Written cyber security and response plans: Just do it
Despite the rising threat, recent survey results show a surprisingly small number of agents are prepared, as most do not have a written cyber security and response plan.
A cyberattack is a malicious and deliberate attempt by and individual or an organization to breach the information system of another individual or company, seeking benefit from the disruption, ransom, or theft of data – and such attacks are increasing in numbers and complexity.
Despite the rising threat, recent survey results show a surprisingly small number of agents are prepared, as most do not have a written cyber security and response plan.
A written cyber security and response plan is essential to be prepared, organized and to execute appropriate and prompt actions when an attack occurs.
The plan does not need to be complex. To be effective, it should be simple and clear and present key information. It should also be built commensurate with the size of the organization.
Key elements of the plan must include:
- Perform a risk analysis to mitigate all risks, covering administrative, technical, and physical controls. Simply put, this is what could be vulnerable, what could go wrong and what is or should be done to try to avoid or contain the threat(s).
- The cybersecurity program must protect the security and confidentiality of nonpublic information, protect against threats or hazards to the security or integrity of information, and protect against unauthorized access.
- Define a schedule for the retention of data and a mechanism for its secure destruction when data is no longer required.
- Designate an individual, third party, or affiliate who is responsible for the information security program.
- Be sure existing controls in place – access controls, authentication controls, and physical controls to prevent access to nonpublic information. Encryption (or an alternative, equivalent measure) should be in place to secure data stored on portable electronic devices and for data transmitted over an external network.
- Identify and manage devices that connect to the network – a simple inventory.
- Adopt secure development practices for in-house applications if applicable. Alternatively, obtain this assurance from your service provider that performs the development for you.
- Use multi-factor authentication to prevent unauthorized accessing of nonpublic information.
- Regularly test and monitor systems for actual and attempted attacks, maintain audit trails, and implement measures to prevent the unauthorized destruction or loss of nonpublic information.
- Keep up-to-date on emerging threats and vulnerabilities and provide ongoing training to employees to be sure they understand existing controls and why they are important; employees must know how to recognize and report threats.
The response plan must include the following elements to be effective:
- Date of the cybersecurity event.
- A description of how the information was exposed, lost, stolen, or breached, including the specific roles and responsibilities of third-party service providers, if any.
- How the cybersecurity event was discovered.
- Whether any lost, stolen, or breached information has been recovered and if so, how this was done.
- The identity of the source of the cybersecurity event.
- Whether you filed a police report or notified any regulatory, governmental or law enforcement agency and, if so, when such notification was provided and by whom.
- A description of the specific types of information acquired without authorization, which means particular data elements including, for example, types of financial information, or types of information allowing identification of the consumer.
- Time period during which the information system was compromised by the cybersecurity event.
- The number of total consumers affected by the cybersecurity event, or a best estimate.
- The results of any internal review identifying a lapse in either automated controls or internal procedures, or confirming that all automated controls or internal procedures were followed.
- A description of efforts being
undertaken to remediate the situation which permitted the cybersecurity event
to occur.
Don’t wait until an event occurs. It’s a chaotic time full of financial and emotional high stress. Do it now and provide yourself the peace of knowing you are prepared.
Tags: ALTA, ALTA Wire Fraud Survey Series, cybersecurity, escrow fraud, escrow security, wire fraud