By Mike Detrow, CISSP, Director of IT & IT Audit, and Noah Lennon, CISA, Consultant, Young & Associates
Emerging trends in technologies, such as cloud computing and artificial intelligence, have significantly increased the complexity of the IT environments at community financial institutions. This has led to heightened regulatory requirements and demands for increased compliance efforts from an already stressed internal staff. Even the most skilled internal staff may find it challenging to manage the increased workload of managing the information security program, IT audits, and regulatory risk, which can lead to repercussions from regulators or security incidents.
For many, the need for dedicated information security management is abundantly clear, but affording and finding dedicated professionals in their communities is not an easy task. While you may already be using the services of a managed services provider (MSP) that may provide some support in this area, most MSPs are focused on IT infrastructure rather than information security programs. Virtual Chief Information Security Officers (vCISOs) are growing in popularity as a solution to this problem as they offer numerous benefits over a dedicated ISO, which are not only limited to cost savings.
Key Benefits of vCISO Services for Financial Institutions
Some of the benefits that a vCISO can provide include:
Document Templates
vCISOs maintain templates for documents such as policies, incident response plans, business continuity and disaster recovery plans, or can simply provide recommendations for enhancements of existing documents. Additionally, vCISOs have exposure to a breadth of policies across the many clients using their services, which allows constant improvements to the financial institution’s own policies and documentation.
Audit/Exam Preparation
vCISOs can help financial institutions prepare for an audit or exam by making sure that documentation is kept up to date and can help with the documentation gathering process to make sure it is well organized when it is provided to the regulator or auditor. vCISOs are also aware of recent audit/exam findings received by other clients and can help prevent your financial institution from receiving these same findings by addressing the identified issues prior to your next audit/exam.
Routine Tasks
vCISOs are aware of the activities that need to be completed each year and can skillfully lead them. These activities include vendor reviews, user access reviews, employee and board training, policy revisions and approvals, strategic planning, end of life monitoring, IT steering committee meetings, and more.
Security Monitoring
vCISOs can help to verify that appropriate security controls are implemented for the financial institution’s information systems, ensure that appropriate logging is configured, and help to monitor logs and alerts to detect and investigate security events.
Vendor Contacts
vCISOs work with a variety of vendors in the financial industry and can attest to their quality of work, which can assist the financial institution in choosing quality service providers. Leveraging existing rapport between the vCISO and service providers enables smoother transitions between vendors and clarity in the expectations for the relationship.
Plan Testing Exercises
vCISOs routinely help their clients perform business continuity and incident response tests, so they have testing scripts already developed to help make the testing process more efficient and productive. vCISOs can also help to ensure that these tests are appropriately documented for regulatory compliance and board reporting.
Incident Response
vCISOs may have experience in responding to incidents that their other clients have experienced. This knowledge can be used to implement controls that will help to prevent an incident at your financial institution or respond more efficiently should you experience an incident.
Selecting the Right Virtual CISO
So now that you are considering the idea of hiring a vCISO, how do you know what to look for? To help with this process, we have identified some of the criteria that you should consider when selecting a vCISO.
Industry Expertise and Regulatory Understanding
One of the first characteristics to look for is a partner that focuses exclusively on financial institutions, or at a minimum has a division with this focus and understands the specific regulatory requirements from the FFIEC and your specific regulatory agency. While some firms may claim to cover all industries, there are differences in the regulatory requirements for various industries and you need a partner that truly understands the requirements that you must meet. In addition, while there may be many similarities that are shared by financial institutions, there are also differences in available local providers, customer demands, regulators, technology, and complexity, so you need to make sure that your partner has the flexibility to customize their processes and deliverables to your specific needs.
Proactive Approach and Value Addition
A vCISO should also provide value by regularly introducing new ideas to enhance the information security program, strengthen the security culture, and improve efficiency in routine processes. You should not need to continuously ask your partner for recommendations for improvements.
Integrated Documentation Systems
Another consideration is the process used by the vCISO to maintain documentation. While some smaller and less complex institutions may do okay with multiple standalone documents and spreadsheets, having an integrated system that is used to share data for various purposes such as the information security risk assessment, vendor risk assessment, and business continuity plan may save time and ultimately money as well as limit the potential for errors as data is updated.
Maintaining Service Quality
One potential concern with using a vCISO is that unlike an CISO employed by the financial institution, vCISOs have multiple clients and may be less loyal to your financial institution than a full-time employee. To avoid potential issues associated with this type of relationship, just like any other vendor, you must perform appropriate due diligence and continuously monitor your vCISO to ensure that they are providing an acceptable level of service for your institution.
The Strategic Value of Virtual CISO Services
In closing, not only can vCISOs help financial institutions meet regulatory and technological goals without the costs associated with a full-time employee, they also bring a broad range of prior experience from working with multiple financial institutions. If you are struggling to stay on top of increasing technologies and related regulations, a vCISO can be an invaluable resource in ensuring your financial institution is successful.
Your Trusted IT Consulting Partner
At Young & Associates, we understand the unique needs and challenges faced by financial institutions. Our IT consulting services are tailored to help you navigate the complexities of technology solutions while ensuring regulatory compliance and information security. Contact us today to learn more about how we can support your institution’s IT needs.
