Boardroom leadership: Cyber risk management as a strategic imperative
Robert S Mueller III, the former Director of the FBI, famously said: “There are only two types of companies: Those that have been hacked and those that don’t know they have been hacked”.
In today’s hyper-connected and digitalised landscape, Australian directors of organisations of all sizes face a rapidly evolving cyber risk environment that transcends traditional IT boundaries. Cyber threats are ubiquitous and sophisticated, capable of disrupting core business operations, eroding brand trust, and triggering significant financial and legal consequences. Effective cyber risk management is no longer a technical issue to be delegated to the IT department. It is a strategic imperative that must be championed at the board level and embedded throughout an organisation.
Directors have many obligations imposed on them by regulators such as ASIC, APRA, and through the ASX Governance and the AICD Cyber Governance Principles to actively oversee these risks. They also have other legal obligations under the Corporations Act, Privacy Act, and industry-specific regulations, with potential exposure to penalties and personal liability for failure to govern cyber exposure effectively.
Below are the 6 key steps that inform a comprehensive cyber risk management governance process. The second version of the AICD and CSCRC’s Cyber Security Governance Principles, recently released, sets the gold standard for cyber governance in Australia. The following key steps amalgamate those Principles with other risk management best practice actions at a board level.
1. Understand the risks
A structured approach to cyber risk governance begins with an understanding of the multifaceted risks at play. These risks can be summarised as follows:
- Business interruption risk: Disruption to critical processes and potential downtime that can impede business outcomes.
- Financial risk: Direct and indirect losses, including business interruption and incident response costs.
- Brand and reputational risk: Damage due to the failure to protect confidential and sensitive information and the subsequent impact on reputation.
- Legal and regulatory risk: Penalties and liabilities due to non-compliance with privacy and other legislation and regulations.
- Third-party liability risk: Exposure to claims from supply chain partners, customers or impacted individuals harmed by a cyber incident.
These risks must be systematically evaluated and addressed in the formulation and execution of a strategy designed to safeguard an organisation from cyber exposure.
2. Develop a clear cyber risk management strategy
The board should actively guide and support the CEO and executives in the formulation of a robust and comprehensive cybersecurity strategy which clearly outlines the framework underpinning the organisation’s approach to protecting its digital assets, systems, networks and data. The identification of the critical assets to be protected or “crown jewels” is a foundational step, enabling a focused approach towards allocation of resources towards their protection.
A comprehensive cyber risk security strategy includes a clear identification of the roles and responsibilities of those within the organisation tasked with managing cyber risk and incident response and should also outline cyber security measures and methodology around dealing with cyber risk. The cyber risk strategy should be driven by the organisational risk appetite identified by the board, which will ultimately drive the desired level of maturity and investment.
3. Ensure cyber risk management complements the organisation’s enterprise-wide risk management approach
Cyber risk is just one of many operational and emerging risks faced by any organisation. As such, it should fall within an organisation’s enterprise-wide approach to risk. Procedures and policies for the management of cyber risk should include the appropriate controls and structure to complement the board-approved risk appetite.
Whilst cyber risk has a deeply technical aspect, the supervision, identification, analysis and evaluation of cyber risk should be harmonised with the organisations general risk management approach, and as such, ensure a consistent and holistic approach to organisational risk.
4. Develop a cyber security risk culture
Boards play a critical role in shaping an organisation’s approach to cyber awareness and risk management by creating and perpetuating a culture where cyber security is a strategic imperative and not an IT issue. It is a responsibility of the whole organisation.
Cybersecurity and risk management should be a regular agenda item in board meetings to ensure ongoing focus and visibility. Boards should promote and engage in cyber awareness training and education, lead by example and set the tone at the top. Security education, training, and awareness programs should be rolled out to all employees, and regular discussion, testing and monitoring of understanding of corporate culture around digital safety is critical.
By highlighting and being engaged in understanding cyber risk and championing a cyber security culture, boards can foster a proactive and resilient workforce, reducing organisational vulnerability and ensuring ongoing compliance with evolving regulatory expectations.
5. Expect a cyber incident and prepare for a cyber crisis
In any crisis, the board’s responsibility is to ensure that management has developed and implemented effective crisis management and business continuity plans to minimise harm and risks during the incident.
Organisations that respond effectively to, and recover quickly from, cyber crises are those with comprehensive, regularly updated and well-rehearsed cyber incident response procedures. The critical importance of “preparation for an incident” cannot be underestimated. Regular simulations, tabletop exercises, and internal and independent review of cyber incident response procedures are essential to respond to evolving and emerging threat vectors and risks. Multiple playbooks for varying scenarios are recommended.
6. Monitor and evaluate cyber risk management effectiveness
Cyber risk management strategies require ongoing assessment to ensure efficacy, integration and investment value. Metrics – whether qualitative or quantitative are valuable not only for monitoring risk but also for communicating technical risk at a board level. Regular reporting and evaluation of metrics enables organisations to continually validate and adapt cyber risk management procedures.
Information security in the digital era means that directors are not just the stewards of capital; they must act as the guardians of trust, reputation, financial stability and operational continuity. The boardroom has become the frontline of cyber defence, where strategic foresight and rigorous governance can literally be the difference between resilience and business ruin. By embracing cyber risk as a core element of corporate strategy, directors can lead with diligence and confidence that they are successfully fostering a cyber-resilient organisation.
About Gill Collins – Guest Contributor
Gill Collins GAICD is a non-executive director with extensive expertise in enterprise risk management, cyber risk and resilience, corporate governance, strategy, and culture. She previously led Marsh McLennan’s cyber business in the Pacific and served as General Counsel for Chubb Insurance Europe and Australian Claims Manager for Chubb Insurance Australia. Gill has also founded and managed two successful advisory firms specialising in insurance, law, and cyber risk management.
