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CYBER RESILIENCE HOW TO PROTECT SMALL FIRMS IN THE DIGITAL ECONOMY

FSB-Cyber-Resilience-report-2016

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fsb.org.uk<br />

The role of the private sector in increasing cyber resilience<br />

The private sector also needs to adapt to improve overall cyber resilience. The rebalancing of<br />

responsibility within the private sector should include:<br />

• Businesses taking as much responsibility as is practical for them to do so. Small businesses<br />

need to be made more aware of the risks that come through operating online. Only with a<br />

better understanding of the risks and the possible negative impact they can have, will small<br />

businesses be able to adjust their practices and processes in the most effective ways. Owing to<br />

the constraints they operate under, small businesses need support from others to help take the<br />

actions necessary to increase their cyber resilience. There are also many things that resource<br />

and knowledge constraints mean small businesses will not be able to do or are not best placed<br />

to do.<br />

• More measures taken by the digital infrastructure providers to help protect users who are not<br />

adequately resourced to protect themselves, such as small businesses.<br />

• The larger economic infrastructure providers taking more responsibility through increasing the<br />

cyber resilience of their systems and practices, in addition to helping their vulnerable users,<br />

such as small businesses, improve their own cyber resilience.<br />

1. Strong foundations for cyber resilience policy<br />

Before outlining specific measures aimed at dealing with the three categories of causes of cyber risk,<br />

Government can make a number of reforms that will provide a set of strong foundations.<br />

A more flexible approach to regulation<br />

Before looking at specific areas of regulation or specific regulations and regulatory reforms, the<br />

Government should look in detail at:<br />

• Its general approach to regulating cyber resilience issues. The fast changing world of cyber<br />

threats and the risks they pose raise questions about the viability of aspects of the current mode<br />

of regulation.<br />

• Making sure that its ability to deliver services to the business community is resilient. There is little<br />

point in the Government playing a major role in implementing measures to help and encourage<br />

the private sector to be more cyber resilient if Government is not sufficiently resilient itself.<br />

Regulating for cyber resilience<br />

Traditional regulation is based on a prescriptive command and control model, where detailed<br />

standards are set out and compliance with those standards is monitored through reporting and<br />

external inspection.<br />

These standards do not usually reflect risk, but instead are based on hazard. The latter can lead to<br />

regulatory micro-management and unnecessary burdens rather than generating buy in from those<br />

being regulated. This hinders the development of broader behavioural changes which are needed<br />

to change the norms of complex systems.<br />

The problems of regulating security issues associated with the digital communications technologies<br />

this way, are well known:<br />

“Regulations that dictate specific solutions can be a poor fit for cyberspace…[a]…focus on<br />

compliance can turn security from an iterative, adaptive process to an organisational routine<br />

disconnected from the risks faced. Compliance replaces accountability, since organisations can<br />

avoid any decision that might improve security”. 81<br />

Singer, P W and Friedman A, Cyber Security and Cyber War: what everyone needs to know<br />

81 Singer, P W and Friedman A, Cyber Security and Cyber War: what everyone needs to know, 2014.<br />

33

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