Published 22 Apr, 2024 7 minutes of reading
When it comes to cyberattacks and malicious actors, many of us fail to appreciate the scope and magnitude that financial institutions have to address. The latest Data Breach Investigation Report (2023 DBIR) from Verizon Business found that 9 out of every 10 data breaches are financially driven, positioning financial institutions as the primary targets for this type of attacks.
And for those malicious actors, it’s not only the monetary assets that attract them. It’s also the vast amount of data that FIs manage. Valuable Personally Identifiable Information (PII) and other customer data act as virtual gold mines, with attackers searching for any avenue of exploitation, whether through ransom demands or the illicit sale of information on the dark web.
There Are Good Systems for Protecting Valuable Information
This is where the importance of an Information Security Management System (ISMS) comes to the forefront. An ISMS is a set of elements designed to protect the confidentiality, availability, and integrity of a collection of data that, when combined and related, acquires meaning and may be otherwise used to take advantage of an organization and its customers.
For instance, someone knowing your full name by itself is not necessarily valuable for the purposes of exploitation. But if they have your name, a social identification number, your date of birth, and other information, that combined could be used to falsify your identity or worse.
Choosing the Right Framework(s)
As part of the data supply chain for many FIs and large organizations, at Modyo we’ve implemented an ISMS in accordance with international standards to protect the data of our clients and their customers.
As such, and along with our recent ISO27001 certification announcement, we want to take this opportunity to share with you some of the challenges and considerations that come along with the implementation of an effective ISMS.
When it comes to implementing an Information Security Management System (ISMS), the first crucial decision is selecting the appropriate framework. ISO/IEC 27001 stands out as a widely adopted standard, renowned for its comprehensive approach to information security. However, organizations should explore various options, such as NIST, COBIT, or industry-specific standards, to find the best fit.
This is because, contrary to common belief, there is no single framework that universally suits all organizations when it comes to security management. In fact, flexibility in your security management allows for the adoption of multiple frameworks, leveraging their equivalent and complementary components.
The key lies in choosing an ISMS that aligns with the organization's unique needs, considering internal and external contexts, strategic objectives, products, and services, as well as legal and regulatory landscapes.
A Security Framework Should Adapt to Your Organization, Not the Other Way Around
It's important to recognize that the ISMS should integrate into the organization's business reality. Rather than forcing the business to conform to a standard, the chosen framework should be adaptable, ensuring a harmonious alignment with the organization's structure, operations, and overarching goals. In essence, the ISMS becomes a tailored solution, dynamically molded to enhance the organization's information security position.
Implementing your own ISMS
Once a framework has been selected, it is important to have the commitment of leadership. This includes allocating human, technical, and financial resources to implement the ISMS efficiently.
Next, it is necessary to conduct a proper classification of information assets and determine the information security risks to which these assets are exposed. This involves identifying the areas and functions where there is a higher probability of risks materializing, as well as assessing the potential impact on the organization.
Setting Priorities & Assessing Value
There are various methodologies that assist in prioritizing information assets based on their value (which is not only financial) such as data classification, risk assessment, and business impact analysis. Data prioritization is crucial as it aligns efforts to protect the most valuable assets for the organization.
It helps when establishing action plans to address risks affecting these assets, and thus implementing appropriate controls, strategies, and security measures to reduce the probability or impact of identified risks. Since achieving a risk-free environment is unlikely, what is important is to define an acceptable level of risk for the organization, aligned with business objectives. In the security world, this is known as risk appetite.
Security Management Comes with Challenges
Implementing an ISMS comes with its own challenges. Some of the most common faced by large organizations range from audits to a shift in the culture itself:
Cultural Change: Implementing an ISMS involves a cultural shift, promoting a security mindset at all levels and ensuring every employee is aware of and embraces information security policies and procedures.
Technological Complexity: Integrating security technologies and controls can be complex, especially in organizations with an extensive and diverse technological infrastructure. This infrastructure may be distributed across On-Premise architectures, Public or Private Clouds, or even in "Multi-Cloud" environments, where protection strategies have similar objectives but need to be approached with different control strategies.
Regulatory Compliance: Complying with specific regulatory requirements can be a challenge, as regulations change and may vary depending on the industry and geographical location of the organization.
Vendor Evaluation: Evaluating and managing the security of vendors is a challenge, especially when dealing with third parties handling sensitive information located in different geographical areas.
Audits and Certification: Preparing for audits, including internal, external, and those from clients and stakeholders, demands meticulous documentation, alignment with industry standards, and proactive communication for successful navigation of the process complexities.
By committing to a systematic approach to these challenges, organizations can build and maintain an effective ISMS that protects both their own and their customer’s sensitive information and contributes to the long-term success of the organization.
Finally, once the selected strategies and controls are implemented, it’s important to verify their effectiveness, ensuring they meet the set objectives, and reviewing and adjusting as needed.
Maintaining your ISMS
Maintaining an ISMS based on a framework such as ISO 27001 involves a series of ongoing duties to ensure its effectiveness and compliance with established standards. Key activities include updating documentation, training, and more:
Review and Documentation Update: Periodically review and update the relevance of policies, procedures, guidelines, and other supporting documents of the system, based on changes in the organization, technology, or applicable regulations from stakeholders. Consider updating information asset records and risk assessments, as well as the effectiveness of selected controls and treatment plans.
Change Management: Evaluate and manage any significant changes in the organization, processes, or technology that may impact information security. It is also necessary to update the ISMS documentation to reflect changes and ensure continuous compliance.
Awareness and Training: Continue and keep awareness programs on information security active to keep employees informed about new threats and best security practices.
Monitoring and Measurement: Conduct regular internal audits to assess ISMS compliance and effectiveness. Measure ISMS performance based on established Key Performance Indicators (KPIs).
Incident Management: It is essential to update and refine incident response plans. Timely analysis of any security incidents is crucial, using lessons learned to enhance controls and processes.
Management Review and Evaluation: Conduct high-level management reviews to assess the effectiveness of the ISMS and identify improvement opportunities. Ensure that the ISMS remains aligned with the organization's strategic objectives.
Vendor Management: Periodically monitor the security of vendors and ensure they comply with established security requirements.
Legal and Regulatory Compliance: Establish activities and assign responsibilities for continuous monitoring of changes in legislation and regulations related to information security. This is essential to comply with new needs and requirements.
These tasks are essential to ensure that the ISMS remains robust, relevant, and effective over time, adapting to internal and external changes that may affect information security in the organization.
Managing System Maturity
Once you have an ISMS in place, it should change, and evolve over time with your organization. A maturity model of an ISMS serves as a guiding framework, enabling organizations to systematically assess and enhance their information security capabilities.
These models provide a structured path to measure the maturity of security processes and controls, enabling organizations to identify areas for improvement and set objectives to progress toward higher maturity levels.
It’s About Improving Over Time
One of the commonly used maturity models in the field of information security is the "Information Security Maturity Model" of Capability Maturity Model Integration (CMMI). While not exclusively designed for information security, it can be adapted to evaluate the maturity of security processes.
The levels in these models represent a continuum toward increased maturity in managing information security. Successfully implementing a maturity model offers organizations a clear roadmap to refine their security practices and fortify their ISMS over time. This progressive journey ensures a proactive response to evolving threats, demonstrating an unwavering commitment to robust information security practices.
Global Standards Also Change & Adapt
Security concerns are constantly evolving. Because of this, it is crucial to adapt to new vulnerabilities, threats, and risks to ensure the effectiveness of security management systems, best practices, and industry standards
An Example of Strengthening Governance & Resilience
For instance, ISO 27001 updated in 2022, leading certification bodies through the accreditation process to certify the new version. While this latest version maintains the structure of its predecessor (ISO 27001:2013), significant changes have been introduced in the classification and quantity of security controls.
Some have been added, some removed, and others merged, reducing the count from 114 controls in the 2013 version to 93 controls in the new 2022 version. This change addresses the continuously evolving security concerns with a focus on cybersecurity, threat intelligence, and cloud environments while also strengthening aspects such as governance and resilience.
An evolving security landscape means that having an effective ISMS requires constant improvement.
Our Ongoing Commitment to Information Security
At Modyo, security is our top priority. As part of our ongoing protection strategies for both ourselves and our clients, we have stringent measures, forged strategic alliances, and are continuously educating and training our team. Our Information Security Management System is both ISO/IEC 270001 certified and SOC 2 Type 2 compliant. This combination uniquely positions Modyo as a secure and trusted composable frontend platform, and solidifies our stance on cybersecurity. This is especially critical for financial organizations and large enterprises that operate in environments where data breaches can have significant repercussions, offering peace of mind to our valued partners and customers.
If you’re currently searching for a composable frontend platform that can help you build solutions for customer-facing web applications, digital onboarding, specific financial solutions, and more through critical digital channels that require robust security, reach out to us and let’s explore how the Modyo platform can help your organization build better solutions.
