Case Study: Regional Bank – Information Security Policy Enhancement

Case Study: Regional Bank – Information Security Policy Enhancement

Introduction: Current Issue

Regional Bank has been expanding aggressively through six smaller financial institution acquisitions within the last two years. Currently, the bank faces a serious challenge to its growth strategy. Federal Deposit Insurance Corporation regulators raised serious concerns regarding the information security policy as it was confusing, disjointed, and replete with inconsistencies. This has led the regulators to halt all future acquisitions until the bank addresses some of the issues. What is presented in this case study is how to update the information security policy at the bank to meet the regulator’s requests and how to continue with the bank’s strategic growth plan.

Discussion

How to Kick Off the Project

As part of the information security policy for this project, it first needs to be properly assessed. Such assessment should, of course, also focus on areas where the current policy is not very clear, badly organized, or contradictory. The gap analysis will enable one to understand specific areas where the practices deviate from best practices, regulatory requirements, and industry standards like ISO 27002:2013 and the NIST Cybersecurity Framework.

Uses of Material from the Original Document

The original document has been criticized, but it still needs to go through and see if there are any areas that could be retained either in their present form or after some amendment rather than being rejected wholesale. All existing text that is adequate to meet today’s regulatory environment and industry standards may be retained, but its clarity and consistency may be improved by editing.

Additional Materials to Be Requested

To ensure the revised policy is comprehensive, additional materials are needed for review, including but not limited to the following: audit reports, previous regulatory feedback, and records of security incidents. Such documents will add significant value in understanding the bank’s security posture and highlighting what needs improvement.

Interviewing the Stakeholders

The original policy author should be contacted to explain their intent behind the present structure and content of the policy. It will also be necessary to interview other stakeholders, such as IT security staff, compliance officers, and departmental heads from the acquired institutions, to solicit an even larger understanding of the bank’s security needs and challenges. Such input will prove of great importance in ensuring that the revised policy is practical, relevant, and in accord with the bank’s overall strategic objectives (Santos et al., 2019).

ISO Certification Consideration

Considering the growing business of the bank and the increased regulatory control over the same, it may be a strategic step to think about attaining ISO 27001 certification. ISO 27001 is a global information security management standard; hence, certification would show a commitment towards the bank’s objective of adhering to stringent safety measures. Sections that must be contained in the policy to attain ISO 27002:2013 conformance should include risk management, asset management, access control, incident response, and so on. These domains are relevant in helping the bank protect its information assets and fall in line with regulatory requirements.

Application of the NIST Cybersecurity Framework

Besides ISO standards, another constructive tool that can be adopted for integration into the policy revision process is the NIST Cybersecurity Framework. The NIST framework proposes the CIA triad of confidentiality, integrity, and availability as foundational elements of information security. This framework will be operationalized for policy development using NIST tools such as the risk management framework and the cybersecurity assessment tool to craft a robust policy attuned to bank-specific risks and security requirements (Standard, 2018).

Information Dissemination Methods

Effective communication becomes indispensable in implementing a policy. The information contained in the policy will be disseminated through email, the bank’s intranet, and meetings with employees. The different departments in the bank will also be provided with some training in their roles and responsibilities concerning the policy.

Other Criteria to Consider

Other critical factors about the policy on the bank’s side include the necessity for it to be aligned with the strategic goal, flexibility, considering future changes, and having an in-built process of making improvements time after time. Though this policy is not a rigid document, the nature of this policy would require it to be reviewed and scheduled for updates from time to time to keep up with the changing threats and requirements.

Conclusion

In these regards, the revision of Regional Bank’s information security policy is one of the critical initiatives that will help the bank continue its growth strategy and meet regulatory requirements. By ensuring adequate analysis, stakeholder involvement, conformance to ISO and NIST standards, and assurance of effective communication, the bank will be better placed to improve its information security posture and thus continue its expansion with confidence.

References

Santos, O. (2019). Developing cybersecurity programs and policies. Pearson IT Certification.

Standard, D. E. (2002). National Institute of Standards and Technology. Federal Information Processing Standard (FIPS) Publication, 46(1).

a:link {text-decoration: none;}a:visited {text-decoration: none;
}a:hover {text-decoration: underline;} a:active {text-decoration: underline;}

We’ll write everything from scratch

---

Refer to “Case Study: Policy Writing Approach” found on page 102 of your textbook and copied below.
Regional Bank has been growing rapidly. In the past two years, it has acquired six smaller financial institutions. The long-term strategic plan is for the bank to keep growing and to “go public” within the next three to five years. FDIC regulators have told management that they will not approve any additional acquisitions until the bank strengthens its information security program. The regulators commented that the Regional Bank’s information security policy is confusing, lacking in structure, and filled with discrepancies.
You have been tasked with fixing the problems with the policy document. Write a two-page case study that includes the following sections.

• Introduction: Current Problem
• Discussion
• Where do you begin this project?
• Would you use any material from the original document?
• What other materials should you request?
• Would you want to interview the author of the original policy?
• Who else would you interview? Should the bank work toward ISO certification?
• Which ISO 27002:2013 domains and sections would you include?
• Should you use NIST’s Cybersecurity Framework (CIA security model) and related tools? If yes, explain why the tools selected are important to IS policy writing.
• Which methods of communication should you use to send the policy?
• What other criteria should you consider?
• Conclusion
• References
Your paper should include a title page and a reference page, which do not count toward the two-page minimum. Use APA formatting. At a minimum, use your textbook as a resource for this assignment and include it on your reference page.

Last Completed Projects