Building a brand new Information Security Program from scratch for a regional bank
CISO
We wanted to ask Scoiel Sentinel – CISO GPT about building a new information security program for a small regional bank because the current ISP is broken and needs a new one built in parallel.
Full Article: https://cisomarketplace.com/cyber-sentinel-ciso-gpt
If i need to build a brand new Information Security Program from scratch, how should we implement the new program while also dismantling and upgrading the previous program? Corporate mindset and internal politics changing, increased budgeting, increased specialized staffing, increased technical rollout of IT and Security architecture and Engineering? We only have a CISO, a staff of 5 sharing IT and security, a small regional bank of 35 employees, 2 locations, and 1 could have hundreds of million in assets.
Response:
Building a new Information Security Program from scratch for a small regional bank while simultaneously dismantling and upgrading the existing setup is a complex but achievable task. With the right strategy, you can manage the transition smoothly. Here are key steps to guide the process, considering the organizational dynamics, budget increase, staffing, and technical rollout:
1. Assess Current State and Define Objectives
Conduct a Thorough Assessment: Evaluate the existing security program, including policies, procedures, technologies, and infrastructure.
Identify Gaps and Risks: Focus on areas that are outdated or non-compliant with industry standards like NIST or ISO 27001.
Set Clear Goals: Define what you want to achieve with the new program, aligning with the bankโs business objectives and regulatory requirements.
2. Gain Buy-In and Align with Corporate Mindset
Engage Leadership: Present the value of the new program to top management, emphasizing ROI, regulatory compliance, and risk mitigation.
Foster a Culture of Security Awareness: Conduct regular training and awareness sessions for all employees, highlighting their role in maintaining security.
3. Plan Budget and Resource Allocation
Budget Planning: Allocate funds for critical areas like staffing, technology upgrades, and training.
Justify Investments: Link budget requests to specific risks and regulatory requirements, demonstrating how investments protect assets and reduce potential losses.
4. Staffing and Specialization
Expand the Team: Hire specialized staff for key roles such as security analysts, compliance officers, and network security engineers.
Outsource as Needed: Consider managed security services for areas where in-house expertise is lacking.
5. Develop a Strategic Implementation Plan
Phased Rollout: Plan a phased approach to implement new technologies and processes without disrupting ongoing operations.
Prioritize Based on Risk: Focus initial efforts on high-risk areas and critical assets.
6. Update Policies and Procedures
Revise Security Policies: Update existing policies to reflect new technologies, threats, and business processes.
Develop Incident Response Plan: Ensure you have an effective plan for responding to security incidents.
7. Implement New Technologies and Infrastructure
Upgrade IT and Security Infrastructure: Introduce advanced security technologies like firewalls, intrusion detection systems, and secure cloud storage solutions.
Ensure Compliance: Align technology deployments with regulatory requirements specific to the banking sector.
8. Continuous Monitoring and Improvement
Implement Monitoring Tools: Use SIEM and other monitoring tools to continuously oversee network and system activities.
Regular Audits and Assessments: Conduct periodic security assessments to identify and remediate vulnerabilities.
9. Documentation and Compliance
Maintain Documentation: Keep detailed records of policies, procedures, and compliance measures.
Regular Reporting: Report to leadership on the status, incidents, and continuous improvement of the security program.
10. Foster External Collaboration
Engage with Industry Groups: Participate in banking and cybersecurity forums for the latest trends and threat intelligence.
Collaborate with Law Enforcement and Regulators: Establish relationships with relevant agencies for guidance and support.
11. Manage Internal Politics and Change
Effective Communication: Maintain open lines of communication across departments to manage expectations and address concerns.
Change Management: Implement change management strategies to smoothly transition to the new security program.
Remember, building a new Information Security Program is an iterative process. It requires continuous evaluation and adaptation to emerging threats, technological advancements, and business needs.