Digital provisions and technology are commonplace in everyday life, creating an ocean of data shared across multiple networks, devices, and users. This information is housed in numerous data caches, accessible from various internet-facing nodes. Remote working and virtualized services have expanded this accessibility creating a demand for security and reporting requirements.
Now, SMBs and larger enterprises have a mandated responsibility to maintain open transparency about their data. What was once voluntary is now a requirement based on legislative and regulatory requirements, primarily shaped by the Cybersecurity Incident Reporting for Critical Infrastructure Act of 2022. This law requires companies to report the nature of a breach event after a cyberattack, with the goal of creating better strategies to counter future threat campaigns.
Therefore, any organization using data pools to conduct services, interact with clients, and otherwise manage online-facing production must account for these transparency mandates. The question is: how does one begin?
The reporting requirements
The SEC has three major areas to cover when discussing reporting requirements. Those areas are:
- Cyber incident reporting (Ex: malware and ransomware attacks)
- Cyber management and risk strategies
- Cyber and digital governance
Cyber Incident Reporting
Incident reporting relates to material events, where digital and IT assets have been directly impacted by a breach event. There are requirements for incident reports if it’s determined to be “material.”
Incidents must be reported on a Form 8-K within four business days of a material intrusion.
Cyber Management Risk Strategies
Mitigating damages means maintaining a comprehensive cybersecurity structure. In the context of transparency, a thorough explanation of your organization’s cybersecurity strategies, defense mechanisms, and IT security policy should be provided in a written, understandable format.
Plans to integrate cybersecurity infrastructure must also be included, if not already.
Digital and Cybersecurity Governance
Industries must expand and outline their governance strategies, from who manages oversight, board members, CISO leaders, and relevant IT/cybersecurity staff regarding key decision paths. This must also cover any and all experts who can explain the processes of IT and cybersecurity features of the enterprise.
If not already, these are the areas within your organization that require documentation. This transparency keeps you out of legislative hot water. Additionally, it looks good for your clients and investor base that need to know their data is vetted, safe, and secured by a thorough process.
There’s an increased concern over the defense and visibility of an organization’s network and how it’s protected (or is not). With regulatory demands, covering these three key areas is critical.
How you can prepare for new reporting requirements
Now that you understand what the requirements are for IT transparency, you need to execute a plan-of-action to bring it to life. It’s worth repeating, this is no longer suggestive or a “guideline.” Companies will need to comply with new reporting standards or risk facing regulatory penalties. Therefore, adopt a strategy in-line with CISA requirements and develop areas that need rigorous plans surrounding their transparency models.
The key challenge is the creation of an agile reporting structure that meets legislative requirements. CISO and leaders need to focus on expanding capacity to facilitate a streamlined reporting process. To do so, you need a comprehensive team of security experts and business leads working together to create a digestible, legible codex of their cybersecurity strategies and weaknesses.
If you need to, assembling a board to handle cybersecurity disclosure is the first step. Assembling a series of questions will help prepare a transparency policy.
What kind of questions should your board ask?
Do we have weaknesses in our current cybersecurity infrastructure that are not in line with SEC rules? What will we do to address those weaknesses?
What is our policy for handling questions related to breaches or cybersecurity policy? Do we have a team for this?
What weaknesses in our reporting need the most/least amount of work? What should we prioritize?
What are the biggest changes we need to make to our cyber risk management and policies?
Inquiries like these can spearhead an efficient restricting of transparency policies and help you get in line with compliance demands. They aren’t the only ones to ask, however, and you need to create questions that best work for your enterprise.
Actionable Information
IT and cybersecurity architecture is a challenging format to understand, therefore, once you’ve developed a transparency policy, it should be presented to management and board leads in an understandable fashion. In other words, translate your architecture into a legible document for non-specialists. This allows management to develop and act on plans to bring them in line with transparency and reporting requirements.
Moving forward
With transparency requirements a law of digital information, it’s important to stay ahead of the curve and maintain compliance with actionable teams and methods.
If you’re struggling or concerned about meeting transparency deadlines, you can always get help. Reach out to Bytagig today for more information.
