dedicated internal resource - and in fact many larger firms appoint a Privacy Officer, or a compliance staff member to manage these issues.
For those firms where that's not efficient, an external solution like our Outsourced Data Privacy Officer can be effective.
Wherever you may be positioned with respect to your cyber journey - feel free to reach out and we can move forward together.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
