RISK MANAGEMENT-INFORMATION SECURITY
1.
INTRODUCTION:
Banks deal with
public money and therefore, trust is the most important pillar of the banking
business. While trust may be considered synonymous with banking, security is also
considered equally important. The concept and perception of security in banking
has, over a period of time, changed drastically, in tandem with changes in the
way banking business is conducted. Now a days, banks maintain their assets more
in digitized rather than physical form, carry out their transactions over
technology enabled platforms/applications and communicate through electronic
modes.
The banking business does not face any growth impediments because of physical,
geographical or
product/knowledge-related boundaries as technology has come to their aid. There
are newer products and channels of delivery. Networked environment has enabled
delivery of banking services at the doorstep of the customer. Anywhere, anytime
banking with core banking and newer delivery channels viz., ATM, online
banking, mobile banking etc. have provided convenience of banking to the
customer and more and more people are
now relying upon the convenience and ease of use of Internet banking services
in their business as well as daily life. But, this has also resulted in enhanced
customer expectations about efficient delivery of services with the highest
level of security. Growth of business, customer satisfaction and retention of customers’
loyalty, therefore, depend on the highest quality of service coupled with the
state of the art security features.
Information and the knowledge based on it have increasingly become
recognized as ‘information assets’, which are vital enablers of business
operations. It is therefore, absolutely crucial for any organisation to provide
adequate levels of protection to these assets. Reliable information is even
more critical for banks, as banks are purveyors of money in physical and
digital form and hence information security is a vital area of concern.
Robust information is at the heart of risk management processes in a
bank. Inadequate data quality is likely to induce errors in decision making.
Data quality requires building processes, procedures and disciplines for
managing information and ensuring its integrity, accuracy, completeness and
timeliness. The fundamental attributes supporting data quality include
accuracy, integrity, consistency, completeness, validity, timeliness,
accessibility, usability and auditability. The data quality provided by various
applications depends on the quality and integrity of the data upon which that
information is built. Entities that treat information as a critical organizational
asset are in a better position to manage it proactively. Information security
not only deals with information in various channels like spoken, written,
printed, electronic or any other medium but also information handling in terms
of creation, viewing, transportation, storage or destruction .This is in
contrast to IT security which is mainly concerned with security of information
within the boundaries of the network infrastructure technology domain. From an
information security perspective, the nature and type of compromise is not as
material as the fact that security has been breached. It is therefore,
imperative for Bank Managements to establish an effective information security risk
governance framework as a part of the
overall Corporate Governance Framework so that the Banks develop and maintain a
comprehensive information security programme.
2. BASIC PRINCIPLES OF INFORMATION SECURITY:
The basic
principles of information security are as under:
a)
Confidentiality: Confidentiality is the term used to prevent the disclosure of
information to unauthorized individuals or systems. For example, a credit card
transaction on the Internet requires the credit card number to be transmitted
from the buyer to the merchant and from the merchant to a transaction
processing network.The system attempts to enforce confidentiality by encrypting
the card number during transmission, by limiting the places where it might
appear (in databases, log files, backups, printed receipts, and so on), and by
restricting access to the places where it is stored. If an unauthorized party
obtains the card number in any way, a breach of confidentiality has occurred.
Breaches of confidentiality take many forms like Hacking, Phishing, Vishing,
Email-spoofing, SMS spoofing, and sending malicious code through email or Bot
Networks, as discussed earlier.
b) Integrity: In information security,
integrity means that data cannot be modified without authorization. This is not
the same thing as referential integrity in databases. Integrity is violated
when an employee accidentally or with malicious intent deletes important data
files, when he/she is able to modify his own salary in a payroll database, when
an employee uses programmes and deducts small amounts of money from all
customer accounts and adds it to his/her own account (also called salami
technique), when an unauthorized user vandalizes a web site, and so on. On a
larger scale, if an automated process is not written and tested correctly, bulk
updates to a database could alter data in an incorrect way, leaving the
integrity of the data compromised. Information security professionals are
tasked with finding ways to implement controls that prevent errors of
integrity.
c) Availability: For any information system to
serve its purpose, the information must be Available when it is needed. This
means that the computing systems used to store and process the information, the
security controls used to protect it, and the communication channels used to
access it must be functioning correctly. High availability systems aim to
remain available at all times, preventing service disruptions due to power
outages, hardware failures, and system upgrades. Ensuring availability also
involves preventing denial-of-service (DoS) and distributed denial-of service
(DDoS) attacks.
d) Authenticity: In computing, e-business and
information security it is necessary to ensure that the data, transactions,
communications or documents (electronic or physical) are genuine. It is also
important for authenticity to validate that both parties involved are who they
claim they are.
e) Non-repudiation: In law,
non-repudiation implies one's intention to fulfill one’s obligations under a
contract / transaction. It also implies that a party to a transaction cannot
deny having received or having sent an electronic record. Electronic commerce
uses technology such as digital signatures and encryption to establish
authenticity and non-repudiation. In addition to the above, there are other
security-related concepts and principles when designing a security policy and
deploying a security solution. They include identification, authorization,
accountability, and auditing.
f) Identification: Identification is
the process by which a subject professes an identity and accountability is
initiated. A subject must provide an identity to a system to start the process
of authentication, authorization and accountability. Providing an identity can
be typing in a username, swiping a smart card, waving a proximity device,
speaking a phrase, or positioning face, hand, or finger for a camera or
scanning device. Proving a process ID number also represents the identification
process. Without an identity, a system has no way to correlate an
authentication factor with the subject.
g) Authorization: Once a subject is
authenticated, access must be authorized. The process of authorization ensures
that the requested activity or access to an object is possible given the rights
and privileges assigned to the authenticated identity. In most cases, the
system evaluates an access control matrix that compares the subject, the
object, and the intended activity. If the specific action is allowed, the
subject is authorized. Else, the subject is not authorized.
h) Accountability and auditability: An organization’s security policy can be properly enforced only if
accountability is maintained, i.e., security can be maintained only if subjects
are held accountable for their actions. Effective accountability relies upon
the capability to prove a subject’s identity and track their activities.
Accountability is established by linking a human to the activities of an online
identity through the identification. Thus, human accountability is ultimately
dependent on the strength of the authentication process. Without a reasonably
strong authentication process, there is doubt that the correct human associated
with a specific user account was the actual entity controlling that user
account when an undesired action took place.
3. INFORMATION SECURITY GOVERNANCE:
Information security governance consists of the leadership,
organizational structures and processes that protect information and mitigation
of growing information security threats like the ones detailed above.
Critical outcomes of information security governance include:
Ø Alignment of information security with business strategy to support
organizational objectives
Ø Management and mitigation of risks and reduction of potential impacts
on information resources to an acceptable level
Ø Management of performance of information security by measuring,
monitoring and reporting information security governance metrics to ensure that
organizational objectives are achieved
Ø Optimisation of information security investments in support of
organizational objectives
It is important to consider the organisational necessity and benefits
of information security governance. They
include increased predictability and the reduction of uncertainty in business
operations, a level of assurance that critical decisions are not based on
faulty information, enabling efficient and effective risk management,
protection from the increasing potential for legal liability, process
improvement, reduced losses from security-related events and prevention of
catastrophic consequences and improved reputation in the market and among customers.
A comprehensive security programme needs to include the following main
activities:
Ø Development and ongoing maintenance of security policies
Ø Assignment of roles, responsibilities and accountability for
information security
Ø Development/maintenance of a security and control framework that
consists of standards, measures, practices and procedures
Ø Classification and assignment of ownership of information assets
Ø Periodic risk assessments and ensuring adequate, effective and tested
controls for people, processes and technology to enhance information security
Ø Ensuring security is integral to all organizational processes
Ø Processes to monitor security incidents
Ø Effective identity and access management processes
Ø Generation of meaningful metrics of security performance
Ø Information security related awareness sessions to users/officials
including senior officials and board members
4. ORGANIZATIONAL STRUCTURE, ROLES AND RESPONSIBILITIES:
(A)
BOARDS
OF DIRECTORS/SENIOR MANAGEMENT:
The Board of Directors is ultimately responsible for information
security. Senior Management is responsible for understanding risks to the bank
to ensure that they are adequately addressed from a governance perspective. To
do so effectively requires managing risks, including information security
risks, by integrating information security governance in the effectiveness of
information security governance is dependent on the involvement of the
Board/senior management in approving policy and appropriate monitoring of the
information security function.
The major role of top management involves implementing the Board
approved information security policy, establishing necessary organizational
processes for information security and providing necessary resources for
successful information security. It is essential that senior management
establish an expectation for strong cyber security and communicate this to
their officials down the line. It is also essential that the senior
organizational leadership establish a structure for implementation of an
information security programme to enable a consistent and effective information
security programme implementation apart from ensuring the accountability of
individuals for their performance as it relates to cyber security.
Given that today’s banking is largely dependent on IT systems and
since most of the internal processing requirements of banks are electronic, it
is essential that adequate security systems are fully integrated into the IT
systems of banks. It would be optimal to classify these based on the risk
analysis of the various systems in each bank and specific risk mitigation
strategies need to be in place.
(B)
INFORMATION
SECURITY TEAM/FUNCTION:
Banks should form a separate information security function/group to
focus exclusively on information security management. There should be
segregation of the duties of the Security Officer/Group dealing exclusively
with information systems security and the Information Technology Division which
actually implements the computer systems. The organization of the information
security function should be commensurate with the nature and size of activities
of a bank including a variety of e-banking systems and delivery channels of a
bank. The information security function should be adequately resourced in terms
of the number of staff, level of skills and tools or techniques like risk
assessment, security architecture, vulnerability assessment, forensic
assessment, etc. While the information security group/function itself and
information security governance related structures should not be outsourced,
specific operational components relating to information security can be
outsourced, if required resources are not available within a bank. However, the
ultimate control and responsibility rests with the bank.
(C)
INFORMATION
SECURITY COMMITTEE:
Since information security affects all aspects of an organization, in
order to consider information security from a bank-wide perspective a steering
committee of executives should be formed with formal terms of reference. The
Chief Information Security Officer would be the member secretary of the
Committee. The committee may include, among others, the Chief Executive Officer
(CEO) or designee, chief financial officer (CFO), business unit executives,
Chief Information Officer (CIO)/ IT Head, Heads of human resources, legal, risk
management, audit, operations and public relations.
A steering committee serves as an effective communication channel for
management’s aims and directions and provides an ongoing basis for ensuring
alignment of the security programme with organizational objectives. It is also
instrumental in achieving behaviour change toward a culture that promotes good
security practices and compliance with policies.
Major responsibilities of the Information Security Committee,
inter-alia, include:
Ø Developing and facilitating the implementation of information security
policies, standards and procedures to ensure that all identified risks are
managed within a bank’s risk appetite
Ø Approving and monitoring major information security projects and the
status of information security plans and budgets, establishing priorities,
approving standards and procedures
Ø Supporting the development and implementation of a bank-wide
information security management programme
Ø Reviewing the position of security incidents and various information
security assessments and monitoring activities across the bank
Ø Reviewing the status of security awareness programmes
Ø Assessing new developments or issues relating to information security
Ø Reporting to the Board of Directors on information security activities
Minutes of the Steering Committee meetings should be maintained to
document the committee’s activities and decisions and a review on information
security needs to be escalated to the Board on a quarterly basis.
(D)
CHIEF
INFORMATION SECURITY OFFICER (CISO):
A sufficiently senior level official, of the rank of GM/DGM/AGM,
should be designated as Chief Information Security Officer, responsible for
articulating and enforcing the policies that banks use to protect their
information assets apart from coordinating the security related issues /
implementation within the organization as well as relevant external agencies.
The CISO needs to report directly to the Head of Risk Management and should not
have a direct reporting relationship with the CIO. However, the CISO may have a
working relationship with the CIO to develop the required rapport to understand
the IT infrastructure and operations, to build effective security in IT across
the bank, in tune with business requirements and objectives.
5. CRITICAL COMPONENTS OF INFORMATION SECURITY:
1)
Policies and
procedures:
Banks need to frame Board approved information security policy supported with relevant
standards, guidelines and procedures need to be framed and appropriate
measures/practices need to be identified and implemented keeping in view the
business needs.
2)
Risk Assessment:
Risk assessment is the core competence of information security
management and must include, for each asset within its scope, identification of
the threat/vulnerability combinations that have a likelihood of impacting the
confidentiality, availability or integrity of that asset - from a business,
compliance or contractual perspective.
3) Inventory and information/data classification:
Effective control requires a detailed inventory of information assets.
Such a list is the first step in classifying the assets and determining the
level of protection to be provided to each asset.
By assigning classes or levels of sensitivity and criticality to
information resources and establishing specific security rules/requirements for
each class, it is possible to define the level of access controls that should
be applied to each information asset.
4) Defining roles and responsibilities:
All defined and documented responsibilities and accountabilities must
be established and communicated to all relevant personnel and management. Some
of the major ones include:
a) Information owner
b) Application owner
c) User manager
d) Security Administrator
e) End user
5) Access Control:
An effective process for access to information assets is one of the
critical requirements of information security. Internal sabotage, clandestine
espionage or furtive attacks by trusted employees, contractors and vendors are
among the most serious potential risks that a bank faces. Current and past
employees, contractors, vendors and those who have an intimate knowledge of the
inner workings of the bank’s systems, operations and internal controls have a
significant advantage over external attackers. A successful attack could
jeopardise customer confidence in a bank’s internal control systems and
processes. Hence, access to information assets needs to be authorised by a bank
only where a valid business need exists and only for the specific time period
that the access is required.
6) Information security and information asset life-cycle:
Information security needs to be considered at all stages of an
information asset’s life-cycle like planning, design, acquisition and
implementation, maintenance and disposal. Banks need to apply systematic
project management oriented techniques to manage material changes during these
stages and to ensure that information security requirements have been
adequately addressed.
7) Personnel security:
Application owners grant legitimate users access to systems that are
necessary to perform their duties and security personnel enforce the access
rights in accordance with institution standards. Because of their internal
access levels and intimate knowledge of financial institution processes,
authorized users pose a potential threat to systems and data. Employees,
contractors, or third-party employees can also exploit their legitimate
computer access for malicious or fraudulent reasons. Further, the degree of
internal access granted to some users can increase the risk of accidental
damage or loss of information and systems. Risk exposures from internal users
include altering data, deleting production and back-up data,
disrupting/destroying systems, misusing systems for personal gain or to damage
the institution, holding data hostage and stealing strategic or customer data
for espionage or fraud schemes. It is, therefore, important to have a process
to verify job application information for all new employees and additional
background and credit checks based on the sensitivity of a particular job or
access level.
8) Physical security:
The confidentiality, integrity, and availability of information can be
impaired through physical access and damage or destruction to physical
components. As such, it is important to mitigate the physical security risks
through zone-oriented implementations and by having proper risk assessment and
environmental controls.
9) User Training and Awareness:
It is acknowledged that the human link is the weakest link in the
information security chain. Hence, there is a vital need for an initial and
ongoing training and information security awareness programme. The programme
may be periodically updated keeping in view changes in information security,
threats/vulnerabilities and/or the bank’s information security framework. There
needs to be a mechanism to track the effectiveness of training programmes
through an assessment/testing process designed on testing the understanding of
the relevant information security policies, not only initially but also on a
periodic basis. At any point of time, a bank needs to maintain an updated
status on user training and awareness relating to information security and the
matter needs to be an important agenda item during Information Security
Committee meetings.
10) Incident management:
Incident management is defined as the process of developing and
maintaining the capability to manage incidents within a bank so that exposure
is contained and recovery achieved within a specified time objective. Incidents
can include the misuse of computing assets, information disclosure or events
that threaten the continuance of business processes. An effective incident
management framework for preventing, detecting, analyzing and responding to
information security incidents is therefore, required to be implemented.
11) Application Control and Security:
Financial institutions have different types of applications like the
core banking system, delivery channels like ATMs, internet banking, mobile
banking, phone banking, network operating systems, databases, enterprise
resource management (ERP) systems, customer relationship management (CRM)
systems, etc., all used for different business purposes. Then these
institutions have partners, contractors, consultants, employees and temporary
employees. Users usually access several different types of systems throughout
their daily tasks, which makes controlling access and providing the necessary
level of protection on different data types difficult and full of obstacles.
This complexity may result in unforeseen and unidentified holes in the
protection of the entire infrastructure including overlapping and contradictory
controls, and policy and regulatory noncompliance. Banks, therefore, need to
implement proper application control
and risk mitigation measures.
12) Migration controls:
A documented Migration Policy indicating the requirement of roadmap/
migration plan / methodology for data migration (which includes verification of
completeness, consistency and integrity of the migration activity and pre and
post migration activities along with responsibilities and timelines for
completion of same) is required to be put in place to take care of data
integrity, completeness, confidentiality, consistency and continuity.
13) Implementation of new technologies:
Banks need to carry out due diligence with regard to new technologies
since they can potentially introduce additional risk exposures. A bank needs to
authorise the large scale use and deployment in production environment of
technologies that have matured to a state where there is a generally agreed set
of industry-accepted controls and robust diligence and testing has been carried
out to ascertain the security issues of the technology or where compensating
controls are sufficient to prevent significant impact and to comply with the
institution’s risk appetite and regulatory expectations. A formal product approval process incorporating,
inter-alia, security related aspects and fulfilment of relevant legal and
regulatory prescriptions should also be in place for all new business products
introduced by the bank.
14) Encryption:
There are two
types of encryption – Symmetric and Asymmetric.
Symmetric encryption is the use of the
same key and algorithm by the creator and reader of a file or message.
Asymmetric encryption lessens the risk
of key exposure by using two mathematically related keys, the private key and
the public key. When one key is used to encrypt, only the other key can
decrypt. Therefore, only one key (the private key) is required to be kept
secret.
Typical areas or situations requiring deployment of cryptographic
techniques, given the risks involved, include transmission and storage of
critical and/or sensitive data/information in an ‘un-trusted’ environment or
where a higher degree of security is required, generation of customer PINs
which are typically used for card transactions and online services, detection
of any unauthorised alteration of data/information and verification of the
authenticity of transactions or data/information. Since security is primarily
based on the encryption keys, effective key management is crucial.
15) Data security:
Banks need to define and implement procedures to ensure the integrity
and consistency of all data stored in electronic form, such as databases, data
warehouses and data archives.
16) Vulnerability Assessment:
Banks need to scan for vulnerabilities and address discovered flaws
proactively to avoid a significant likelihood of having their computer systems
compromised because any significant delays in finding or fixing software with
critical vulnerabilities provides ample opportunity for persistent attackers to
break through, gaining control over the vulnerable machines and getting access
to the sensitive data they contain.
17) Establishing on-going security monitoring processes:
A bank needs to have robust monitoring processes in place to identify
events and unusual activity patterns that could impact on the security of IT
assets. The strength of the monitoring controls needs to be proportionate to
the criticality of an IT asset. Alerts would need to be investigated in a
timely manner, with an appropriate response determined.
18) Security measures against Malware:
Malicious software is an integral and a dangerous aspect of internet
based threats which target end-users and organizations through modes like web
browsing, email attachments, mobile devices, and other vectors. Malicious code
may tamper with a system's contents, and capture sensitive data. It can also
spread to other systems. Modern malware aims to avoid signature-based and
behavioral detection, and may disable anti-virus tools running on the targeted
system. Anti-virus and anti-spyware software, collectively referred to as
anti-malware tools, help defend against these threats by attempting to detect
malware and block their execution. Banks should, therefore, have proper preventive
and detective/corrective controls at the host, network, and user levels to
protect against malicious codes by using layered combinations of technology,
policies and procedures and training.
19) Patch Management:
A documented standards / procedures for patch management needs to be
in place to address technical system and software vulnerabilities quickly and
effectively in order to reduce the likelihood of a serious business impact
arising.
20) Change Management:
Banks need to establish a change management process covering all types
of change. For example, upgrades and modifications to application and software,
modifications to business information, emergency ‘fixes’, and changes to the
computers/networks that support the application.
21) Audit trails:
Banks needs to ensure that audit trails exist for IT assets satisfying
the banks business requirements including regulatory and legal requirements,
facilitating audit, serving as forensic evidence when required and assisting in
dispute resolution.
22) Information security reporting and metrics:
Banks need to have security monitoring arrangements to provide key
decision-makers and Senior Management/Board of Directors with an informed view
of aspects like the effectiveness and efficiency of information security
arrangements, areas where improvement is required, information and systems that
are subject to an unacceptable level of risk, performance against quantitative,
objective targets, actions required to help minimize risk (e.g., reviewing the
organization’s risk appetite, understanding the information security threat
environment and encouraging business and system owners to remedy unacceptable
risks).
23) Information security and Critical service providers/vendors:
Banks use third-party service providers in a variety of different capacities
like an Internet service provider (ISP), application or managed service
provider (ASP/MSP) or business service provider (BSP). Management should
evaluate the role that the third party performs in relation to the IT
environment, related controls and control objectives and institute effective
third-party controls to enhance the ability of the bank to achieve its control
objectives.
24) Network Security:
Protection against growing cyber threats requires multiple layers of
defenses, known as defense in depth. As every organization is different, this
strategy should therefore be based on a balance between protection, capability,
cost, performance, and operational considerations. Some of the important network
protection devices are
a) Firewalls,
b)
Intrusion Detection
Systems
c)
Network Intrusion
Prevention Systems
d)
Quarantine
e)
DNS Placement
25) Remote Access:
Banks may sometimes provide employees, vendors, and others with access
to the institution’s network and computing resources through external
connections. Those connections are typically established through modems, the
internet, or private communications lines. Remote access to a bank’s provides
an attacker with the opportunity to manipulate and subvert the bank’s systems
from outside the physical security perimeter. The management should establish
policies restricting remote access and be aware of all remote-access devices
attached to their systems. These devices should be strictly controlled.
26) Distributed Denial of service attacks(DDoS/DoS):
Banks providing internet banking should be responsive to unusual
network traffic conditions/system performance and sudden surge in system
resource utilization which could be an indication of a DDoS attack.
Consequently, the success of any pre-emptive and reactive actions depends on
the deployment of appropriate tools to effectively detect, monitor and analyze
anomalies in networks and systems. Banks should, therefore, install and
configure network security devices appropriately for reasonable preventive/detective
capability.
27) Implementation of ISO 27001 Information Security Management
System:
Commercial banks should implement Information Security Management
System (ISMS) best practices for their critical functions/processes with the
best known ISMS as described in ISO/IEC 27001 and ISO/IEC 27002 and related
standards published jointly by ISO and IEC.
28) Wireless Security:
Wireless network includes all wireless data communication devices like
personal computers, cellular phones, PDAs, etc. connected to a bank’s internal
networks. Wireless networks security is a challenge since the wireless data
communication devices do not have well-defined perimeters or well-defined
access points and unauthorized monitoring and denial of service attacks can be
performed without a physical wire connection. Further, unauthorized devices can
potentially connect to the network, perform man-in-the- middle attacks, or
connect to other wireless devices. To mitigate those risks, wireless networks
rely on extensive use of encryption to authenticate users and devices and to
shield communications. The banks using a wireless network should, therefore,
carefully evaluate the risks involved and implement appropriate additional
controls.
29) Business Continuity Considerations:
Events that trigger the implementation of a business continuity plan
may have significant security implications. Depending on the event, some or all
of the elements of the security environment may change. Different tradeoffs may
exist between availability, integrity, confidentiality, and accountability,
with a different appetite for risk on the part of management. It is, therefore,
imperative that the business continuity plans are reviewed as an integral part
of the security process.
30) Information security assurance:
a) Penetration Testing:
Penetration testing is defined as a formalized set of procedures
designed to bypass the security controls of a system or organization for the
purpose of testing that system’s or organization’s resistance to such an
attack. Penetration testing is performed to uncover the security weaknesses of
a system and to determine the ways in which the system can be compromised by a
potential attacker.
b) Audits
Auditing compares current practices against a set of
policies/standards/guidelines formulated by the institution, regulator
including any legal requirements. Bank management is responsible for
demonstrating that the standards it adopts are appropriate for the institution.
Audits should not only look into technical aspects but also the information
security governance process.
c) Assessment
An assessment is a study to locate security vulnerabilities and
identify corrective actions. An assessment differs from an audit by not having
a set of standards to test against. It differs from a penetration test by providing
the tester with full access to the systems being tested. Assessments may be
focused on the security process or the information system. They may also focus
on different aspects of the information system, such as one or more hosts or
networks.
A bank should manage the information security risk management
framework on an ongoing basis as a security programme following project
management approach, addressing the control gaps in a systematic way.
31) General information regarding delivery channels:
Provision of various electronic banking channels like ATM/debit
cards/internet banking/phone banking should be issued only at the option of the
customers based on specific written or authenticated electronic requisition
along with a positive acknowledgement of the terms and conditions from the
customer. A customer should not be forced to opt for services in this regard.
Banks should provide clear information to their customers about the risks and
benefits of using e-banking delivery services to enable customers to decide on
choosing such services. When new operating features or functions, particularly
those relating to security, integrity and authentication, are being introduced,
the bank should ensure that customers have sufficient instruction and
information to be able to properly utilize them. Banks should sensitize
customers on the need to protect their PINs, security tokens, personal details
and other confidential data to raise security awareness levels. Banks need to
ensure suitable security measures for their web applications and take
reasonable mitigating measures against various web security risks.
6. EMERGING TECHNOLOGIES AND INFORMATION SECURITY:
The security concerns in respect of the technologies like
virtualisation and cloud computing which have been emerging increasingly of
late also need to be considered by Banks.
(a)
Virtualization
Of late, the trend in the data center has been towards
decentralization, also known as horizontal scaling because centralized servers
were seen as too expensive to purchase and maintain. However,
decentralization’s application sandboxes have a high annual maintenance cost and
lower efficiency. Virtualization is a modified solution between centralized and
decentralized deployments. Instead of purchasing and maintaining an entire
computer for one application, each application is given its own operating
system, and all those operating systems reside on a single piece of hardware.
This provides the benefits of decentralization, like security and stability,
while making the most of a machine’s resources.
Challenges
of Virtualization
a. Compatibility and support
b. Licensing
c. Staff training
d. Reliability
(b) Cloud Computing
Cloud computing refers to computing environment owned by a company which
is shared with client companies through web-based service over Internet which
hosts all the programs to run everything from e-mail to word processing to
complex data analysis programs. Service may include software, platform or
infrastructure. At the backend, cloud computing can make use of virtualization
and grid computing. In grid computing, networked computers are able to access
and use the resources of every other computer on the network.
Cloud
Computing Concerns
The biggest concerns about cloud computing are security and privacy.
7. IMPLEMENTATION OF RECOMMENDATIONS OF THE WORKING GROUP ON INFORMATION
SECURITY, ELECTRONIC BANKING, TECHNOLOGY RISK MANAGEMENT AND CYBER FRAUDS:
The
Banking Industry has been conscious of the challenges to Security and
appreciable efforts are being made by all the stakeholders in the context, viz.
Governments, Regulators, banks and technology providers. In this regard, the
Reserve Bank of India issued Guidelines
on Information security, Electronic Banking, Technology risk management and
cyber frauds in 2011, which were based on the report submitted by the
working group constituted by RBI under the Chairmanship of Shri. G.
Gopalakrishna, Executive Directror, RBI.
The guidelines are not “one-size-fits-all” and the implementation of
these recommendations need to be risk based and commensurate with the nature
and scope of activities engaged by banks, the technology environment prevalent
in the bank and the support rendered by technology to the business processes.
Banks with extensive leverage of technology to support business processes were
required to implement all the stipulations outlined in the circular. Banks were
also required to conduct a formal gap analysis between their current status and
stipulations as laid out in the guidelines and put in place a time-bound action
plan to address the gap and comply with the guidelines.
The guidelines are fundamentally expected to enhance safety, security,
efficiency in banking processes leading to benefits for banks and their
customers. The measures suggested for
implementation are not static. Banks need to pro-actively
create/fine-tune/modify their policies, procedures and technologies based on
new developments and emerging concerns.
8. CONCLUSION:
In the IT enabled
banking environment, information security is of paramount importance because it
involves tremendous risk that can result in huge business and financial losses
which can also assume international dimensions. As it is often said, in a
chain, it is the weakest link that is the most vulnerable. Therefore, it is not
only important to ab initio take
care of the information security risks but we also need to make sure
that the information security risk management process adopted by us is
continuously benchmarked against the international standards. There has to be a
paradigm shift in the perception about security in banking and the top
management’s response to the same. It is important for banks to realize that
they have a vital role and responsibility to ensure that appropriate risk management
measures are in place to avoid frauds, losses and business disruption.
It may be noted
that the real challenge in this environment goes beyond merely providing
additional technology solutions and increasingly complex security layers, and
translates into providing secured banking while balancing the same against
customer convenience requirements, which puts the regulators and security
implementers on the horns of a dilemma. For a Bank, while the challenges to
information security are stiff and are increasing by the day, being alive to
threats is of the highest importance. This also involves resources - human and
monetary, attitude and aptitude and a continuous monitoring and review of the
information security management processes.
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