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This is an important judgement at a time when regulators are looking to increase cybersecurity risk management oversight, assurance and attestation. The case highlights the courts view of the role of the CSO at the time of the incident and subsequently. The role of the CSO as it relates to incident reporting, oversight, assurance and attestation and penalties for failing to comply. Note the role of the board was not discussed. Albeit in this case the FTC were already onsite.
Boards, CSO/ CISOs will face conflict when it comes to cybersecurity disclosure, that maybe good for both. But Security Professionals that will be required to work at the board table will need the professional strength and independence (3rd Line) to be able to manage cybersecurity risk. Alternatively as E.J. Hilbert points out they may walk, exposing the board at a time when significant regulatory pressures are building.
#cybersecurity #cyberriskmanagement #cyberlaw #theaugustagroup
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