Customizing and Testing Policies and Procedures for Cybersecurity

Many companies spend a lot of money, time and effort securing their internal systems to avoid being the next firm making headlines because of an avoidable security breach. From phishing to data loss to DDoS attacks, there are a variety of methods that hackers can use to exploit vulnerabilities. With SDDco, consultants will fully manage the process, putting plans and actions in motion for any data security incident.

Starting with customizing and testing your policies and procedures for Cybersecurity, we will:

  • Profile current operations to ensure our recommendations are applicable to your firm using proprietary processes and technologies
  • Assess statutory and regulatory requirements to produce current and customized procedures in real time using the National Institute of Standards and Technology (NIST)
  • Produce documentation which is reflective of actual and repeatable work processes
  • Establish the required disposition and controls for all data elements including hardware, software, and data classifications
  • Monitor and update all aspects of coverage based on regulatory, statutory, and operating changes
  • Produce evidence of human understanding and device performance that confirms current policies and procedures

Don’t Be the Next Cyber Casualty
Protect Your Network and Data from Hackers and Threats

Have you implemented cybersecurity policies that were not customized for your firm? If so, you might be faced with some consequences!

The SEC’s Office of Compliance Inspections and Examinations (OCIE) discovered many firms have implemented policies that were not customized to their firms’ circumstances, which have posed a risk alert advisory. Some of the issues found were:

  • Broker-dealers and investment advisors did not have privacy notices that were both accurate and met Regulation S-P’s requirements
  • The procedures that were in place did not adequately protect customers’ nonpublic financial information in several specific ways
  • The registrants’ written policies and procedures were not customized for their business, did not comprehensively address cybersecurity, and did not accurately reflect their practices

Test Your Cybersecurity Risk
Protect Your Network from Hackers and Threats

The key takeaway by OCIE is that registrants should review their written policies and procedures, including the implementation processes. SDDco consultants recommend broker- dealers and investment advisors benchmark their privacy and cybersecurity written policies, and their implementation processes against the SEC’s expectations set forth in the Risk Alert. Additionally, it is a best practice to stay current with both FINRA and the SEC’s cybersecurity guidance as new threats are constantly looming.

This can be approached efficiently using a questionnaire that is designed with the SEC’s stated expectations in mind. It is crucial to conduct annual risk assessments and testing of controls to verify effectiveness and adequacy. This assessment may be accomplished by a third-party or firm security experts, which is where we come in. SDDco Regulatory Services, LLC will make sure that your firm’s cybersecurity policies do not raise any red flags to OCIE. With data breach incidents occurring daily, it’s no longer a matter of if you will suffer one, but when, how often, how you will respond, and how you will recover. With your company’s business continuity, reputation, and future at risk, you can’t afford to be unprepared and non-compliant. SDDco Regulatory Services, LLC protects your company from the devastating effects of an internal data breach by providing essential services to help you respond to the situation.

We Have a Solution for You!

Protection from a cyber breach is within your reach, leverage the power of SDDco Cyber for your firm’s cybersecurity compliance program! Our experienced consultants are dedicated and prepared to review your current security protocols and to implement new policies to ensure you are protected.

  • Become compliant with all state and federal requirements including FINRA, NYDFS, SEC, etc.
  • Infrastructure Testing including Penetration Testing
  • Customized and Tested Policies and Procedures
  • Fully Managed Incident Response Coverage
  • Data Security Training
  • Vendor Due Diligence
  • Risk Assessments