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NIS2: 3.Establish a cybersecurity framework

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We wrote here https://www.sorinmustaca.com/how-to-nis2-eu-directive/ that the 3rd  step in implementing the requirements of the directive is to establish a cybersecurity framework.

If you haven’t read what a cybersecurity framework means, then you should read article: https://www.sorinmustaca.com/demystifying-cybersecurity-terms-policy-standard-procedure-controls-framework/ .

 

Establishing a cybersecurity framework is critically important for organizations of all sizes and types because it is the basis on which you build your cybersecurity. The cybersecurity framework is the basis of the ISMS, which represents the plan of your cybersecurity strategy.

 

Why it is essential to have a cybersecurity framework

In case you still wonder if you need a cybersecurity framework, here are several key reasons why it is essential:

  1. Protection against Cyber Threats
    Cyber threats are constantly evolving and becoming more sophisticated. A cybersecurity framework provides a structured approach to identifying and mitigating these threats, reducing the risk of data breaches, cyberattacks, and other security incidents.
  2. Risk Management
    Cybersecurity frameworks help organizations assess their cybersecurity risks and prioritize their efforts to address the most critical vulnerabilities. This risk-based approach ensures that resources are allocated where they are needed most.
  3. Compliance and Legal Requirements
    Many industries and regions have specific cybersecurity regulations and legal requirements that organizations must adhere to. A cybersecurity framework provides a roadmap for meeting these compliance obligations, reducing the risk of fines and legal repercussions.
  4. Business Continuity
    Cybersecurity incidents can disrupt business operations, leading to downtime, financial losses, and damage to reputation. A well-structured cybersecurity framework helps organizations prepare for and respond to incidents, minimizing their impact and ensuring business continuity.
  5. Protection of Sensitive Data
    Organizations store vast amounts of sensitive and confidential data, including customer information, financial records, and intellectual property. A cybersecurity framework helps safeguard this data from unauthorized access or theft.
  6. Preservation of Reputation
    A security breach can seriously damage an organization’s reputation and erode customer trust. Implementing a cybersecurity framework demonstrates a commitment to security, which can enhance the organization’s reputation and instill confidence among customers, partners, and stakeholders.
  7. Cost Savings
    Proactively addressing cybersecurity through a framework can ultimately save an organization money. Preventing security incidents is more cost-effective than dealing with the aftermath of a breach, which can involve significant financial and legal expenses.
  8. Consistency and Standardization
    Cybersecurity frameworks promote consistency and standardization of security practices across an organization. This is especially important in larger enterprises with multiple locations, business units, or teams, ensuring that security measures are applied uniformly.
  9. Continuous Improvement
    Cyber threats and technology evolve rapidly. A cybersecurity framework emphasizes the importance of ongoing monitoring, assessment, and improvement, helping organizations stay ahead of emerging threats and vulnerabilities.
  10. Competitive Advantage
    Having a robust cybersecurity framework can be a competitive advantage. It can differentiate an organization in the eyes of customers, partners, and investors who prioritize security when choosing business partners.

Steps to Choose or Create a Cybersecurity Framework

Choosing a cybersecurity framework is a tedious process and potentially long. If you want to succeed, then you need to plan for it. In order to create a project plan, follow these milestones:

  1. Assess Organizational Needs and Objectives
    Begin by understanding your organization’s specific cybersecurity needs, objectives, and goals. Consider the industry you operate in, the types of data you handle, and your organization’s size and complexity.
  2. Identify Relevant Regulations and Standards
    Determine which cybersecurity regulations, standards, and compliance requirements are applicable to your organization. These may include GDPR, HIPAA, ISO 27001, NIST, CIS Controls, TISAX, ISO 21434 and industry-specific regulations.
  3. Conduct a Risk Assessment
    Perform a comprehensive risk assessment to identify potential cybersecurity threats, vulnerabilities, and the potential impact of security incidents. This assessment will help you prioritize security measures.
  4. Define Your Scope
    Clearly define the scope of your cybersecurity efforts. Consider which systems, data, and assets are in scope for protection and compliance efforts. Document this scope in detail.
  5. Research Existing Frameworks
    Investigate existing cybersecurity frameworks and standards that align with your organization’s needs and objectives. Consider well-established frameworks like NIST Cybersecurity Framework, ISO 27001, CIS Controls, and others.
    Have a look here to view a comparison. Consider country-specific frameworks like the recommendations or requirements from your country’s information security agency.
  6. Evaluate Framework Alignment
    Evaluate how closely each candidate framework aligns with your organization’s requirements, risk assessment findings, and compliance obligations. Consider factors like ease of implementation and ongoing maintenance.
  7. Customization vs. Adoption
    Decide whether to adopt an existing framework as-is or customize it to fit your organization’s specific needs. Customization may be necessary to address unique risks or industry-specific requirements.
  8. Engage Stakeholders
    Involve key stakeholders, including senior leadership, IT teams, compliance experts, and legal advisors, in the decision-making process. Ensure their input and buy-in throughout the framework selection or development process.
  9. Develop Framework Documentation
    If you choose to customize or create a framework, develop comprehensive documentation that outlines the framework’s policies, procedures, controls, and guidelines. This documentation serves as a roadmap for the implementation of the ISMS.
  10. Implement and Test
    Begin implementing the selected or customized framework within your organization. Test its effectiveness in addressing cybersecurity risks and compliance requirements.
  11. Training and Awareness
    Train employees and raise awareness about the cybersecurity framework, its policies, and best practices. Ensure that everyone in the organization understands their role in maintaining security.
  12. Continuous Monitoring and Improvement
    Establish ongoing monitoring and assessment processes to ensure the framework’s effectiveness. Regularly review and update the framework to adapt to evolving threats and technology.

 

Key Considerations When Choosing or Creating a Cybersecurity Framework

There are some things to keep in mind when implementing the project plan for choosing the cybersecurity framework. The project can easily go out of scope because of the security landscape continuously changing.

Please review regularly these considerations and make sure you go through the list before taking any big decisions.

  1. Alignment with Objectives: Ensure that the chosen framework aligns with your organization’s cybersecurity objectives, risk profile, and compliance requirements.
  2. Applicability: Consider the framework’s applicability to your industry and specific business needs.
  3. Resource Requirements: Assess the resources (financial, human, and technological) required for framework implementation and maintenance.
  4. Scalability: Determine whether the framework can scale with your organization’s growth and evolving cybersecurity needs.
  5. Integration: Ensure that the framework can integrate with existing security technologies and processes within your organization.
  6. Cost vs. Benefit: Evaluate the cost-effectiveness of implementing and maintaining the framework relative to the expected security benefits and risk reduction.
  7. Accessibility of Expertise: Consider the availability of expertise and training resources related to the chosen framework.
  8. Audit and Certification: If compliance or certification is a goal, verify that the framework is recognized and accepted by relevant certification bodies or authorities.
  9. Legal and Privacy Considerations: Ensure that the framework supports compliance with relevant data protection and privacy laws.
  10. Flexibility: Assess the framework’s flexibility to adapt to changing threat landscapes and emerging technologies.

 

Conclusions

Having a robust cybersecurity framework can be a competitive advantage. It can differentiate an organization in the eyes of customers, partners, and investors who prioritize security when choosing business partners.

Remember that selecting or creating a cybersecurity framework is not a one-size-fits-all process. It should be a thoughtful and strategic decision that aligns with your organization’s unique needs and circumstances.

Establishing a cybersecurity framework is essential to protect an organization’s digital assets, manage risks effectively, comply with legal requirements, and maintain the trust of stakeholders.

 

The post NIS2: 3.Establish a cybersecurity framework first appeared on Sorin Mustaca on Cybersecurity.

How to implement an Information Security Management System (ISMS)

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We wrote here https://www.sorinmustaca.com/how-to-nis2-eu-directive/ that the 3rd  step in implementing the requirements of the directive is to establish a cybersecurity framework.

If you haven’t read what a cybersecurity framework means, then you should read article: https://www.sorinmustaca.com/demystifying-cybersecurity-terms-policy-standard-procedure-controls-framework/ .

An ISMS is typically based on the ISO 27001 standard, which provides a framework for establishing, implementing, maintaining, and continually improving information security within an organization.

Establishing a cybersecurity framework is usually achieved together with, or while implementing an Information Security Management System (ISMS) based on a standard like ISO 27001. So, before going to the NIS2 Step 3, I must explain why is it important to have a “good” ISMS.

This article will guide you through the steps to create a solid foundation for the ISMS which uses a cybersecurity framework.

 

Here are the steps you must follow to implement your ISMS:

  1. Get Top Management Support
    • Before you start, synchronize with the top management in order to define company’s goals in this regard. Usually it should be clear, since the company strives to receive a certification like ISO 27001, ISO 16949, TISAX, CSMS, etc..
    • Then secure the commitment and support of senior management by helping them understand the necessary resources and efforts.
    • In all standards that require an ISMS it is imperative to have the commitment of the management because their feedback and support are required in several places along the way.
  2. Scope Definition
    • Define the scope of your ISMS: determine which assets, processes, and locations will be covered by the ISMS.
    • This will help in setting boundaries for your security efforts. Some certifications require an assessment per location and scope, so this needs to be developed properly and in accordance with company’s goals.
  3. Risk Assessment
    • Create policies that help identify and assess information security risks.
    • This involves:
      • How to identifying assets: List all the information assets your organization handles, such as data, hardware, software, and personnel, intellectual property.
      • How to identify threats and vulnerabilities: Determine potential risks and vulnerabilities that could impact your assets.
      • How to assess risks: Analyze the likelihood and potential impact of these risks.
      • How to calculate risk levels: Prioritize risks based on their severity.
  4. Risk Treatment
    • Develop a policy for risk treatment plan:
      • How to implement controls: Select and implement security controls and measures to mitigate identified risks.
      • Document policies and procedures that enforce the creation of security controls.
      • Allocate responsibilities: Assign roles and responsibilities for managing and monitoring security measures.
      • Set risk acceptance criteria: Determine which risks can be accepted, mitigated, or transferred.
  5.  Establish the ISMS Framework
    • Establish the ISMS framework based on ISO 27001:
      • Define information security objectives.
      • Develop an information security policy.
      • Create a risk assessment methodology.
      • Define criteria for risk acceptance.
      • Develop and implement security controls.
  6. Implementation
    • Execute the ISMS based on the established framework:
      • Train employees: Provide information security training to all staff members.
      • Implement security controls: Put in place the technical, administrative, and physical controls identified in your risk treatment plan.
      • Monitor and review: Continuously monitor the effectiveness of your controls and review your risk assessment.
  7. Measurement and Evaluation
    • Regularly measure and evaluate the performance of your ISMS to ensure that it remains effective and aligned with your objectives.
      • Conduct internal audits.
      • Perform security testing (e.g., penetration testing, vulnerability scanning).
      • Analyze security incident data.
  8. Management Review
    • Conduct regular management reviews to assess the ISMS’s performance and effectiveness.
      • Ensure that the ISMS is aligned with the organization’s strategic goals.
      • Make improvements based on review findings.
  9. Continual Improvement
    • Use the results of audits, reviews, and incidents to continually improve the ISMS.
      • Update policies and procedures as needed.
      • Enhance security controls based on new threats and vulnerabilities.
      • Maintain employee awareness and training.
  10. Certification (Optional):
    • If your organization desires ISO 27001 or any other certification, engage an accredited certification body to perform an external audit and certification assessment.
    • Be careful because several certification require a pre-certification or pre-assessment performed either with in-house auditors (internal) or external auditors.
  11. Documentation
    • Maintain detailed documentation of all ISMS activities, including policies, procedures, risk assessments, and audit reports.
    • Maintain a log of all changes in time, because this demonstrates continual improvement and usage.
  12. Training and Awareness
    • Continuously educate and raise awareness among employees regarding information security policies and best practices.
  13. Incident Response and Recovery
    • Develop an incident response plan to address security incidents promptly and effectively.

 

Remember, and make sure that your management remembers as well, that implementing and maintaining an ISMS is an ongoing process. Even if certifications are renewed only after 3 years (usually) it is important that in these 3 years the ISMS is lived.

Regularly update your risk assessments and adapt your security controls to evolving threats and business needs. Continuous improvement is key to the success of your ISMS.

 

The post How to implement an Information Security Management System (ISMS) first appeared on Sorin Mustaca on Cybersecurity.

NIS2: 2.Designate a responsible person or team

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We wrote here https://www.sorinmustaca.com/how-to-nis2-eu-directive/ that the second step in implementing NIS2 requirements is to designate a responsible person or team.

Appointing an individual or a team responsible for overseeing the implementation of the NIS2 directive within your company is critical to ensure its success.

NIS2 implementation and compliance is a project, and as any project must have a dedicated team that is actively working on its implementation.

Due to the fact that the the NIS2 requirements are demanding a continuous activity, there must be a continuity of the project after its implementation. This means that there has to be a team appointed to this project that is responsible for continuously monitoring and adapting the activities required for NIS2 compliance. To effectively manage these challenges, companies should establish a new dedicated team or name an existing team to be responsible for cybersecurity and compliance.

In this article, we will explore the reasons behind the need for such a team and identify existing teams within a company that could take on these vital responsibilities.

Cyber threats are constantly evolving, becoming more sophisticated and persistent. From data breaches and ransomware attacks to regulatory changes, companies are exposed to a multitude of risks that can have significant consequences.

Here’s why a dedicated cybersecurity and compliance team is essential:

  1. Proactive Threat Mitigation: A dedicated team can stay ahead of emerging threats by continuously monitoring the threat landscape, analyzing vulnerabilities, and implementing proactive security measures. They can assess potential risks and ensure that the company is well-prepared to defend against cyberattacks.
  2. Regulatory Compliance: Compliance with industry-specific regulations (ISO 27001, TISAX, ISO 21434) and data protection laws (such as GDPR or HIPAA) is a legal requirement. A dedicated team can ensure that the company adheres to these regulations, avoiding costly fines and legal repercussions.
  3. Incident Response: In the unfortunate event of a cybersecurity breach, a well-prepared team can swiftly respond to contain the damage, investigate the incident, and minimize the impact on the business and its customers.

 

Good news: existing teams can take on cybersecurity and compliance roles!

Identifying the right team to assume the responsibility of cybersecurity and compliance is crucial.

Below are some existing teams within a company that could take on these roles. However, be aware that due to the complex nature of the task, most chances of success has an interdisciplinary team.

 

  • IT Department: IT professionals are typically responsible for managing the company’s technology infrastructure. They can play a critical role in implementing security measures, monitoring networks, and ensuring that software and hardware are up to date with security patches.

Be aware, the IT teams may not have the specialized expertise needed for compliance and may benefit from additional support. With the right people on board, they can take over this critical task.

 

  • Legal and Compliance Teams: Legal and compliance departments are already well-versed in navigating complex regulatory frameworks. They can take on the compliance aspect of cybersecurity, ensuring that the company aligns with industry-specific laws and regulations.

L&C teams may require additional cybersecurity expertise to address the technical aspects of protection.

 

  • Dedicated Cybersecurity Team: For companies with significant digital assets and a higher level of exposure to cyber threats, establishing a dedicated cybersecurity team is advisable.

This team would focus exclusively on safeguarding the company’s digital assets, monitoring threats, conducting penetration testing, and developing comprehensive cybersecurity policies and strategies.

 

  • Cross-Functional Cybersecurity Team: In some cases, it may be beneficial to establish a cross-functional committee that includes representatives from various departments, including IT, legal, compliance, and risk management.

This team can collaborate to address cybersecurity and compliance challenges effectively.

 

Important activities that must be performed for NIS2 compliance

As part of the NIS2 requirements, the team responsible make sure that these activities are performed.

However, due to the fact that so many areas are involved, it is quite clear that the entire company must be involved.

 

  1. Risk Assessment and Management:
    • Identifying and assessing cybersecurity risks and vulnerabilities across the organization.
    • Developing risk mitigation strategies and prioritizing security measures based on the level of risk.
  2. Compliance Monitoring:
    • Ensuring the company complies with relevant industry-specific regulations, data protection laws, and compliance standards (e.g., GDPR, HIPAA, ISO 27001).
    • Conducting regular compliance audits and assessments to identify and address non-compliance issues.
  3. Policy Development and Enforcement:
    • Developing and maintaining comprehensive cybersecurity policies, procedures, and guidelines that align with regulatory requirements and industry best practices.
    • Enforcing these policies throughout the organization and ensuring employees are aware of and adhere to them.
  4. Security Awareness Training:
    • Providing cybersecurity awareness training to employees and stakeholders to enhance their understanding of security risks and best practices.
    • Promoting a security-conscious culture within the organization.
  5. Incident Response Planning:
    • Developing and maintaining an incident response plan that outlines the steps to take in the event of a security incident or data breach.
    • Conducting tabletop exercises and simulations to test the effectiveness of the incident response plan.
  6. Security Auditing and Testing:
    • Conducting regular security audits and assessments to identify vulnerabilities and weaknesses in the company’s systems and processes.
    • Performing penetration testing and vulnerability scanning to proactively detect and address security flaws.
  7. Security Architecture and Design:
    • Collaborating with IT teams to ensure that security is integrated into the design and architecture of systems, applications, and networks.
    • Evaluating and selecting security technologies and solutions to protect the organization’s assets.
  8. Threat Intelligence and Monitoring:
    • Monitoring the threat landscape to stay informed about emerging cybersecurity threats and trends.
    • Collecting and analyzing threat intelligence to proactively identify potential risks to the organization.
  9. Security Incident Investigation:
    • Investigating security incidents and breaches to determine their scope, impact, and root causes.
    • Collecting and preserving digital evidence for potential legal and regulatory purposes.
  10. Vendor and Third-Party Risk Management:
    • Assessing the cybersecurity practices of third-party vendors and partners who have access to the company’s data or systems.
    • Implementing risk mitigation strategies for third-party relationships.
  11. Reporting and Communication:
    • Reporting cybersecurity and compliance status and incidents to senior management, the board of directors, and relevant stakeholders.
    • Maintaining open lines of communication with legal, IT, risk management, and other relevant departments.
  12. Continuous Improvement:
    • Continuously evaluating and improving the organization’s cybersecurity posture based on lessons learned from security incidents and evolving threats.
    • Staying updated on cybersecurity trends and best practices to adapt security measures accordingly.
  13. Business Continuity and Disaster Recovery Planning:
    • Developing and maintaining business continuity and disaster recovery plans to ensure the organization can recover from disruptive events, including cybersecurity incidents.
  14. Regulatory Liaison:
    • Interacting with regulatory authorities and auditors during compliance assessments and audits.
    • Ensuring timely responses to regulatory inquiries and requests for information.

 

Cybersecurity and compliance are ongoing commitments that require dedicated attention and expertise. By establishing a specialized team or task force responsible for these crucial aspects, companies can better protect their data, reputation, and financial stability. Whether by empowering existing teams or creating new ones, the commitment to cybersecurity and compliance is an investment in the long-term success and resilience of the organization.

The post NIS2: 2.Designate a responsible person or team first appeared on Sorin Mustaca on Cybersecurity.

How-To: NIS2 EU Directive

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The NIS2 Directive is a European Union legislative text on cybersecurity that supersedes the first NIS (Network and Information Security) Directive, adopted in July 2016.

NIS vs. NIS2

While the first NIS (Network and Information Security) Directive increased the Member States’ cybersecurity capabilities, its implementation proved difficult, resulting in fragmentation at different levels across the internal market. To respond to the growing threats posed with digitalisation and the surge in cyber-attacks, the Commission has submitted a proposal to replace the NIS Directive and thereby strengthen the security requirements, address the security of supply chains, streamline reporting obligations, and introduce more stringent supervisory measures and stricter enforcement requirements, including harmonised sanctions across the EU.

NIS2 strengthens security requirements in the EU by expanding the NIS scope to more sectors and entities, taking into account

  • the security of supply chains,
  • streamlining reporting obligations,
  • introducing monitoring measures,
  • introducing more stringent enforcement requirements,
  • adding the concept of “management bodies” accountability within companies, and
  • harmonizing and tightening sanctions in all Member States.

To achieve the above mentioned goals, NIS2 requires member states to take a number of measures that forces them to work together:

  • Establish or improve information sharing between member states and a common incident response plan that coordinates with other member state plans
  • Establish a national Computer Emergency Response Team
  • Strengthen cooperation between public and private sector entities

 

In a nutshell, companies can stay compliant with the NIS2 Directive by

  • establishing an effective monitoring system that can detect intrusions, detect suspicious activities, and alert the authorities when necessary
  • developing comprehensive plans that detail how they will respond to an attack and what steps they will take to recover from it.

 

The official website of the EU for the NIS2 Directive has prepared an FAQ with many good questions and answers.

However, what the website is not saying (for good reasons) is how should companies start to prepare for implementing the directive.

 

How to start the compliance path

In order to successfully start implementing the requirements, the following steps should be implemented in this order. We will publish articles about pretty much each of these topics.

 

1.Conduct a gap analysis

Assess your company’s current cybersecurity practices, policies, and infrastructure against the requirements of the NIS2 directive.

Identify any gaps or areas that need improvement to comply with the directive.

Dedicated article:  https://www.sorinmustaca.com/nis2-1-perform-a-gap-analysis/

 

2.Designate a responsible person or team

Appoint an individual or a team responsible for overseeing the implementation of the NIS2 directive within your company. This could be a dedicated cybersecurity team or an existing department with relevant expertise.

Dedicated article: https://www.sorinmustaca.com/nis2-2-designate-a-responsible-person-or-team/

 

3.Establish a cybersecurity framework

Develop or update your company’s cybersecurity framework to align with the NIS2 directive. This framework should include policies, procedures, and technical controls to protect your network and information systems effectively.

Dedicated article: https://www.sorinmustaca.com/nis2-3-establish-a-cybersecurity-framework/

 

4.Perform a risk assessment

Conduct a comprehensive risk assessment of your company’s network and information systems. Identify potential threats, vulnerabilities, and risks that may impact the availability, integrity, and confidentiality of critical systems and data. This assessment will help you prioritize security measures and allocate appropriate resources. Risk management and assessments are an ongoing process. Once one risk assessment is carried out, it is important to schedule regular updates to ensure all steps are maintained.

Dedicated article: https://www.sorinmustaca.com/nis2-perform-a-risk-assessment/

 

5.Implement security measures

Based on the risk assessment findings, implement appropriate security measures to mitigate identified risks. This may include network segmentation, access controls, intrusion detection systems, incident response procedures, encryption, employee training, and regular security updates, among others.

Dedicated article:

 

6.Establish incident response capabilities

Develop an incident response plan and establish procedures for detecting, responding to, and recovering from cybersecurity incidents. Ensure the assigned employees are trained on how to recognize and report security breaches promptly. Business continuity is a very complex topic, which must be planned with a lot of time in advance and it requires extra resources (both human and financial).

Dedicated article:

 

7.Continuously Monitor and review

Implement mechanisms to continuously monitor and assess your network and information systems for potential threats. Regularly review and update your cybersecurity measures to adapt to emerging risks and changes in the threat landscape.

Dedicated article:

 

8. Maintain documentation and records

Keep comprehensive documentation of your cybersecurity measures, risk assessments, incident response activities, and any other relevant information. This documentation will serve as evidence of compliance and may be required for regulatory audits or investigations. A good record might save your company legal and regulatory repercussions in case of a major incident (cyber related or not).

Dedicated article:

 

9.Engage with regulatory authorities

Stay informed about any reporting or notification obligations outlined in the NIS2 directive. Establish communication channels with the relevant regulatory authorities and comply with any reporting requirements or inquiries they may have. NIS2 strives to improve EU-wide communication and sharing of cyber events in order to better prepare answers and reactions. Communication has never been more important than now.

Dedicated article:

 

10. Define KPIs for cybersecurity and measures taken based on them

In order to measure the effectiveness of the cybersecurity, you need to define metrics that allow identifying and quantifying changes. Example of metrics are number of incidents, types of incidents,  how many trainings have been made, how many people were trained, how many pentests were made and how many issues were identified, and many more.

Dedicated article:

 

 

 

The post How-To: NIS2 EU Directive first appeared on Sorin Mustaca on Cybersecurity.

Executive summary: NIS2 Directive for the EU members

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The NIS 2 Directive is a set of cybersecurity guidelines and requirements established by the European Union (EU) . It replaces and repeals the NIS Directive (Directive 2016/1148/EC) . The full name of the directive is “Directive (EU) 2022/2555 of the European Parliament and of the Council of 14 December 2022 on measures for a high common level of cybersecurity across the Union, amending Regulation (EU) No 910/2014 and Directive (EU) 2018/1972, and repealing Directive (EU) 2016/1148 (NIS 2 Directive)” .

The NIS 2 Directive aims to improve cybersecurity risk management and introduce reporting obligations across sectors such as energy, transport, health, and digital infrastructure . It provides legal measures to boost the overall level of cybersecurity in the EU .

The directive covers a larger share of the economy and society by including more sectors, which means that more entities are obliged to take measures to increase their level of cybersecurity .

The management bodies of essential and important entities must approve the cybersecurity risk-management measures taken by those entities, oversee its implementation, and can be held liable for infringements .

Who is affected?

The NIS 2 Directive significantly expands the sectors and type of critical entities falling under its scope.

As a ground rule, companies from certain areas that meet these conditions are affected:

Essential Entities (EE):

  • at least 250 employees and
  • 50 Mil € revenue

Important Entities (IE):

  • at least 50 employees and
  • 10 Mil € revenue

 

NIS 2 covers areas such as

  • Essential Entities:
    • energy (electricity, district heating and cooling, oil, gas and hydrogen);
    • transport (air, rail, water and road); banking;
    • financial market infrastructures;
    • health including  manufacture of pharmaceutical products including vaccines;
    • drinking water;
    • waste water;
    • digital infrastructure (internet exchange points; DNS service providers;
    • TLD name registries; cloud computing service providers;
    • data centre service providers;
    • content delivery networks;
    • trust service providers;
    • providers of  public electronic communications networks and publicly available electronic communications services);
    • ICT service management (managed service providers and managed security service providers), public administration and space.

Important Entities:

    • postal and courier services;
    • waste management;
    • chemicals;
    • food;
    • manufacturing of medical devices, computers and electronics, machinery and equipment, motor vehicles, trailers and semi-trailers and other transport equipment;
    • digital providers (online market places, online search engines, and social networking service platforms) and research organisations.

Note:
An entity may still be considered “essential” or “important” even if it does not meet the size criteria, in specific cases such as when it is the sole provider of a critical service for societal or economic activity in a Member State.

 

Deadlines

The Member States have until October 17, 2024, to adopt and publish the measures necessary to comply with the NIS 2 Directive. They shall apply those measures from October 18, 2024 .

The benefits of the NIS 2 directive include creating the necessary cyber crisis management structure (CyCLONe), increasing the level of harmonization regarding security requirements and reporting obligations, encouraging Members States to introduce new areas of interest such as supply chain, vulnerability management, core internet, and cyber hygiene in their national cybersecurity strategies, bringing novel ideas such as peer reviews for enhancing collaboration and knowledge sharing amongst Member States .

In order to comply with the NIS 2 directive, entities will need to take measures to increase their level of cybersecurity. This may include following training for members of management bodies of essential and important entities as well as offering similar training to their employees on a regular basis .

How does the NIS 2 Directive differ from the previous directive?

The NIS 2 Directive replaces the previous Network and Information Security (NIS) Directive, which was the first piece of EU-wide legislation on cybersecurity. Its specific aim was to achieve a high common level of cybersecurity across the Member States .

While the NIS Directive increased the Member States’ cybersecurity capabilities, its implementation proved difficult, resulting in fragmentation at different levels across the internal market. To respond to the growing threats posed by digitalization and the surge in cyber-attacks, the Commission submitted a proposal to replace the NIS Directive and thereby strengthen security requirements, address security of supply chains, streamline reporting obligations, and introduce more stringent supervisory measures and stricter enforcement requirements, including harmonized sanctions across the EU .

 

Consequences

The proposed expansion of the scope covered by NIS 2, by effectively obliging more entities and sectors to take measures, would assist in increasing the level of cybersecurity in Europe in the longer term . The NIS 2 Directive establishes very strict sanctions for breaches of its obligations. In contrast to the previous NIS Directive, which merely required Member States to set forth effective, proportionate and dissuasive penalties for non-compliance, the NIS 2 Directive introduces a much stricter regime .

NIS 2 will introduce a fining regime for non-compliance. The potential maximum fines for non-compliance could reach either

(i) €10 million or 2% of global annual turnover for “essential” entities or

(ii) €7 million or 1.4% of global annual turnover for “important” entities .

Next

In a future post I will explain how these requirements can be achieved.
Sources:
1. cybertalk.org
2. nis-2-directive.com
3. digital-strategy.ec.europa.eu
4. enisa.europa.eu
5. europarl.europa.eu
6. mondaq.com
7. rapid7.com
8. https://digital-strategy.ec.europa.eu/en/faqs/directive-measures-high-common-level-cybersecurity-across-union-nis2-directive-faqs

The post Executive summary: NIS2 Directive for the EU members first appeared on Sorin Mustaca on Cybersecurity.

The Importance of Implementing an Information Security Management System (ISMS)

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In today’s interconnected and data-driven business landscape, information has become one of the most valuable assets for companies. As organizations rely heavily on technology and digital platforms, protecting sensitive data from threats has become a critical concern.

This is where an Information Security Management System (ISMS) plays a pivotal role. In this article, we will explore why it is essential for companies to have an ISMS and how it can help safeguard their information assets.

Definitions

An ISMS, or Information Security Management System, is a systematic approach to managing an organization’s information security processes, policies, and controls. It is a framework that provides a structured and holistic approach to protect the confidentiality, integrity, and availability of sensitive information assets within an organization.

The primary objective of an ISMS is to establish a set of coordinated security practices that align with the organization’s overall business goals and risk management strategies. It involves defining and implementing policies, procedures, guidelines, and controls to manage the security of information assets effectively.

Key components of an ISMS typically include:

  1. Risk Assessment: Identifying and assessing potential risks and vulnerabilities to the organization’s information assets, including data breaches, unauthorized access, and system failures.
  2. Security Policies: Developing comprehensive policies and guidelines that outline the organization’s approach to information security, including acceptable use, data classification, incident response, and access control.
  3. Asset Management: Inventorying and categorizing information assets based on their importance and sensitivity, ensuring proper protection measures are applied accordingly.
  4. Access Control: Implementing controls to manage user access privileges, authentication mechanisms, and authorization processes to ensure that only authorized individuals can access sensitive information.
  5. Incident Response: Establishing procedures and protocols to detect, respond to, and recover from security incidents, including data breaches, malware attacks, or system compromises.
  6. Business Continuity Planning: Developing strategies to maintain critical business operations during and after a security incident or a disruptive event, ensuring minimal impact on the organization’s functions and services.
  7. Security Awareness and Training: Promoting a culture of security within the organization through regular training programs and awareness campaigns to educate employees about security best practices and their roles in protecting information assets.
  8. Continuous Monitoring and Improvement: Regularly monitoring and evaluating the effectiveness of security controls, conducting audits, and implementing improvements to address emerging threats and vulnerabilities.

Commonly recognized standards for implementing an ISMS include ISO/IEC 27001, which provides a globally recognized framework for information security management, and NIST Cybersecurity Framework, developed by the National Institute of Standards and Technology in the United States.

 

ISMS Scope

Key goals of an ISMS are:

1. Protecting Confidentiality and Integrity:

Companies possess a vast amount of confidential information, including customer data, financial records, proprietary processes, and intellectual property. An ISMS provides a structured framework to identify, classify, and protect this valuable information from unauthorized access, disclosure, or modification. By implementing robust security controls and protocols, an ISMS ensures the confidentiality and integrity of sensitive data, reducing the risk of data breaches, leaks, and unauthorized usage.

2. Compliance with Legal and Regulatory Requirements:

In an era of increasing data privacy regulations, companies face stringent legal obligations to protect customer information and comply with industry-specific standards. Implementing an ISMS assists in meeting these requirements by providing a systematic approach to information security management. Whether it’s the General Data Protection Regulation (GDPR), Health Insurance Portability and Accountability Act (HIPAA), or Payment Card Industry Data Security Standard (PCI DSS), an ISMS helps companies establish and maintain a strong security posture, avoiding legal penalties and reputational damage.

3. Mitigating Risks and Vulnerabilities:

Cyber threats and attacks are a constant and evolving concern for businesses of all sizes. An ISMS helps identify potential risks and vulnerabilities within the company’s information systems and infrastructure. By conducting regular risk assessments and implementing appropriate controls, such as firewalls, encryption, and intrusion detection systems, an ISMS minimizes the likelihood of security incidents. It enables proactive monitoring, threat detection, and incident response, ensuring that companies can effectively manage security risks.

4. Enhancing Customer Trust and Competitive Advantage:

In today’s highly competitive marketplace, customers prioritize the security and privacy of their data. By implementing an ISMS, companies demonstrate their commitment to protecting customer information and build trust among their client base. A robust information security framework helps differentiate the organization from its competitors and can be a valuable marketing point, particularly when dealing with sensitive data or operating in industries where security is paramount. Additionally, companies that adhere to international standards such as ISO 27001 gain a competitive edge by showcasing their dedication to best practices in information security management.

5. Business Continuity and Disaster Recovery:

Information security incidents can have severe consequences, leading to financial losses, operational disruptions, and damage to the company’s reputation. An ISMS encompasses business continuity planning and disaster recovery strategies to minimize the impact of such incidents. By implementing appropriate backup mechanisms, incident response protocols, and recovery procedures, companies can quickly restore operations and maintain the trust of stakeholders in the event of a security breach or a disruptive event.

An ISMS provides a comprehensive framework to protect sensitive information, comply with legal obligations, mitigate risks, build customer trust, and ensure business continuity. By implementing an ISMS, organizations can safeguard their valuable assets, keep and even enhance their reputation.

The post The Importance of Implementing an Information Security Management System (ISMS) first appeared on Sorin Mustaca on Cybersecurity.

How to convince Top Management to invest in cybersecurity and secure software development

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I’ve heard many times IT people and Software Developers complaining that they have difficulties to sensibilize their managers to invest more in cybersecurity.

Also some employees of my customers in the cybersecurity consulting area show sometimes frustration when we are talking about priorities of their top management – cybersecurity is almost neveve one until it is too late.

When I talk to C-Level of the organizations that book us for consulting, I am telling them that organizations face an increasing number of cyber threats these days compared to 10-20 years ago  (yes, we are so old).

They have a lot of risks like data breaches, ransomware attacks, and intellectual property theft and their only chance to survive these is to  investing early in robust cybersecurity measures and secure software development practices.

However, convincing top management to allocate resources and invest in these areas is a challenging task for everyone, me included.

Unfortunately, investing in cybersecurity is a bit like investing in a optional insurance: you want it so that you can stay relaxed, but you know you are not forced to buy it, so you try to find the cheapest one that covers more or less your risks. Additionally, you don’t even want to invest much in finding the right one that suits you, because you considered even this time almost a waste. In the end, you do something just for the sake of being able to sleep better, but deep down in your mind you know that you don’t actually know if it will help you if something happens, so you just tell yourself: this will not happen to me. Sounds familiar, right? 🙂

 

Here are some thoughts that you can expand if you want, that can help you persuade your management to invest in cybersecurity and secure software development.

  1. Understand the Risks and Consequences: Before making your case to top management, thoroughly comprehend the risks associated with inadequate cybersecurity and insecure software. Research recent cyber-attacks and data breaches to present real-life examples of the devastating consequences that organizations have faced. Emphasize the financial, reputational, and legal ramifications that can result from such incidents.
  2. Communicate in Business Terms: Top management is primarily concerned with the organization’s success and business continuity and growth. To effectively persuade them, it is essential to frame your argument in terms of business impact. Highlight how cybersecurity and secure software development directly contribute to the organization’s profitability, customer trust, regulatory compliance, and competitive advantage.
  3. Showcase the ROI of the investment: Present a compelling return on investment (ROI) analysis to demonstrate the financial benefits of investing in cybersecurity and secure software development. Calculate potential cost savings by comparing the expenses associated with preventing a breach to the financial implications of recovering from an attack. Additionally, highlight the positive impact on productivity, customer retention, and brand value that can result from a strong cybersecurity posture.
  4. Address Regulatory Compliance: Many industries (medicine, automotive, software development) have stringent data protection regulations and privacy laws. Highlight the legal and financial risks of non-compliance, such as substantial fines and damage to the organization’s reputation. Explain how investing in cybersecurity and secure software development aligns with regulatory requirements, safeguarding the organization against potential penalties and legal repercussions.
  5. Present Industry Benchmarks and Best Practices: Illustrate industry benchmarks and best practices to establish a standard of excellence in cybersecurity and secure software development. Share case studies of organizations in the same industry that have suffered cyber-attacks or data breaches, emphasizing how investing in security measures could have prevented or mitigated the damage. Highlight recognized frameworks and certifications, such as ISO 27001 and PCI DSS, to demonstrate the organization’s commitment to security.
  6. Present the Threat Landscape: Explain the main cyber threats and the need for investment in cybersecurity. Highlight risks such as ransomware, social engineering, and zero-day vulnerabilities. Illustrate the importance of regular security assessments, penetration testing, and employee training to stay ahead of new threats. Explain that cybersecurity is not a one-time investment but an ongoing process that requires continuous attention.
  7. Come up with a Step-By-Step Plan: Explain how a plan in several steps will help to mitigate the problems without causing too much disruption in the daily business. If business people want to hear anything more often , than it is that it won’t cost too much.
    Tailoring the solution in many steps and matching your company’s needs will also allow controlling the costs involved with the implementation.

 

Convincing top management to invest in cybersecurity and secure software development requires a strategic step-by-step approach. No business can go all-in because cybersecurity is hard to implement, even harder to maintain and expensive..

Remember to tailor your arguments and plans to the specific needs and priorities of your organization.

With a well-structured and persuasive approach, you can encourage top management to prioritize and allocate resources to safeguard the organization’s digital assets and ensure its long-term success in the face of evolving cyber threats.

 

If you need help to talk to your management, you can book the consulting services of Endpoint Cybersecurity here.

The post How to convince Top Management to invest in cybersecurity and secure software development first appeared on Sorin Mustaca on Cybersecurity.

Securing the Secure: The Importance of Secure Software Practices in Security Software Development

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In an increasingly interconnected digital world, the importance of secure software cannot be overstated.

Many people think that by using security software all their digital assets become automatically secured.

However, it is crucial to recognize that security software itself is not inherently secure by default.

To ensure the highest level of protection, security software must be designed, developed, and maintained using secure software practices.

This blog post emphasizes how important it is to incorporate secure software development practices within the broader context of the secure software lifecycle for security software.

 

Understanding the Secure Software Lifecycle

The secure software lifecycle encompasses the entire journey of a security software product, from its inception to its retirement.

It consists of multiple stages, such as :

  • Requirements gathering/Analysis
  • Design,
  • Implementation
  • Testing,
  • Deployment
  • Maintenance
  • Retirement

Incorporating secure software practices at each step is essential to fortify the software’s defense against potential vulnerabilities and attacks.

 

Implement Secure Software Development Practices

Implementing secure software practices involves adopting a proactive approach to identify and address security concerns from the outset.

Some fundamental practices include:

a. Threat Modeling:

Conducting a comprehensive analysis of potential threats and vulnerabilities helps developers design robust security measures. By understanding potential risks, developers can prioritize security features and allocate resources accordingly.

b. Secure Coding:

Writing code with a security-first mindset minimizes the likelihood of exploitable vulnerabilities. Adhering to coding standards, utilizing secure coding libraries, and performing regular code reviews and audits contribute to building a solid foundation for secure software.

c. Secure Configuration Management

Properly configuring the security software environment, such as secure network settings, encryption protocols, and access controls, is vital for safeguarding against unauthorized access and data breaches.

d. Regular Security Testing

Rigorous testing, including vulnerability assessments, penetration testing, and code analysis, helps identify and rectify security flaws. It ensures that security software operates as intended and remains resilient against evolving threats.

 

The Bigger Picture: Security in a Connected World

Secure software development practices extend beyond the development of security software alone. They have a broader impact on the overall security ecosystem. The adoption of secure software practices sets a precedent for other software developers, promoting a culture of security awareness and accountability.

Moreover, incorporating secure practices in security software helps foster trust among users and organizations. It instills confidence that the software is diligently designed to protect sensitive information and critical systems. Secure software practices also contribute to regulatory compliance, enabling organizations to meet stringent security standards and safeguard user data.

 

The Vital Importance of Secure Software: Consequences of Security Vulnerabilities for Security Companies

The implications of security vulnerabilities go beyond the immediate risks they pose to users and organizations. For security companies, the consequences of having products with security vulnerabilities can be severe, impacting their reputation, customer trust, and overall business viability.

Here are just a few negative consequences that security companies may face if their products fall prey to security vulnerabilities:

  1. Reputation Damage: Security companies are built on trust and reliability. When a security product is discovered to have vulnerabilities, it erodes customer confidence and tarnishes the company’s reputation. The perception that a security company cannot protect its own software casts doubt on its ability to safeguard sensitive information and defend against external threats. This loss of trust can be challenging to regain, resulting in a significant blow to the company’s credibility and market standing.
  2. Customer Loss and Dissatisfaction: Security vulnerabilities in software can lead to compromised systems, data breaches, and financial losses for users. In such instances, customers are likely to seek alternative security solutions, abandoning the vulnerable product and the company behind it. This loss of customers not only affects the company’s revenue but also demonstrates a lack of customer satisfaction and loyalty. Negative word-of-mouth can spread rapidly, deterring potential customers from considering the security company’s offerings in the future.
  3. Legal and Regulatory Consequences: Security vulnerabilities can have legal and regulatory implications for security companies. Depending on the nature and severity of the vulnerabilities, companies may face legal action from affected parties, resulting in costly litigation and potential financial penalties. Furthermore, security companies operating in regulated industries, such as finance or healthcare, may face compliance violations, leading to fines and reputational damage. Compliance with security standards and industry regulations is critical for security companies to maintain credibility and avoid legal consequences.
  4. Increased Operational Costs: Addressing security vulnerabilities requires significant resources, both in terms of time and finances. Security companies must invest in dedicated teams to investigate, fix, and release patches or updates to address vulnerabilities promptly. Additionally, engaging in incident response, customer support, and post-incident communication efforts adds to the operational costs. Failure to address vulnerabilities in a timely and efficient manner can exacerbate the negative consequences, making the recovery process more challenging and expensive.

 

In an era where security breaches and cyber threats are prevalent, relying solely on the notion that security software is inherently secure is a grave misconception. Secure software practices are indispensable for developing robust and resilient security software. By implementing these practices throughout the software lifecycle, developers can significantly mitigate the risks associated with vulnerabilities and ensure the highest level of protection for users and organizations alike. Embracing secure software practices sets the stage for a safer digital landscape, bolstering trust, and reinforcing security across the entire software development ecosystem. By prioritizing security, security companies can protect their customers, preserve their reputation, and maintain a competitive edge in the ever-evolving landscape of cybersecurity.

 

If you want to know more about SSDLC, contact Endpoint Cybersecurity for a free consultation.

Secure Software Development Lifecycle (SSDLC)

The post Securing the Secure: The Importance of Secure Software Practices in Security Software Development first appeared on Sorin Mustaca on Cybersecurity.