Julia McCarron reflects on the news that regulators are almost at the point of requiring major financial services companies to participate in a cyber security testing programme, according to the Bank of England.
It was nice to see the Bank of England talking about cyber security recently, and the importance it sees in testing awareness and resilience amongst the financial sector.
In May 2015, the CBEST scheme for firms and FMIs considered core to the UK financial system, was launched to test the extent to which they are vulnerable to cyber attacks and to improve understanding of how these attacks could undermine UK financial stability.
The scheme is currently voluntary and testing services are delivered by an approved list of providers regulated by CREST, a not for profit organisation that represents the technical information security industry.
The voluntary aspect of this is arguably what could make, what appears on the face of it to be a worthwhile initiative, ultimately unsuccessful. That said vulnerability scanning, assessments and penetration testing should frankly already be part of a financial institutions make up. So, if it’s not, the Bank of England is right be “expressing concern”.
The most interesting element of the Bank of England’s discussions though was that when talking cyber security they acknowledged that it’s not all about technical controls. I quote in respect of them keeping their own house in security order,
“Technical controls put in place had strengthened the Bank’s ability to prevent, detect and respond to attacks. But no technical fix could guarantee security 100%, so at the same time significant effort had been made to improve security awareness among all staff, and incident handling procedures had been strengthened“.
This is something we have evangelised about for years. Technical controls are not the answer. They are only part of the answer. We all know that the majority of security beaches are caused by staff, mostly unintentionally, due to lack of security awareness and training. It’s all very well having a state of the art lock on the front door but if no one knows how to use it what is the point in it being there? You might as well invite the burglar in for a cup of tea and a slice of cake.
The Bank also jumped on the Advent band wagon by mentioning that regulators have been discussing the importance of cyber security being a board room issue for companies particularly in relation to governance. Again, check our archives. We’ve worn down the drum from beating that point so hard and for so long. A security culture will only be successful if it’s supported from the top down. Otherwise it’s a constant uphill walk on the down escalator.
One initiative the Bank took to improve security awareness is one which is growing in popularity, especially amongst large organisations and data centres – ‘Phishing Attack Testing’. This is where a fake phishing email is sent to staff and monitored a) as to how many times its opened, b) as to how many times its reported c) as to how many times the link is clicked and by whom. This helps to raise awareness of the issues of suspicious emails and target staff training. The Bank claims it is personally seeing a decline in staff “taking the bait” and an increase in security incident reporting. A report by Verizon in 2014 stated that as many as 18% of users will visit a link in a phishing email which could compromise their data. This against a backdrop of phishing being not only on the rise but getting more sophisticated in its presentation. So more should follow in the Bank of England’s footsteps when it comes to raising awareness against this type of attack.
- Technical vulnerability testing is encouraged;
- It’s not all about the technical controls; don’t forget to train you staff;
- A security culture must start in the boardroom;
- Make staff aware of the perils of phishing emails through fake attack testing.