The role of the Information Security Officer (ISO) in financial institutions continues to increase in responsibility and accountability year over year. The security challenges of community banks and credit unions are expanding as data breaches, targeted attacks, and cybersecurity threats become more pervasive. ISOs must be equipped to guide their institution through the complexities of addressing security threats in the current environment. The ISO job function—which should exist as a separate role within the institutions—should go beyond focusing on overall policy development, risk management, and working with high-level executives to also include visibility and accountability for technical activities on internal systems and with technology service providers (TSPs). This ensures that all security strategies are being implemented and managed according to organizational objectives.
Regulatory Expectations and Requirements
While the role can vary among different financial institutions, today's ISO has leadership responsibilities that involve crucial areas like cyber risk assessment, regulatory compliance, business continuity planning, and incident response. Other key duties include the technology committee and board reporting and preparing for and responding to audits and exams.
In terms of regulatory expectations and requirements, today's ISO is responsible for proving its institution has met all relevant regulatory requirements and is protecting all the data, records, and personal information of its customers/members. In addition, the Federal Financial Institutions Examination Council (FFIEC) requires all institutions to have a designated ISO that is responsible and accountable for implementing and monitoring the information security program. Although general information security management duties may be shared among various business lines, the ISO is responsible for providing stakeholders and decision-makers with sufficient information to support their oversight efforts.
Augmenting the ISO Role
As today's ISOs expand their focus beyond conventional information security issues and duties, they will need more expertise and advanced tools to protect their institution against ever-changing cyber threats. The ISO will need to address more complex challenges relating to cloud security, artificial intelligence, and other technological advancements. Many ISOs with community FIs do not have the time, experience, or technology expertise to organize and manage these responsibilities. The good news is that financial institutions can augment any lack of expertise with a Virtual ISO (VISO) solution. A VISO does not remove the need for a resident ISO at the institution, but it can provide valuable expertise, perspective, and assurance that all periodic responsibilities are adequately addressed. Our virtual ISO solution offers access to a suite of applications, resources, reporting, and dedicated risk and compliance specialists to help community banks and credit unions manage the myriad of risk management and FFIEC Compliance responsibilities including accountability and visibility for anomalies and exceptions for technology and IT (Information Technology) security activities that could negatively affect non-public information and financial transactions.
Navanta is dedicated to sharing knowledge and providing training around this critical role. Our IT and Information Security Compliance experts have hosted numerous "ISO 101" classes and webinars that focus on the requirements of the role within today's regulatory framework and the accountability factors among the various stakeholders.
