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Interview<br />

UNHAPPY<br />

‘Modern slavery has<br />

rightly been made a<br />

priority across law<br />

enforcement, but it is a<br />

hidden crime so the<br />

onus is on us to seek it<br />

out.’<br />

Will Kerr, the National<br />

Crime Agency’s Director<br />

of Vulnerabilities.<br />

continued ... from page 30<br />

IT, for example<br />

a priority, and escalated<br />

or not. The various arms<br />

of the business such as IT<br />

and human resources, and<br />

research and development,<br />

and legal, have their own<br />

sub-risk groups, that feed<br />

into the overall register.<br />

The scoring is from one<br />

to five, the lower the<br />

better. How effective<br />

is the control? One for<br />

complete, five for not at<br />

all. What’s the likelihood<br />

of the risk happening?<br />

One for very unlikely,<br />

five for highly likely, and<br />

grades in between. And<br />

likewise with impact, from<br />

one for negligible to five<br />

for big. As a visual aid,<br />

the evaluation of the risk<br />

is coloured in a ‘traffic<br />

light’ system: green is all<br />

right, yellow is to keep<br />

and eye on, red is ‘do<br />

something about this’. It<br />

takes a spreadsheet to,<br />

even if only briefly, type<br />

the nature of the risk and<br />

its history of what you’ve<br />

done.<br />

A good example that Guy takes is<br />

IT assets. It’s not giving away any<br />

corporate secret that Suntory staff<br />

use laptops and other kit; like anyone<br />

else, they run the risk of losing them,<br />

whether in error or theft. The risks<br />

go further. It only takes a click to<br />

let in malware; and worse still if the<br />

business is running on an unsupported<br />

programme such as Windows XP,<br />

as parts of the National Health<br />

were found out in May thanks to<br />

the Wannacry ransomware. “It was<br />

encouraging,” Guy says, “that we had<br />

no breach.” But as an example of how<br />

risk management is not a one-off,<br />

but a process that you halt at your<br />

peril, Guy adds that Suntory comes<br />

under such cyber attacks consistently;<br />

the same as anyone else; and has<br />

measures to combat that. The register<br />

also gives the risk a category (in the<br />

case of IT assets, technological) and it<br />

has a named ‘owner’. Cyber security<br />

policy is documented, so that people<br />

know what to do if something does go<br />

wrong. Another control mechanism<br />

that Guy points out, that’s easily<br />

overlooked, is capex estimates. As<br />

he says, you have a team to evaluate<br />

risk; but have you estimated what<br />

the budgetary cost would be, for<br />

what’s proposed - to encrypt every<br />

laptop, for example, or to pull staff<br />

away for cyber awareness training?<br />

Do you need to factor that in? Later,<br />

Guy points out the temptation to<br />

actually or at least say you’re going<br />

to throw money at a problem; if you<br />

have that money; and what if you<br />

can only find that money by taking<br />

it from elsewhere. Hence the scoring<br />

of risk matters, to give some sense<br />

to priorities. To leave Guy for a<br />

minute; it may have seemed sensible,<br />

or an acceptable risk to skimp on a<br />

Windows update; only to prove a<br />

false economy when you can’t do<br />

a thing because you’re a victim of<br />

ransomware. Back to Suntory. Once<br />

they complete a control (such as<br />

that training of staff), they assess<br />

how effective it is, and give a new<br />

score and priority to the risk; most<br />

obviously, seeking to bring the red<br />

down to a yellow or green.<br />

Attention to detail<br />

As Guy sets it out, it becomes plain<br />

that such attention to detail is the only<br />

way to keep up with everything - the<br />

visible and the invisible cyber - that<br />

can and does happen to a business.<br />

The sub-risk groups send their<br />

findings into what Guy describes as<br />

a clearing house, that evaluates. To<br />

stay with the IT assets as a risk; IT<br />

flag it, but is the risk really at a level<br />

that they say it is? Thus you build the<br />

‘master risk register’, that Guy and<br />

colleagues will work on continuously:<br />

“So it should always be a live<br />

document.” It’s subjective, as Guy<br />

admits - to stay with the example, IT,<br />

close to the risk, have one evaluation<br />

of the risk, others another. Likewise,<br />

how many risks do you list: a top ten?<br />

15? 50? When if ever is it sensible to<br />

stop?<br />

Routine<br />

Guy now calls up another document,<br />

the ‘corporate governance cycle<br />

time-line’. Again, it’s hardly giving<br />

away a secret that inside the 12-month<br />

year, divided into quarters, you<br />

have a routine that begins with<br />

the risk sub-groups reporting to<br />

Guy and colleagues to collate. The<br />

clearing house meets, to judge those<br />

identified risks. Updates go to a risk<br />

management committee, that may<br />

invite the head of the IT risk sub-team<br />

to talk about a particularly burning<br />

issue. Next, an ethics and compliance<br />

committee meets; to take everything<br />

in the round. Then the register goes in<br />

front of the board. And you finish the<br />

loop, with the sub-groups beginning<br />

again: “So you are constantly trying<br />

to refresh that risk. In an ideal world,<br />

you wouldn’t get to a point where the<br />

risk registers were static.”<br />

Movers and shakers<br />

Another document Guy shows is<br />

the numbered top risks. Guy shows<br />

his age by likening it to ‘Top of the<br />

Pops’; what are the ‘movers and<br />

shakers’. Instead of pop music, it’s<br />

familiar UK business stuff: Brexit,<br />

supply chain, IT. As Guy says,<br />

pointing towards the screen: “So<br />

much of this I would argue would be<br />

pretty consistent for most business<br />

sectors.” Guy closes by showing a<br />

Venn diagram; the three overlapping<br />

circles represent crisis management,<br />

risk management and business<br />

continuity planning. In the middle<br />

is a enterprise risk management<br />

system. Again, it’ll be familiar to<br />

other corporates, who may express it<br />

differently, in a quadrant for example.<br />

And like any other multi-national<br />

company, Suntory needs a way<br />

to pass on between countries an<br />

identified risk. Some risks straddle<br />

countries, such as the general data<br />

protection regulation, that is due to<br />

come into force in 2018; sensibly, as<br />

it’s European Union-wide, Suntory<br />

are working on it at a European<br />

level. Given that any product can<br />

have ingredients from one country<br />

(or continent) taken to a factory in<br />

another, and sold in another, if a<br />

‘Watchdog’ TV show in one country<br />

unveils some compliance failing,<br />

whether a car or a washing machine,<br />

it may damage the wider reputation of<br />

the business. Underlying all this, you<br />

assume, that the physical premises<br />

security of your factory is sound; and<br />

that is where we’ll go next. p<br />

32 OCTOBER 2017 PROFESSIONAL SECURITY www.professionalsecurity.co.uk

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