Should companies be required to publish security reviews?
I recently attended a cyber security conference about the current preparedness and future of cyber crime and security in the UK.
One of the audience members made a comment about how seriously businesses take their own security. He thought that, as with annual financial returns, business should be required to certify their own security credentials on an annual basis.
Many incidents of fraud occur not through cards being physically stolen, but through breaches in security at the shops we buy products from. The 2013 breach at Target is an example, the result of which might be that we decide not to shop there again.
Where we can make these consumer choices, the market is operating as it should. But it’s more challenging if the problem exists further down the chain. Perhaps the vendor used by the store for credit checking is the one that suffers a breach, such as at Equifax in 2017. Or more recently, the Ticketmaster incident, which was blamed on a third party component in their customer support system. How can consumers check several orders down into the supply chain?
Of course this is the idea behind one of the GDPR requirements to provide a list of all the third parties that data is being transferred to. But with companies like PayPal sharing data with hundreds of organisations, is it reasonable to expect consumers to check them all? Or any of them? And what would they actually check?
The Government already runs a certification programme called Cyber Essentials. If you want to sell into certain areas of government then you have to have a Cyber Essentials certification. Requiring vendors to certify helps with the government’s supply chain assurance at the same time as encouraging adoption of a UK standard.
But only around 10,000 businesses have certified in the 4 years the scheme has been operating. Is it a lack of awareness about the scheme or do customers and suppliers outside of government just not care? Maybe a combination of both.
As a consumer, you can’t easily assess security from the outside. You can only go on whether there have ever been any historical incidents and even then, that doesn’t tell you much about the state of their security today. So perhaps that audience member was onto something with requiring annual reporting?
There is also a power dynamic at work. The UK Government can mandate all of its suppliers comply with a particular certification because they all want to sell to government. But what if it were the other way around? Or swap the Government for another big organisation. Good luck requiring your suppliers to implement something similar if you’re just a small business.
It is impossible to have 100% security and breaches are inevitable, but as a customer you want to know that companies are taking basic steps to protect you – things like using strong passwords and keeping their systems up to date. It sounds simple, but one of the more interesting statistics from the conference I attended was that 80-90% of instances of cyber crime could be prevented by people having strong passwords and by keeping their computers and devices up to date. Surely these are basic security precautions all businesses should be expected to take.
Companies are already required to submit financial reports and annual statements about company details to Companies House. Would adding a security questionnaire to that return make a difference?
Voluntary compliance is often the first step because the companies that don’t provide the information are liable to be asked: why not? But then Cyber Essentials is already voluntary and not many businesses have certified. Maybe more would participate if it was free (there’s currently a £300 fee) and it just asked you about the current status, rather than requiring active steps to achieve a certification. Perhaps a grading system could indicate what level of security a business has in place which could show on the Companies House search record.
How many people would actually check this? Financial information about companies is already available but how often are returns checked before signing a contract? Suppliers sometimes run credit checks before offering credit terms but then there are multiple outcomes, such as the length of credit. A security check could only really have two outcomes – to do business, or not.
Last year, I wrote about how the supply side of the market was broken in relation to the security of consumer devices. Consumers should be able to expect product security just like they expect product safety. The good news is that they can indeed now expect this. In March this year, a report was released by the Department for Digital, Culture, Media and Sport alongside a new code of practice. Device manufacturers now have an incentive to build their products with security by design. If they don’t, the next step is regulation.
This is good for assurance of the security of consumer internet of things devices, but at what point does not using a secure password and keeping your systems up to date become negligence? Is the next step extending secure by design from internet of things devices to day to day general company administration?