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Commentary



TOP TAKEAWAYS FROM TABLE TALKS WITH FORTUNE 100 CISOS

As organizations struggle to keep up with new regulations and hiring challenges,
chief information security officers share common challenges and experiences.
Larry Whiteside Jr.
Chief Information Security Officer, RegScale
July 11, 2023
Source: Panther Media GmbH via Alamy Stock Photo
PDF


Recently, I toured the East Coast and met with Fortune 100 chief information
security officers (CISOs) in different industries to have frank discussions
about cybersecurity and the changing regulatory compliance landscape. These
leaders discussed the impacts of significant breaches and the most serious
challenges facing them today. As many organizations struggle to keep up with new
regulations and simultaneously face hiring challenges, I discovered some shared
challenges and experiences from CISOs, regardless of their organization's size
or location. 




FEDERAL REGULATIONS AND AGENCIES 

CISOs generally have a complex relationship with regulatory agencies.
Increasingly, governments are sharing recommendations and creating regulations
to build robust cybersecurity strategies. It's important to establish
relationships with federal agencies before experiencing a breach. Relationships
with individuals in key agencies for your industry help you understand clearly
which agencies to contact in the event of a security incident. Some of the CISOs
I spoke to had experienced significant breaches, and those with existing
relationships with relevant agencies navigated the response process easily and
addressed the incident efficiently and swiftly.

As the regulatory compliance landscape changes, the CISOs agree on the
importance of staying current with regulatory requirements. Some regulations
require organizations to file disclosures about their cybersecurity practices
periodically. The General Data Protection Regulation (GDPR), the Cyber Incident
Reporting for Critical Infrastructure Act of 2022 (CIRCIA), and the National
Credit Union Administration (NCUA) require organizations to disclose information
about a material cybersecurity incident within 72 hours, while the Securities
and Exchange Commission (SEC) allows 96 hours. The timeline means that robust
incident response plans must be in place to make a determination quickly. 

Similarly, CISOs anticipate the Cybersecurity Maturity Model
Certification (CMMC) will seriously impact prime contractors for Department of
Defense contracts because prime contractors are responsible for ensuring that
their subcontractors meet the appropriate CMMC level for their work. Many
smaller subcontractors need to be more prepared to answer the myriad questions
and controls required. 



CISOs in public and private industries accept the inevitability of these
changes. They are trying to find the balance between putting the right
protections in place to meet regulations and being ready to report quickly if a
significant incident occurs. Hiring and retaining cybersecurity talent is
integral to achieving this balance.




HIRING CHALLENGES AND OPPORTUNITIES 

As cybersecurity challenges continue evolving, staff shortages are growing in
the workforce. (ISC)2 research showed a workforce gap of 3.4 million cyber
professionals worldwide in 2022, even as many organizations face increasing
risks, work to comply with new regulatory requirements, and adopt new
technologies. Hiring challenges are twofold: finding the right talent is hard,
and many organizations seek to increase team diversity. 

Despite tech industry layoffs, CISOs still have trouble finding people to fill
their open roles. In Florida, however, I discovered that many people moved to
the area during the pandemic, making available roles easier to fill there. 



To handle the impossibility of getting all the talent they need, the CISOs I
spoke to are looking to use more automation. Security teams are inundated with
vast amounts of data as the technology landscape changes and new tools emerge.
Security leaders are looking for automation to sort through that data and
highlight what their teams need to focus on. Everyone wants more artificial
intelligence (AI) and machine learning (ML) to make it easier for them to
appropriately protect the data, infrastructure, and organizations they are
responsible for. 


CISOS ROLE AND D&O INSURANCE 

Massive breaches, such as those that exposed the data of over 50 million
customers at Uber, are advancing the conversation about the CISO's role and
whether CISOs need directors and officers (D&O) insurance. Uber CISO Joseph
Sullivan was ordered to pay a $50,00 fine and complete 200 hours of community
service and three years of probation for his role in the 2016 breach. While some
in the industry see it as a broader security failure and a cautionary tale for
CISOs as it relates to their role among the corporate executive team, others
believe Sullivan misrepresented the situation and bore greater responsibility. 

These incidents show that the CISO role and reporting relationship with the
executive team and the board may need review. Today, CISOs bear significant
responsibility for their organizations' reputation and success, and many believe
it is time to require D&O insurance as part of their cybersecurity leadership
role, just as the rest of the executive team does. 


WHAT'S NEXT? 

As CISOs look ahead, they are heavily concerned with increasing regulations and
the need to comply with them. Security leaders need to choose which controls are
most important and align them to a compliance framework. This can help them get
the budget needed to create an effective cybersecurity program that blends
automation, AI, ML, and cybersecurity talent to meet the challenges ahead —
preferably without needing that D&O insurance coverage.

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