Pravin Kumar

Why cultivated BFSIs are moving from Cyber Defense to Cyber Resilience

Cyber threats like APT (Advance Persistence Threat), Malware, hacking, phishing, ransomware, and distributed denial-of-service (DDoS) attacks have the potential to cause enormous challenges for organizations. Not only can companies suffer serious service disruption and reputational damage, but the loss of personal data can also result in huge fines from regulators. Some experts define cyber defence as preventing hackers from attacking your network and accessing your systems and data. Cyber resilience, they may view it, is about responding and recovering after an attack has happened. While they position cyber defense and cyber resilience as two separate activities, the reality is more complex than that. Cyber security can be seen as the first step in cyber resilience meaning any cyber resilience strategy must encompass cyber security. This blog explains more: If we map these two strategies with NIST -CSF (Cyber Security Framework), Cyber Défense is limited to Identify, Detect and protect pillars, however, Cyber Resilience also touches other two pillars i.e. Respond and Recover. It should be clear by now that cyber security and cyber resilience are different but symbiotic. Some companies do still treat them as separate and inter-related solutions, often establishing cyber security and resilience policy frameworks and strategies. However, there is more value when cyber security forms an element of overall cyber resilience. Why Cyber resilience over cyber security? Cyber resilience starts with nailing the cyber security basics; at Wibmo, we call it “doing the common uncommonly well.” This includes regular risk assessment, patching vulnerabilities, detecting and mitigating threats, and awareness on how to defend company assets. But we need to be doing these things continuously, not just once a year. The aim of cyber resilience is clear enough: to ensure operational and business continuity with minimal impact. But the reality can be harder to pin down because there’s currently a no good way to measure cyber resilience. As leaders, we need to have a certain level of confidence in our ability to respond to an attack, to maintain our customers’ trust, absorb the financial, legal, and brand impact and get back to business. But there is no widely-accepted cyber resilience framework, no maturity model, and I think there should be. The four elements of cyber resilience: I recommend a four-part approach to cyber resilience: 1. Manage and protect The first element of a cyber resilience programme involves being able to identify, assess and manage the risks associated with network and information systems, including those across the supply chain. 2. Identify and detect The second element of a cyber resilience programme depends on continual monitoring of network and information systems to detect anomalies and potential cyber security incidents before they can cause any significant damage. 3. Respond and recover Implementing an incident response management programme and measures to ensure business continuity will help you continue to operate even if you have been hit by a cyberattack, and get back to business as usual as quickly and efficiently as possible. 4. Govern and assure The final element is to ensure that your programme is overseen from the top of the organisation and built into business as usual. Over time, it should align more and more closely with your wider business objectives. Benefits: A cyber-resilient posture helps you to: Reduce financial losses; Meet legal and regulatory requirements: Improve your culture and internal processes; and Protect your brand and reputation Author: Pravin Kumar, CISO Wibmo A PayU/Naspers FinTech Company Cyberattack, Cybercrime, Cybersafe, Cybersafety, Cybersecurity

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How did we make Wibmo GDPR ready in 6 months?

A brief about GDPR GDPR is the world’s most strictly enforced set of data protection rules, enhancing how people can access information about themselves and limiting what organizations can do with personal data. GDPR’s full text is a cumbersome beast with 99 individual articles. The regulation in the EU, which replaced the previous 1995 data protection directive, serves as a framework for laws across the continent. After more than four years of debate and negotiations, the GDPR’s final form was adopted by both the European Parliament and the European Council in April 2016. At the end of that month, the underlying regulation and directives were published. GDPR went into effect on May 25, 2018. Countries in Europe were given the ability to make minor changes to better suit their own needs. This adaptability resulted in the creation of the Data Protection Act (2018) in the United Kingdom, which replaced the previous Data Protection Act of 1998. Driver for GDPR Wibmo currently has a large presence in India, Asia, Middle East, and Africa. And we aspire to enter the European market with our flagship service offering such as Authentication solutions and Fraud Risk Management solutions. We foresee that with increasing dependency on technology and digital products, we can offer seamless services to the European market. Moreover, with the expansion of the European Union, the EU market seems to be more lucrative to capture a large clientele base with a common regulatory framework and processes. Journey to GDPR readiness We performed initial due diligence with regards to GDPR articles and realized that it falls under the category of “Data Processor” as the majority of Personally Identifiable Information (PII) are not captured by themselves. These PII are shared with us by our customers/banks (controller) to whom we provide services. Then we defined “Security and Privacy by Design” principles and implemented them across the organization. To make everyone aware of these principles, we also provided mandatory training to all our employees on this subject through the “OneTrust” training tool. We performed a check for applicability of GDPR Articles and prepared a Statement of Applicability (SOA) which listed the set of GDPR Articles applicable to it. As a next logical step, we engaged with a Big4 consulting firm to perform gap assessment vis-à-vis processor control requirements. The gap assessment covered below domains: 1. Governance and Operating Model 2. Legal and Regulatory 3. Data Privacy Policy 4. Data Management 5. Privacy by Design 6. Security for Privacy 7. Third-Party Management 8. Data Subject Access and Requests 9. Consent Management 10. Training and Awareness 11. Breach and Incident Management 12. Business Unit Processing Activity (BUPA) 13. Data Privacy Impact Assessment (DPIA) The identified gaps were categorized in the areas of People, Process, and Technology. Then we created several policies and processes with the help of the global privacy team to comply with GDPR articles. To name a few policies and processes — Cyber Security and Privacy Incident Process, Data Subject Request Handling process. We also defined Business Unit Processing Activity (BUPA) and Data Privacy Impact Assessment (DPIA) for applicable business processes. We also enhanced our systems following a robust Change Management process to address some of the technology-specific gaps. We organized several awareness sessions and training on Privacy and Security controls requirements to ensure that the entire company stands in unison with regards to GDPR expectations. We are very pleased to share that the identified gaps have been successfully remediated. The remediation evidence has been shared with consulting partners for independent verification and closure confirmation thereafter. In addition, we have established a dedicated team for enforcement, implementation, and ongoing support of the GDPR compliances. Finally, we got a much expected and long-awaited tagline that “Wibmo is a GDPR-ready organization”. This compliance would help our business team to attract customers based out of the EU region which will make us globally the number one authentication service provider. Lastly, we would like to extend a big thanks to all our customers, employees, vendors for their seamless support in this journey. Author: Pravin Kumar, CISO Wibmo A PayU/Naspers FinTech Company GDPR, GDPR Compliance, GDPR Training, Security

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