Kunal Malhotra

Overview

A leading financial institution in the UAE aimed to upgrade its cybersecurity governance & framework by revising & developing a set of cybersecurity policies & procedures. The project’s goal was to ensure that the institution's cybersecurity approach aligned with international best practices (NIST, COBIT) & regional regulations (NESA), while also enabling proactive risk management & compliance.

The developed policies & procedures were designed to address critical areas, including risk management, incident response, data protection, & third-party risk management, thereby providing the institution with the tools needed to defend against emerging cyber threats & adhere to regulatory requirements.

Challenge

• Fragmented & Outdated Policies: The institution’s existing policies were inconsistent, outdated, & lacked alignment with the latest cybersecurity frameworks & regulations.
• Complex Regulatory Compliance Needs: Keeping up with rapidly evolving regulations from NESA, NIST, & COBIT while ensuring compliance with both regional & international standards was a complex task.
• Cross-Departmental Collaboration: SEnsuring alignment between the IT, legal, compliance, & business teams to create standardized cybersecurity processes was challenging, especially in a large organization.

Approach & Methodology

• Stakeholder Consultation & Gap Analysis: The project began with an in-depth gap analysis of the institution’s existing cybersecurity policies & procedures. We engaged key stakeholders from various departments (IT, compliance, legal, risk management) to identify the gaps & needs. The gap analysis was followed by mapping these requirements to the NESA, NIST, & COBIT frameworks.
• Policy Development & Standardization: Developed cybersecurity policies & procedures across key domains, including governance, incident response, data protection, & third-party management. Each document was carefully crafted to ensure it aligned with international standards while meeting the specific operational needs of the institution.
• Iterative Review & Feedback: A collaborative, iterative review process was employed, allowing each department to provide feedback & input on the drafts. This ensured that the documents were not only comprehensive but also practical & actionable for staff.
• Training & Awareness: Developed tailored training sessions & awareness campaigns to ensure that employees understood the newly introduced policies & procedures. This included specialized sessions for IT & compliance teams, as well as broader awareness programs for the entire organization.

Deliverables

The project resulted in the development & implementation of comprehensive cybersecurity policies & procedures, grouped into important operational & regulatory categories. Below is a breakdown of the deliverables, including specific details on what was done for each policy & procedure:

• Compliance Mapping Tool: A tool mapping each policy & procedure to relevant sections of NESA, NIST, & COBIT, enabling easy verification of the institution's compliance status.
• Implementation Guidelines: A comprehensive guide detailing how the policies & procedures should be integrated into daily operations, along with mechanisms for continuous monitoring & review.
• Employee Training & Awareness Program: Custom training modules covering the new policies, focusing on the roles & responsibilities of each employee to ensure full adoption across the organization.
• Executive Report: A high-level strategic report that summarizes the key findings, recommendations, and outcomes of the project. It includes an overview of the policies & procedures developed, their alignment with regulatory requirements, and the anticipated impact on the institution’s cybersecurity posture. This report serves as a key communication tool for senior leadership, providing them with a concise and actionable summary of the project’s success and the next steps for ongoing implementation & compliance.
• Policies:
• Cybersecurity Governance Policy: Defined roles, responsibilities, & processes for managing cybersecurity risks & ensuring compliance. It established a governance framework aligned with NESA, NIST, & COBIT, emphasizing continuous improvement & board-level oversight.
• Data Protection & Privacy Policy: Outlined data protection principles, including data classification, storage, access, retention, & sharing practices, ensuring compliance with data privacy regulations such as GDPR & UAE’s data protection laws.
• Incident Response & Management Policy: Established a clear, structured approach for identifying, assessing, & responding to cybersecurity incidents. Detailed the roles of response teams & required integration with external agencies in the case of major incidents.
• Risk Management Policy: Defined processes for identifying, assessing, & managing cybersecurity risks across all operations. It integrated risk management principles from NIST & COBIT, ensuring a proactive approach to risk mitigation.
• Access Control Policy: Detailed access control mechanisms for systems, applications, & sensitive data, ensuring the principles of least privilege & segregation of duties are enforced. It also covered user account management & authentication requirements.
• Third-Party Risk Management Policy: Set clear guidelines for assessing & managing cybersecurity risks associated with third-party vendors, ensuring due diligence is performed on all external partnerships, including regular assessments & audits.
• Business Continuity & Disaster Recovery Policy: Developed a strategy for ensuring business continuity in the event of a cyber incident or natural disaster. Detailed disaster recovery protocols, including recovery time objectives (RTO) & recovery point objectives (RPO).
• Data Classification & Handling Policy: Defined data classification levels & specific handling procedures for each type of data, ensuring sensitive data is properly protected throughout its lifecycle.
• Backup & Recovery Policy: Provided guidelines for regularly backing up critical data & ensuring that recovery processes are in place for a swift restoration of services in the event of data loss or cyber incidents.
• Change Management Policy: Standardized the process for managing system & software changes, ensuring that all changes are documented, tested, & approved to minimize the risk of introducing vulnerabilities.

(… and so on for the other policies…)

• Procedures:
• Risk Assessment Procedure: Detailed steps for conducting regular cybersecurity risk assessments, including vulnerability scanning, threat modeling, & reporting, to identify & mitigate risks proactively.
• Vulnerability Management Procedure: Defined processes for identifying, tracking, & remediating vulnerabilities across systems & applications, ensuring timely patching & risk reduction.
• Incident Identification & Classification Procedure: Created a clear method for identifying & categorizing cybersecurity incidents, allowing for a swift response based on the severity of the threat.
• Security Event Logging & Monitoring Procedure: Defined procedures for logging, monitoring, & analyzing security events to detect & respond to potential security incidents in real time.
• Change Management Procedure: Standardized the process for implementing changes to systems & applications, ensuring changes are tested, approved, & documented to minimize security risks.
• Access Management Procedure: Detailed processes for granting, modifying, & revoking access to systems & data, ensuring appropriate access control is maintained throughout an employee’s lifecycle.
• Backup & Restore Procedure: Defined data classification levels & specific handling procedures for each type of data, ensuring sensitive data is properly protected throughout its lifecycle.
• Employee Onboarding/Offboarding Security Procedure: Established guidelines for managing employee access during onboarding & offboarding, including granting/revoking access, returning assets, & ensuring secure data handling.

(… and so on for the other procedures…)

Outcome

The development & implementation of detailed cybersecurity policies & procedures has significantly enhanced the institution's cybersecurity risk management & compliance posture. The alignment with NESA framework, NIST, & COBIT has ensured the institution is in full compliance with regional & global standards, reducing exposure to risks & ensuring regulatory adherence. Key outcomes include:

• Unified Cybersecurity Governance: The introduction of standardized policies & procedures provide a unified approach to managing cybersecurity risks, improving overall governance.
• Improved Risk Mitigation: Clearly defined processes for proactively assessing, managing, & mitigating cybersecurity risks, ensuring a more resilient IT environment.
• Faster Incident Response: Detailed incident response procedures to significantly enhance the institution’s ability to respond to & recover from security breaches quickly & effectively, minimizing potential damage.
• Regulatory Compliance: Full alignment with NESA, NIST, & COBIT ensures compliance with regional & global standards, reducing the risk of fines, penalties, or reputational damage.